Incident #C701EE · 19 MAR 2026notable
Hily's EU privacy policy names a new US data controller and adds processors
The data controller changes from LATHINOL LIMITED (Cyprus) to Hily Corp. (Las Vegas, US). The processor list adds Calendly (user research interviews) and a TikTok SDK (ads, using phone number and email), and Preluder takes the place of Ding SAS for SMS. The Virginia/Texas section now covers more US states. Payment and banking details are no longer listed in some data-purpose tables, and phone number is added to marketing contact data.
Taken from you
- Data controller is now a US company (Hily Corp., Nevada) instead of a Cyprus/EU entity
- TikTok SDK added: phone number, email and user IDs shared for ad targeting
- Calendly added as processor, handling meeting recordings and contact details for user research
- Phone number now used for direct marketing contact
- Gender now taken from Facebook sign-up
- Section 8.3 now says rights requests are answered within the timeframe required under applicable privacy law, instead of one month at the longest. The separate 30-day EU timeframe in section 11.2 is unchanged.
- Agents acting for you must now provide proof of authority rather than only possibly being asked
Won back
- Rights section rewritten to be clearer, with rights available to residents of more US states
- Payment card and banking details no longer listed as collected for paid features and remuneration
- Appeal rights extended to more US states, with 45 days for New Jersey users
- Added explicit statement that behavioral advertising lets third parties collect app-use information
Evidence · 4 of 4 quotes matched in source
(a) in this current case, your data controller is Hily Corp., a company with its registered address at 3172 North Rainbow Boulevard #1132, Las Vegas, NV 89108, United States of America; email: legal@hily.com;+ inserted · ✓ matched in source
| TikTok SDk | TikTok Information Technologies UK Limited | https://www.tiktok.com/legal/page/row/privacy-policy/en | Phone number, email, Username from the advertiser, Unique user ID from the advertiser, installation events, registration events | We use it to show you more relevant ads that will not annoy you. |+ inserted · ✓ matched in source
Archived version ↗ · 5,331 words changed