Global Privacy Policy

1. Scope and Application

This Global Privacy Policy applies to all personal data processed by HATTEN Development LLC ("HATTEN") worldwide, including through our websites, applications, products, and services (collectively, "Services"). We adhere to the highest international standards including the EU General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), and other applicable global privacy laws.

2. International Data Controller

Global Controller: HATTEN Development LLC
Headquarters: 420 Southwest 7th Street, Suite 1014, Miami, FL 33130, USA
Data Protection Officer: [email protected]
For EU/UK Representatives: [email protected]

3. Data Collection

We collect information that identifies, relates to, describes, or could reasonably be linked with a particular individual ("Personal Data"), including:

• Identifiers: Name, email, phone, IP address, online identifiers
• Commercial Information: Services purchased, obtained, or considered
• Professional Information: Company, job title, business contact details
• Usage Data: Browsing activity, interactions with our Services
• Geolocation Data: Country-level location information

4. Global Processing Purposes

We process Personal Data to:

• Provide and maintain our Services globally
• Develop new products and features
• Prevent fraud and ensure security
• Comply with legal obligations worldwide
• Personalize user experience across regions
• Communicate about services (where permitted)

5. Legal Bases for Processing (GDPR)

For individuals in the European Economic Area and UK, processing is based on:

• Consent: Where we've obtained your clear consent
• Contract: To fulfill our contractual obligations
• Legal Obligation: To comply with EU/US/international laws
• Legitimate Interests: For our business needs when balanced with your rights

6. International Data Transfers

As a global company, we transfer Personal Data internationally using approved mechanisms:

• EU-US Data Privacy Framework
• Standard Contractual Clauses
• Binding Corporate Rules where applicable

We implement supplementary measures including encryption and strict access controls for all transfers.

7. Data Retention

We retain Personal Data only as long as necessary for the purposes collected, including to:

• Meet legal requirements in multiple jurisdictions
• Resolve disputes
• Enforce agreements
• Maintain business records

8. Global Data Rights

Depending on your jurisdiction, you may have rights including:

• Access/Portability: Request copies or transfer of your data
• Correction: Update inaccurate information
• Erasure: Request deletion under certain conditions
• Restriction: Limit processing of your data
• Objection: Object to certain processing
• Non-Discrimination: (CCPA) Equal service if you exercise rights

To exercise rights, contact: [email protected]

9. Security Measures

We implement enterprise-grade security appropriate for global operations:

• Encryption of data in transit and at rest
• Regular security audits and penetration testing
• Access controls and authentication protocols
• Incident response plans meeting global standards

10. Third Parties and Subprocessors

We carefully vet all third parties that handle Personal Data and require contractual commitments to:

• GDPR/CCPA/global compliance
• Security standards matching ours
• Immediate breach notification

11. Policy Updates

We may update this policy to reflect:

• Changes in our Services
• New legal requirements globally
• Feedback from regulators or users

We will notify you of material changes through our website or direct communication when required by law.