Privacy Policy

Your privacy is important to us. To better protect your privacy we provide this notice explaining our online information practices and the choices you can make about the way your information is collected and used. To make this notice easy to find, we make it available on our homepage and many pages of our websites.

The Data We Collect
In order to provide services to you, we may collect the following types of information: Information you provide - For example, when you sign-up for an account, write reviews, contact us, or use other services on the website that requires input, we will store and save the information you provide. This information may include personally identifiable information such as your name, postal address, email address, etc. (“ Personal Data”).

Cookies - When you use access files on the website, one or more cookies will be sent and stored on your computer. These cookies are used to save certain preferences on the website and identify you on future visits. You can choose to limit the storage of cookies on your computer when accessing the website. Limiting or prohibiting cookies from being stored on your computer may however affect the usability of the website services.

Log information - All information sent by your web browser and computer when you visit the website may be stored by our servers. This information may include your IP address, browser type, URL accessed, cookie information, the date and time of your request, and other information that may uniquely identify you and may also be considered as part of your Personal Data.

You are responsible for ensuring the accuracy of your Personal Data you submit to us. Inaccurate information will affect the information you receive when we provide you services and our ability to contact you as contemplated in this Privacy Policy as well as to provide you the services at the best manner possible.

In addition, please note that this Privacy Policy does not cover the following information as it cannot be considered as Personal Data:

• Information relating to a legal entity (e.g. corporate information, contact details, accounting information, etc.);
• Anonymized data, namely information which does not relate to an identified or identifiable natural person or to Personal Data rendered anonymous in such a manner that the data subject is not or no longer identifiable.

Use of Personal Data
We use the Personal Data we collect from or about you to make the services available to you, to conduct statistical analysis, provide customer support, to undertake necessary security and identify verification checks, to meet certain business requirements and for any other purpose related to the operation of the services we provide you. Your Personal Data may also be used by us to provide you with promotional offers and information regarding products and services from third parties, and in order for us to improve the services and/or customer service. We may also use the Information to track your use of the services and/or for other internal purposes, such as evaluating, providing, and improving the services. We collects the Personal Data, solely for the use of our clients and the administration of the websites and Facebook enabled apps. We limits access to all Personal Data gathered within our organization and Personal Data is never shared outside of Habílitas, only in accordance to this Privacy Policy as further specified below. We may contact you in connection with the websites and Facebook apps you engaged with and use your Personal Data collected from past engagements when you access or utilize Habílitas applications in the future. You may also grant Habílitas permissions within Facebook applications that allow Facebook to share your activity within Facebook applications on the Facebook platform and post on your behalf. You may request that your Personal Data be deleted from Habílitas systems at any time by sending your request to Habílitas will process Personal Data as above-mentioned and only in accordance to the provisions of this Privacy Policy. Habílitas personnel are obligated to maintain the security, and secrecy of any Personal Data as provided in this Privacy Policy and this obligation continues even after their engagements end.

Personal Data Sharing and Transferring
We do not give, sell, transfer or otherwise share any Personal Data to, or with, any third party without first advising our affected customers of this activity, except for the cases listed in this Privacy Policy. Sharing of Personal Data may occur (i) if you have requested and/or agreed that the Personal Data will be provided to third parties; or (ii) if the disclosure is required by law; or (iii) if it is transferred for the performance of a contract between you and Habílitas; or (iv) the transfer is necessary in order to protect the vital interests of the data subject; or (v) the transfer is necessary or legally required on important public interest grounds, or for the establishment, exercise, or defense of legal claims; or(vi) if the transfer is for the purposes of the legitimate interests pursued by Habílitas or by the relevant third party. The information collected about you may be shared with third parties to facilitate the serving of advertising on the website and to improve our service as part of compliance with contractual duties between us. Some of these advertisers (such as Google through the Google AdSense program) may use technology such as cookies and web beacons and may collect additional information about you. Habílitas provides applications that contain entry forms that collect information about you on behalf of other third-parties. Habílitas makes this information available to the third-parties that have created the campaign running on Habilitas's servers. This information can include any information you provide along with other Personal Data that we collect and that is accessible through permissions you grant to our applications on the Facebook, Twitter, and other platforms. In addition, we may disclose your Information if we believe in good faith that such action is necessary to comply with applicable legislation, a current judicial proceeding, a court order or legal process, or to protect and defend Habilitas's rights or property, the personal safety of other users of the website or the public at large. We reserves the right to share the Personal Data with appropriate authorities and financial institutions, if we determines in our sole discretion that you attempted to defraud Habílitas, or if we suspects you are committing any fraudulent activity, or any other prohibited transaction, or if you breach the Terms of Use. In the event that Habílitas sells, assigns or transfers some or all of its business or assets to a successor or acquirer, or if Habílitas is acquired by or merges with a third party, or if Habílitas files for bankruptcy or becomes insolvent, Habílitas may disclose, sell, assign or transfer all of your Personal Data as part of the transaction.

Our Commitment to Data Security
To prevent unauthorized access, maintain data accuracy, and ensure the correct use of Personal Data, we have put in place physical, electronic, and managerial procedures to safeguard and secure the information we collect online. However, we cannot guarantee the security of your data, which may be compromised by unauthorized entry or use of the Website. We implemented and will maintain and follow appropriate technical and organizational measures intended to protect information that we collect against accidental, unauthorized or unlawful access, disclosure, alteration, loss, or destruction.

Security Incident Notification
If we become aware of any unlawful access to any information we stored, or unauthorized access to it, resulting in loss, disclosure, or alteration of the information, we will promptly (1) notify you of this security incident; (2) investigate this security incident and provide you with detailed information about the security incident; and (3) take reasonable steps to mitigate the effects and to minimize any damage resulting from the security incident. Notification(s) of those security incidents will be delivered to one or more of your administrators by any means we selects, including via email. It is your sole responsibility to ensure your administrators maintain accurate contact information on the services portal. Our obligation to report or respond to such security incident is not an acknowledgement by us of any fault or liability with respect to a security incident. You must notify us promptly about any possible misuse of your accounts or authentication credentials or any security incident related to the services that we providing to you.

Our Commitment to Children's Privacy
Protecting the privacy of the very young is especially important. For that reason, our services are not directed towards and may not be used by persons under 16, and no part of our website is structured to attract anyone under 16.

This site uses Google Analytics for Display Advertising. We use Remarketing with Google Analytics to advertise online. Third-party vendors, including Google, show our ads on sites across the Internet. This site and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on someone's past visits to this website. Visitors can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads using the Google Ads Preferences Manager.

Links to Other Sites
Our website may contain links to other sites. Other sites may also reference or link to our website. We are not responsible for the privacy practices or the content of such other online sites, and any information collected by these third party online sites is not governed by this Privacy Policy, and we assume no responsibility or liability whatsoever for the policies (including privacy policies), practices, actions or omissions of such third parties.

Retention and Deletion of Your Information
We may retain your information for as long as needed to provide you with the services and the uses described in this Privacy Policy. This often means that we will keep information for the duration of your account. Please note, however, that where applicable legislation requires us to do so, it may be required to keep records of your Information even after such termination.

How You Can Access or Correct Your Information
Registered users can access and maintain much of their personally identifiable information that we collect online using the account management section of the website. Information that is not accessible online can be modified or deleted by sending us a request using the contact procedure in this policy. To protect your privacy and security, we will also take reasonable steps to verify your identity before granting access or making corrections. We provide registered users with the ability to correct, delete, or block their data, or make such corrections, deletions, or blockages on their behalf.

Additional European Terms
These Additional European Terms apply only if you resides in the European Union (“ EU”).
The provisions of this Additional European Terms section of the Privacy Policy are in addition to all other provisions in this Privacy Policy in which Habílitas is bound.
For this section, below are important definitions:

• " GDPR" means the European Union General Data Protection Regulation.
• “ Personal Data” means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
For the services provided by Habílitas, Habílitas is a data processor acting on your behalf. As data processor, Habílitas will only act upon your instructions.
The duration of data processing shall be for the term designated under an agreement (which refers to this Privacy Policy) between you and Habílitas. The objective of the data processing is the performance of the services and as specified above in the “Use of Information” section above.
The scope and purpose of processing your data, including any Personal Data is described in this Privacy Policy.
This section do not limit or reduce any data protection commitments Habílitas makes to you in a services agreement between you and Habílitas and in this Privacy Policy.
Habílitas shall not engage another processor without your prior specific or general written authorization. In the case of general written authorization, Habílitas shall inform you of any intended changes concerning the addition or replacement of other processors, thereby giving Customer the opportunity to object to such changes.
Processing by Habílitas shall be governed by the GDPR terms under the EU and are binding on Habílitas with regard to you. The subject matter and duration of the processing, the nature and purpose of the processing, the type of Personal Data, the categories of data subjects and your rights are set forth in your agreement, including these GDPR terms. In particular, Habílitas shall:
(a) process the Personal Data only on documented instructions from you (if you are “Controller” according to the GDPR), including with regard to transfers of Personal Data to a third country or an international organization, unless required to do so by Union law to which Habílitas is subject; in such a case, Habílitas shall inform you of that legal requirement before processing, unless that law prohibits such information on important grounds of public interest;
(b) ensure that persons authorized to process the Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality;
(c) take all measures required pursuant to Article 32 of the GDPR;
(d) ensure compliance with the obligations pursuant to Articles 32 to 36 of the GDPR, taking into account the nature of processing and the information available to Habílitas;
(g) at your choice, delete or return all the Personal Data to you after the end of the provision of services relating to processing, and delete existing copies unless Union law requires storage of the Personal Data;
(h) make available to you all information necessary to demonstrate compliance with the obligations laid down in Article 28 of the GDPR.
Habílitas shall immediately inform you if, in its opinion, an instruction infringes the GDPR or other Union or Member State data protection provisions.
Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, Habílitas shall implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including inter alia as appropriate:
(a) the pseudonymisation and encryption of Personal Data;
(b) the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
(c) the ability to restore the availability and access to Personal Data in a timely manner in the event of a physical or technical incident; and
(d) a process for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing.
In assessing the appropriate level of security, account shall be taken of the risks that are presented by processing, in particular from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data transmitted, stored or otherwise processed. Habílitas shall take steps to ensure that any natural person acting under the authority of Habílitas who has access to Personal Data does not process them except on instructions from Habílitas, unless he or she is required to do so by Union law.
Habílitas shall notify you without undue delay after becoming aware of a personal data breach.

Lawful Bases for Processing
We will only collect and process Personal Data about you where we have one of the following 6 lawful bases:
Consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g. to deliver the services you have requested), legal obligation (to comply with a common law or statutory obligation), vital interest (to protect someone’s life), public task (to perform a specific task in the public interest that is set out in law) and for legitimate interests. Where we rely on your consent to process Personal Data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object. If you have any questions about the lawful bases upon which we collect and use your Personal Data, please contact us (contact information provided below).

Transfer of Personal Data to Third Countries
We may transfer your Personal Data to third parties located at destinations outside the European Economic Area. The data protection and privacy laws of the jurisdictions to which the Personal Data will be transferred may not be as comprehensive as those in the European Union (if applicable to you); in which case New Stream will take measures to ensure a similar level of protection is provided to your Personal Data according to one of the following safeguards:

(a) Personal Data is transferred to countries that the European Commission has identified as the countries ensuring an adequate level of protection of Personal Data;
(b) In the case of recipients based in the United States of America, we may transfer Personal Data if recipients participate in the Privacy Shield programme, which aims at ensuring the same level of protection of Personal Data as that applicable in Europe;
(c) We apply relevant standard contractual clauses approved by the European Commission or we rely on binding corporate rules which guarantee the security of your data.

Your Rights
In certain circumstances, you have rights in relation to the Personal Data we process about you. The table below sets out an outline of those rights and how to exercise them:
Please note that Habílitas will require you to verify your identity before responding to any requests to exercise your rights. To exercise any of your rights, please email Please note that for each of the rights below, Habílitas may have valid legal reasons to refuse your request, in such instances we will let you know if that is the case.