Last Updated: August 20th, 2019
This Privacy Policy (the “Privacy Policy”) serves to inform you of our policies and procedures regarding the collection, use and disclosure of the information we receive when you access and use this website (the “Site”), and all products and services available on the Site (all of the foregoing collectively, the “Services”) owned, controlled or offered, directly or indirectly, by Habla Incorporated (“Habla”, “we,” “our” or “us”). Users, account holders, customers, visitors, and others who download, access, use and/or subscribe to the Services (“you”) agree to the following Privacy Policy. The Privacy Policy is incorporated by reference into our Terms of Service, currently available at https://getwulu.com/tos (the “Terms of Service”). By using the Services, you hereby warrant and represent that you have read, understand and agree to this Privacy Policy and the Terms of Service and that you are over 13 years of age. PLEASE DO NOT USE, INSTALL OR ACCESS THE SERVICES IF YOU DO NOT AGREE TO THIS PRIVACY POLICY.
IMPORTANT – TRANSFER OF DATA AND PERSONAL INFORMATION TO THE U.S.
WE PRIMARILY STORE DATA ABOUT YOU, INCLUDING PERSONAL INFORMATION, ON SERVERS LOCATED AND OPERATED WITHIN THE UNITED STATES. IF YOU RESIDE OUTSIDE OF THE UNITED STATES, IN ORDER TO PROVIDE THE SERVICES TO YOU, WE MAY SEND AND STORE YOUR PERSONAL INFORMATION (ALSO COMMONLY REFERRED TO AS PERSONAL DATA) OUTSIDE OF THE COUNTRY WHERE YOU RESIDE OR ARE LOCATED, TO THE UNITED STATES. THEREFORE, OUR COLLECTION AND USE OF YOUR PERSONAL INFORMATION IS SUBJECT TO THE UNITED STATES’ LAWS RELATED TO PRIVACY AND USE OF PERSONAL DATA AND INFORMATION. THESE LAWS, INCLUDING WHAT IS DETERMINED TO BE “PERSONAL DATA AND/OR INFORMATION,” ARE DIFFERENT AND MAY BE LESS PROTECTIVE THAN THOSE APPLICABLE TO YOU IN YOUR COUNTRY OF RESIDENCE. BY ACCEPTING THE TERMS OF THIS PRIVACY POLICY, YOU ACKNOWLEDGE, AGREE AND CONSENT TO (1) THE TRANSFER TO AND PROCESSING OF PERSONAL INFORMATION ON SERVERS LOCATED OUTSIDE OF THE COUNTRY WHERE YOU RESIDE, (2) OUR COLLECTION AND USE OF YOUR PERSONAL INFORMATION AS DESCRIBED HEREIN AND IN ACCORDANCE WITH THE LAWS OF THE UNITED STATES THAT MAY BE DIFFERENT AND MAY BE LESS PROTECTIVE THAN THOSE IN YOUR COUNTRY AND (3) THAT YOU ARE TAKING A RISK BY USING THE SITES AND SERVICES.
EU-US and Swiss-US Privacy Shield
Habla’s commitment to comply with the Privacy Shield Principles
Habla is a participant in the Privacy Shield and has self-certified to the Privacy Shield Frameworks. Habla confirms it commitment to comply with the EU-US Privacy Shield Framework and the Swiss – U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and notion of personal information from the European Union and Switzerland to the United States, respectively. Habla has certified to the Department of Commerce that it adheres to each of the Privacy Shield Principles: Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit
Accountability for onward transfers
Habla’s accountability for personal data that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Habla remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless Habla proves that it is not responsible for the event giving rise to the damage.
Right of access
You have a legal right to request the personal information about you held by us. On request, we will provide you with a copy of this information. You also have a right to correct, amend or delete such personal information where it is inaccurate or has been processed in violation of the Privacy Shield Principles.
Resolution of disputes and complaint mechanism
In compliance with the Privacy Shield Principles, Habla commits to resolve complaints about your privacy and our collection or use of your personal information. If European Union or Swiss individuals have any queries related to the processing of your personal information under the Privacy Shield framework, we encourage you to contact us directly in the first instance at: support+wulu@olark.com or Habla Privacy, 205 ½ N Main St., Ann Arbor, MI 48104.
Independent recourse mechanism
In compliance with the EU-US and Swiss-US Privacy Shield Principles, Habla commits to resolve complaints about your privacy and our collection or use of your personal information.
European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact Habla at:
support+wulu@olark.com OR Privacy Shield Compliance Habla Incorporated (“Habla”) 205 ½ N Main St. Ann Arbor, MI 48104
Habla has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit
Binding arbitration
As further explained in the Privacy Shield Principles, a binding arbitration option before the Privacy Shield Panel will also be made available to you in order to address residual complaints not resolved by any other means.
Enforcement
Habla is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC). Please be aware that Habla may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. Information We Collect
Personal Information
“Personal Information” means data that allows someone to identify or contact you, including, for example, your name, address, geographic location of your computer or mobile device, telephone number, email address, availability, online video/chat services login, and credit card information, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. We may collect Personal Information from you when you (i) use our mobile apps or visit the Site, (ii) register for Services or create an account or profile (an “Account”), (iii) access the Services through social networking sites or third party services, (iv) subscribe to newsletters; (v) purchase a product or Services on the Site or in our mobile apps (“in-app purchase”); (vi) invite your contacts to visit the Site or join the Services, “share” the Services or Site on social networking sites or perform other similar features; (vii) request technical support; and (viii) otherwise use our mobile apps or online Services where Personal Information is required for such use and/or participation. The Personal Information we collect will vary depending upon the Services you use and may include your name, email address, phone number, birth date, company name, mobile phone number and credit card information.
We may use, depending on the Services, (i) location based on the IP address presented by you, (ii) network-based geo-location data based on proximity of network towers or the location of Wi-Fi networks, and/or (iii) geo-location data based on coordinates obtained from a mobile device’s GPS radio and location services. Your GPS geo-location is not accessed without your consent. If location services are enabled on your mobile device, certain of the Services will passively and automatically send location information to Habla so we can deliver location-specific information on your device and compile your individualized timeline. Please note that disabling location service will not anonymize data already collected and uploaded to our servers.
In this Privacy Policy, we refer to all information collected from or about you, including Personal Information and non-Personal Information, as “Your Information.”
Information You Provide Us
If you choose to sign up for an Account, we may collect and process certain Personally Identifiable Information that you provide us, such as your full name, photo, birthdate, phone number, online video/chat services login, access to contacts or your availability stored on your mobile device or tablet computer or linked third party account, and e-mail address. We may also retain the contents of any messages you send to us or through the Services, and we may collect information you provide in user content that you post or upload to the Services (“User Content”).
Automatically Collected Information
We may now or in the future receive Personally Identifiable Information about you from third parties. For example, if you access our Site or Services through a third-party connection or log-in, including social networking services such as Google, Facebook, Twitter, Instagram, or LinkedIn, linking your account to the Services, etc., that third party may pass certain information about you or your use of its service to Habla. This information could include, but is not limited to, the user ID associated with your account (for example, your Facebook user identification), an access token necessary to access that service, any information that you have permitted the third party to share with us, and any information you have made public in connection with that service. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to the Services. In addition, we and other third parties use cookies and other technologies to passively collect non-Personal Information as described. The information collected typically includes browser, mobile device, such as model, device IDs or other device identifiers, operating system or platform type, IP Address (as defined below), devise language and time zone, network Media Access Control (MAC) address and connection, referring site, list of search terms entered, and the date and time of each visitor request. When you download any content from the Site or use the Services, information such as usage information, including without limitation, length of time spent accessing the Services and click paths, device information, and debug logs will be tracked and communicated back to a centralized server. We collect this data to best serve our users.
Cookies and Other Technologies
When you visit websites on the Internet, your browser may automatically transmit information to the websites you visit throughout every visit. Like many websites, we may use “cookies” to collect information. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. You consent to the use of cookies, web beacons, and log file information to: (i) operate the Site, (ii) store information so that you will not have to re-enter it during your visit or the next time you login to use the Site; (iii) provide custom, personalized content and information; (iv) monitor the effectiveness of our marketing campaigns; (v) monitor aggregate metrics such as total number of visitors and pages viewed; and (vi) track your entries, submissions, and status in promotions, sweepstakes, and contests. If you are logged in to your account, we may associate the Personal Information with your account. Unlike persistent cookies, session cookies are deleted from your computer when you log off from the Site and then close your browser. Third party tools in the Site may also place or read cookies on your browser and we may use Flash cookies (or local shared objects) to store your preferences or use on the Site to personalize your visit. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you will not be able to use all portions or all functionalities of the Site. We and our service providers may also use “pixel tags,” “web beacons,” “clear GIFs,” or similar means in connection with the Services and HTML-formatted email messages to, among other things, track the actions of users, to determine the success of marketing campaigns and to compile aggregate statistics about Site usage and response rates. This information is collected anonymously, in a manner that does not personally identify you.
IP Address
When you visit and interact with the Site, we and/or third parties with whom we have contracted to provide services to us may collect your Internet Protocol Address (“IP Address”), which is a number that is automatically assigned to the computer that you are using by your Internet Service Provider. This number is identified and logged automatically in our server log files whenever you visit the Site, along with the time(s) of your visit(s) and the page(s) that you visited. We use IP Addresses to monitor the regions from which Users navigate the Site and for fraud prevention purposes.
Do Not Track
You may have implemented a “do not track” signal through your browser. As there currently is no fixed standard for do not track signals, we currently do not respond to do not track signals from your web browser
Use of Collected Information
Habla believes that the privacy of its users is paramount and strives to use their data only in ways outlined in this Privacy Policy. By providing Your Information to us, you are expressly and voluntarily accepting the Terms of Service and freely accepting and agreeing to our processing of Your Information in ways set forth in this Privacy Policy. Supplying to us any information deemed “sensitive” by applicable law is entirely voluntary on your part. Most uses of the collected data are for internal purposes or in order to provide the services such as a feature that enables interaction between (i) you and other users, and / or (ii) you and third party service providers.
When you submit Your Information to us, it is collected, processed and maintained by us or by third party service providers who are bound by privacy restrictions at least as restrictive as those set forth in this Privacy Policy. Your Information is used and disclosed for, but is not limited to, the following purposes: (i) to provide the Services, including without limitation to collect and remit payment for paid features and enable interaction with other users, as applicable, (ii) to administer your use of the Services and any Accounts you may have with us, (iii) to personalize your experience, (iv) to provide to you Service announcements or inform you of new releases and features, (v) to provide you with further information and offers from us or third parties that we believe you may find useful or interesting, such as newsletters, marketing or promotional materials, (vi) to perform tasks on behalf of and according to instructions of a third party, (vii) to enforce our Terms of Service, (viii) to resolve any disputes between users of the Site or between such users and us, and (ix) to contact you to obtain feedback from you regarding the Site and the Services. If you decide at any time that you no longer wish to receive such contact, announcements, information or offers, please follow the unsubscribe instructions provided in the communication or update your settings in your personal profile.
We use non-Personal Information for the above purposes and in addition in order to (i) monitor and analyze use of the Services and for the technical administration of the Site, (ii) improve the Site and the Services, (iii) generate and derive useful data and information concerning the interests, characteristics and website use behavior of our users, and (iv) verify that users of the Services meet the criteria required to process their requests.
Service Providers
We may share or collect your Private Information in collaboration with our third party service providers (“Partners”), including companies that assist with payment processing, business analytics, data processing, account management, providing or enabling certain features in the Services, and other services. We instruct these Partners to not use your Personal Information themselves or share it with another party not under a similar contract to provide service to us, and to only use your Personal Information for the specific services we have requested for us or on your behalf.
Other users:
If you elect to post something in a public area of our Services or using a feature that enables interaction between users (for example, using our video/chat services, enabling access to your availability information to people in your contact list), any Personally Identifiable Information or content that you voluntarily disclose for posting to the Services, becomes available to the public, as controlled by any applicable privacy settings. If you remove information that you posted to the Services, copies may remain viewable in cached and archived pages of the Services, or if other users have copied or saved that information.
Corporate Transactions
Habla may disclose certain information in the event that it is merged, acquired, sold, or some of its assets are acquired. Habla will endeavor to ensure that the entity who receives your information treats it in accordance with this Privacy Policy.
Compliance with Law and Law Enforcement
We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to: (1) comply with a legal requirement or process, including, but not limited to, civil and criminal subpoenas, court orders or other compulsory disclosures; (2) enforce the Privacy Policy or the Terms of Service; (3) respond to claims of a violation of the rights of third parties; (4) respond to user comments or service inquiries; (5) protect the our rights, property, or safety and the rights, property and safety of the Services, our users or the public; or (6) prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable. However, Habla will endeavor only to disclose information requested via a valid legal process, and will endeavor to notify any user about whom we have disclosed information if possible.
Links to Other Websites
We may make content or services from other websites available to you from links located on the Site. We may present links in a format that enables us to keep track of whether these links have been followed. This Privacy Policy applies only to the Site and the Services. Your interactions with these third party services are governed by the privacy policy of the company providing it. These other sites and services may place their own cookies or other files on your computer’s browser, collect data or solicit personal information from you. Other websites and services follow different rules regarding the use or disclosure of the Personal Information that you submit, and the collection and use of such information and access of any third party websites are subject to such third party’s privacy policy. We encourage you to read the privacy policies and other terms of such third parties before using their services.
Choice/Opt-Out
You may opt-out of receiving communications from us and our partners, remove your information from our database, and choose to not receive future communications unrelated to the Services by contacting us at support+wulu@olark.com.
When you submit information on the Site, we will include you in marketing correspondence from Habla, which you can opt-out of at any time using the ‘unsubscribe’ option in the email. If you use the Services, we may occasionally contact you with information about special events, sales, activities, promotions, contests, submission opportunities and programs. You always have the option to ask Habla not to contact you with this information again. If you receive unsolicited email from an Habla domain after opting out, please contact us at support+wulu@olark.com. We use your Personally Identifiable Information to provide the Services and send you Services-related emails or other emails that we believe may interest you (e.g., account verification, purchase and billing confirmations and reminders, changes/updates to features of the Services, technical and security notices). You may not opt out of Services-related e-mails without terminating your Account and access to the Services.
Retention
To preserve the integrity of our Services, we may also retain information submitted by Users for an indefinite length of time, even after the termination of your account or your relationship with us as governed by the Terms of Service. We will not share Private Information in backups with third parties unless compelled to by law.
Security
We understand the importance of privacy and security to our users and have made them a priority. Habla uses a variety of industry-standard security technologies and procedures to help protect your personal data from unauthorized access, use, or disclosure and trains Habla employees on privacy and security issues. However, we cannot guarantee that unauthorized third parties will never be able to overcome those measures or use your Personal Information for improper purposes, and we do not promise that your Personal Information or private communications will be protected from unauthorized disclosure or use. Habla is not responsible for the actions of those who obtain your content in this manner. Habla cannot guarantee your safety and security and you should be aware that submitting any information and using the Services is done at your own risk. Please do not provide any privileged information on the Site or when using the Services.
Children’s Privacy and Note to Parents and Guardians
We do not knowingly collect personal information from children under 13 years of age. Our Services are not directed to children under the age of 13 and children under 13 are not permitted to use the Services. If we become aware that we have unknowingly collected personal information from a child under the age of 13, we will make commercially reasonable efforts to delete such information from our database. If you are a parent or guardian of a child under the age of 13, and you believe that your child has provided us with personal information, please contact us using the information in the “Contact Habla” section at the end of the Privacy Policy.
Managing Your Privacy
We keep your data on your behalf and for your benefit. You can correct or delete your account information by following the instructions on the Services or by e-mail at support+wulu@olark.com, which you may also access for further assistance and questions regarding the Privacy Policy or for a copy of your account data. If you cancel your account or request us to delete your information, Habla will limit its access to personally identifiable data to perform what is requested by you and will delete information accessible to Habla within seven (7) business days.
California Residents
California Civil Code Section 1798.83 requires certain businesses that share customer personal information with third parties for the third parties’ direct marketing purposes to respond to requests from California customers asking about the businesses’ practices related to such information-sharing. We currently do not share or disclose your Personal Information to third parties for the third parties’ direct marketing purposes. If we change our practices in the future, we will implement an opt-out policy as required under California laws.
Jurisdiction
All information passed through Habla is primarily handled in the United States but may from time to time be handled in any country in which Habla or its affiliate companies maintain facilities. By using the Services, you agree that the handling of your personal information and any communication through the Services will be governed by the laws of the United States and any applicable state laws.
Requests to Access, Edit, or Delete Information
You have a right to access your personal information. Please contact us at support+wulu@olark.com to find out how to access and change information you cannot access. Habla shall, upon request and promptly using commercially reasonable efforts, correct, delete, and/or block Personal Information from further processing and/or use except to the extent required by law. You can request deletion or correction of your Personal Information by contacting Habla at support+wulu@olark.com.
Notification of Changes
Habla’s security and Privacy Policy are periodically reviewed and enhanced as necessary. This policy might change as Habla updates and expands the Services. Habla will endeavor to notify you of these changes by email, but will not be liable for any failure to do so. Habla also encourages you to review this Privacy Policy periodically. If you do not understand any of the terms or conditions of any of Habla’s policies, you may inquire regarding the same via email at support+wulu@olark.com.
Contact Habla
If you have any questions about the Privacy Policy, please contact us at support+wulu@olark.com.