Privacy Policy

Welcome to Huntcode and our website at Huntcode (our “website”). At Huntcode, we are committed to protecting and respecting your privacy. This privacy policy sets out the basis on which we will process any Personal Data that we may collect about you as a visitor to our website. This policy further sets out how we protect your privacy and your rights in respect of our use of your Personal Data. 

What is personal data?

Personal Data is information that makes it possible to identify a natural person. This includes, in particular, your name, date of birth, address, telephone number, e-mail address, but also your IP address. Anonymous data exists if no personal reference to the user can be made.

What is processing?

“Processing” means and covers virtually any handling of data.

What law applies?

We will only use your Personal Data in accordance with the Tennessee Information Protection Act (“TIPA”) and the EU’s General Data Protection Regulation (“GDPR”), and of course only as described in this Privacy Policy.

Who is the data controller?

A “data controller” is a person or organization who alone or jointly determines the purposes for which, and the manner in which any personal data is, or is likely to be, processed. In this sense, Cam G Media LLC of 5801 Avalon Ct, Hermitage, TN 37076, USA (“Huntcode”, “we”, “us”, “our”) is the data controller. If you want to contact us or if you have any questions, you can contact us by email using camgmediallc@gmail.com with “Data Protection” in the subject line.

We have to have at least one of the following legal bases to process your Personal Data: a) you have given your consent; b) the data is necessary for the fulfillment of a contract/pre-contractual measures; c) the data is necessary for the fulfillment of a legal obligation; or d) the data is necessary to protect our legitimate interests, provided that your interests are not overridden.

What personal data do we collect from you?

We may collect and process the following Personal Data about you:

a) Personal Data that you give us:
This is information about you that you give to us by filling in forms on our website or correspond with us. It may include, for example, your name, address, email address, and telephone number. This data is collected and processed exclusively for the purpose of contacting you and processing your request and then deleted again, provided that there is no legal obligation to retain it. The legal basis for processing is our legitimate interest, the provision or initiation of a contract, and your consent.

b) Personal Data that our website and other systems collect about you:
If you visit our website, it will automatically collect some information about you and your visit, including the Internet protocol (IP) address used to connect your device to the Internet and some other information, such as the pages on our site that you visit. This is used to monitor the performance of the website and improve the experience of visitors to the website. 

We use the hosting services of Linode, for hosting and displaying our website. Linode does this on the basis of processing on our behalf, which also means that all data collected on our website is processed on Linode’s servers. The basis for processing is our legitimate interest and the initiation and/or fulfillment of a contract. 

We also use the open-source Content Management System (CMS) of WordPress.Org to publish and maintain the created and edited content and texts on our website. This means that all content and texts submitted to us are transferred to Linode and that your contact and contract data and your usage data are stored on Linode’s servers. The legal basis for this processing is our legitimate interest.

We use fonts from Font Awesome (Fonticons) on our website to display external fonts. To enable the display of certain fonts on our website, a connection to a Font Awesome server is established when our website is accessed. The connection to Font Awesome established when you call up our website enables Font Awesome to determine which website sent your request and to which IP address the display of the font is to be transmitted. This represents a legitimate interest.

We also use Google Tag Manager. Google Tag Manager is a solution enabling us to administer website tags via an interface. Google Tag Manager itself, which implements the tags, is a cookie-free domain and does not record any personal data. However, the tool triggers other tags that may record your Personal Data. Google Tag Manager itself does not access this data. If you refuse Analytical/Performance and/ or Marketing & Social Media Cookies, Google Tag Manager remains in place. The legal basis for the processing is our legitimate interest.

Lastly, and in terms of integrated videos, we use the services of YouTube (Google). The integration requires that YouTube can perceive the IP address of the user. This is a mere technical process and required to make the video available for viewing on your device. The legal basis for the data processing is our legitimate interest and your consent.

c) Cookies 
We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be small files or other types of information storage. As set out in the TIPA and the EU`s Privacy and Electronic Communications Directive (“PECD”), we need to obtain consent for the use of non-essential cookies. For further information on the cookies we use, please refer to our Cookie Policy.

d) Analytics
For business reasons, we analyze the data we have on web and server traffic patterns, website interactions, browsing behavior, etc. The analyses serve us alone and are not disclosed externally and processed using anonymous analyses with summarized and/or anonymised values (“Aggregated Data”). Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy. For this purpose we use Google Analytics from Google. The legal basis is our legitimate interest and your consent. For further information on our use of Google Analytics, please refer to our Cookie Policy.

Change of purpose

We will only use your Personal Data for the purposes for which we collected it as detailed above, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will notify you, and we will explain the legal basis which allows us to do so.

Data sharing

In certain cases, it is necessary to transmit the processed Personal Data in the course of data processing. In this respect, there are different recipient bodies and categories of recipients.

Internal
If necessary, we transfer your Personal Data within Huntcode. Access to your Personal Data is only granted to authorized employees who need access to the data due to their job, e.g., to provide our products or services or to contact you in case of queries. 

External bodies
Personal Data is transferred to our service providers in the following instances: 

  • in the context of fulfilling our contract with you,
  • to communicate with you,
  • to provide our website, and 
  • to state authorities and institutions as far as this is required or necessary.

International transfers 

We may transfer your Personal Data to other companies as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organizational measures to protect the Personal Data we transfer.

How long do we keep your personal data?

We will delete your Personal Data when we no longer need such Personal Data, for instance, where:

  • it is no longer necessary for us to retain your Personal Data to fulfill the purposes for which we had collected it; 
  • we believe that your Personal Data that we hold is inaccurate; or 
  • in certain cases where you have informed us that you no longer consent to our processing of your Personal Data.

Sometimes, however, there are legal or regulatory requirements which may require us to retain your Personal Data for a specified period, and in such cases we will retain your Personal Data for such specified period; and we may need to retain your Personal Data for certain longer periods in relation to legal disputes, and in such cases we will retain it for such longer periods to the extent required.

Data security

Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as donations, login data, or contact requests that you send to us. We have also implemented numerous security measures (“technical and organizational measures”), for example encryption or need-to-know access, to ensure the most complete protection of Personal Data processed through our website. 

Marketing

Insofar as you have given us your consent to process your Personal Data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to. Our Marketing generally takes the form of email but may also include other less traditional or emerging channels. These forms of contact will be managed by us, or by our contracted service providers. Every directly addressed marketing sent by us or on our behalf will include a means by which you may unsubscribe or opt out.

Linked sites

For your convenience, our website may contain hyperlinks to other websites. We are not responsible for the privacy practices of linked websites or companies that are not owned or controlled by us, and this Privacy Policy does not apply to them. The links on our website may collect additional information in addition to the information we collect.

We do not endorse any of these linked websites, their products, services, or any content on their websites. We encourage you to read the privacy policies of each linked website you visit to understand how the information collected about you is used and protected.

Social media

We are present on social media based on our legitimate interest. If you contact or connect with us via social media, we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint responsibility agreement. The Personal Data collected when you contact us is used to process your request, and the basis for this is both your consent and our legitimate interest.

Your rights and privileges

Privacy rights 

You can exercise the following rights:

  • The right to access;
  • The right to rectification;
  • The right to erasure;
  • The right to restrict processing;
  • The right to object to processing;
  • The right to data portability;

Update your information and withdraw your consent 

If you believe that the information we hold about you is inaccurate or request its rectification, deletion, or object to legitimate interest processing, please do so by contacting us.

Access Request 

In the event you want to make a Data Subject Access Request, please contact us. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.

What we do not do

  • We do not request Personal Data from minors and children;
  • We do not process special category data without obtaining prior specific consent;
  • We do not use automated decision-making, including profiling; and
  • We do not sell your Personal Data.

Who is the competent data protection authority?

The Office of the Attorney General. If you believe that the processing of your Personal Data is not lawful, you can lodge a complaint with the AG or your local data protection supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach the AG or any other supervisory authority.

Data Breaches and Notification

Databases or records containing Personal Data may be breached accidentally or through unlawful intrusion. As soon as we become aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised, and the notification will be accompanied by a description of the measures that will be taken to repair the damage caused by the data breach. Notifications will be sent as soon as possible after the violation is discovered.

USA specific provisions

The following applies to users located elsewhere in the United States. While we understand and appreciate that privacy and consumer data protection laws differ as they are subject to each state’s legislature and that no data protection framework similar to the EU’s GDPR exists on a federal level, we are committed to follow and apply the for your state relevant privacy rules and regulations. 

As of the day of drafting, the following states had enacted privacy and consumer data protection laws: California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Texas, Utah, and Virginia. Under consideration of the similarities of the above provisions, no conflict should arise pursuing a uniform approach in granting all users in the USA the same rights and privileges as set out above. However, should ambiguity occur the most stringent provision is chosen to ensure the most comprehensive approach when it comes to protecting your Personal Data.

Further, the following also apply

i) “Shine the Light”

“Shine the Light” law (Civil Code Section 1798.83) requires us to respond to requests from California asking about the business’s practices related to disclosing Personal Data to third parties for the third parties’ direct marketing purposes. You may make a request about our collection and disclosure of your Personal Data using the contact details provided.

ii) COPPA (Children Online Privacy Protection Act)

When it comes to the collection of Personal Data from children under the age of 13 years old, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States’ consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online. We do not specifically market to children under the age of 13 years old.

iii) CAN SPAM Act

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations. To be in accordance with CAN SPAM, we agree to the following: If at any time you would like to unsubscribe from receiving future emails, you can email us, and we will promptly remove you from ALL correspondence.

iv) Telephone Consumer Protection Act (TCPA)

If we process your Personal Data for the purpose of sending you SMS marketing communications, you may manage your receipt of marketing and non-transactional communications from us by replying or texting ‘STOP’ if you receive our SMS communications. In this respect, the data processing is carried out solely on the basis of our consent in personalized direct advertising per SMS.

v) Controls For Do-Not-Track Features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (‘DNT’) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, our website does not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this policy.

vi) Right to complain

Finally, and in regard to the right to complain to a supervisory authority. You have the right to lodge a complaint about our processing of Personal Data with a supervisory authority responsible for data protection. Users based in the above mentioned States may lodge a complaint with the relevant district attorney or attorney general office. However, we would appreciate the opportunity to address your concerns before you contact any supervisory authority.

Canada and mexico specific provisions

Both Canada and Mexico have introduced data protection laws that are similar to the GDPR, namely Federal Law for the Protection of Personal Data in the Possession of Private Parties (“LFPDPPP”) supplemented by the Rules of the Federal Law for the Protection of Personal Data in the Possession of Private Parties in Mexico and the Personal Information Protection and Electronic Documents Act (“PIPEDA”) in Canada. Under consideration that the GDPR has played a pivotal role, no conflict should arise pursuing a uniform approach in granting all users in Mexico or Canada the same rights and privileges as set out above. However, should ambiguity occur, the most stringent provision is chosen to ensure the most comprehensive approach when it comes to protecting your personal data.

In terms of your right to complain, Canada’s national supervisory authority is the Office of the Privacy Commissioner (www.priv.gc.ca) and the National Institute of Transparency, Access to Information and Personal Data Protection (Instituto Nacional de Transparencia, Acceso a la Información y Protección de Datos Personales) (“INAI”) is the national supervisory authority in Mexico (www.ifai.org.mx). 

Help and complaints

If you have any questions about cookies or about data protection at Huntcode, you can contact us by email using camgmediallc@gmail.com with “Data Protection” in the subject line.

Changes

The first version of this policy was issued on Sunday, November 3rd, 2024, and is the current version. Any prior versions are invalid, and if we make changes to this policy, we will revise the effective date.