At Hoihc, we strive to honor the privacy and security of our users, customers and suppliers, as well as their representatives, in relation to all products, services, applications and websites provided by Hoihc or any of its affiliates (“Hoihc”), when acting as a Data Controller under relevant data protection rules and regulations.

This Privacy Statement describes our privacy practices as required by the EU General Data Protection Regulation (“GDPR”), UK General Data Protection Regulation (“UK GDPR”), California Consumer Privacy Act (“CCPA”) and other applicable data protection laws (collectively “Privacy Laws”). This Privacy Statement applies where Hoihc is acting as a Data Controller with respect to the Personal Information (which includes “Personal Data” as defined under relevant Privacy Laws) of our customers, employees, website users, partners and service providers. In other words, this Privacy Statement applies where we determine the purposes and means of the processing of Personal Information.

This Privacy Statement provides information regarding how we, when acting as a Data Controller, collect, process, share, transfer, retain and protect Personal Information, and the rights you may exercise, where applicable, regarding your Personal Information.

This Privacy Statement applies to Hoihc’s websites, including, but not limited to hoihc.com, Hoihc mobile apps, Hoihc dedicated social media accounts, etc. (“Sites”). This Privacy Statement does not apply to third-party applications, products, services, websites, or social media features that may be accessed through links on our Sites that have their own privacy policies. Accessing those links will cause you to leave our Sites and may result in the collection and/or sharing your Personal Information by a third party. We do not control, endorse, or make any representations about third-party websites or their privacy practices, which may differ from ours. We encourage you to review the privacy practices of any site you interact with before allowing the collection and use of your Personal Information.

2. PERSONAL INFORMATION WE COLLECT ABOUT YOU

When you complete a transaction, submit a request, set up an account, apply for a position (Privacy Statement for Job Applicants) , visit our Sites, etc., or interact with any Hoihc entity, you may be asked to provide certain information, including, but not limited to, your name, title, company, address, phone number, e-mail address, credit card information, and line of business. You may also provide us with data regarding your devices, such as your IP address, your geolocation, your data usage, your client or supplier account, etc. In limited circumstances, we may collect information related to you, and your family members, such as age, gender and civil status. This information and data may be considered Personal Information under applicable Privacy Laws.

We may also collect your information from third-party sites, including when you log in through a third-party site such as Facebook, Snapchat, Instagram, Amazon, LinkedIn, Twitter, etc. We may also disclose information collected from third parties to customize ads and to manage and facilitate messaging on third party sites.

3. HOW WE DISCLOSE YOUR PERSONAL INFORMATION

We may disclose your Personal Information to any member of our group of companies, affiliates, as reasonably necessary for the purposes, and on the legal bases, set out in this Privacy Statement.

Advertising Networks/Partners – We may disclose electronic identification data and personal characteristics including product related video viewing history to support our marketing efforts.

Insurers and Professional Advisors - We may disclose personal information for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise, or defense of legal claims, whether in court proceedings or other legal proceedings.

Payment Service Providers - We may disclose your Personal Information to complete financial transactions. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.

We may disclose your Personal Information within Hoihc to: (a) complete and send purchases/orders, (b) facilitate payments, (c) manage you interaction with our organization and affiliates, (d) respond to consumer inquiries, (e) address legal or regulatory claims, (f) facilitate marketing, product, service information (g) manage product recalls, (h) train our employees and contractors; or (i) train artificial intelligence or machine learning systems, models, and applications for internal research purposes to improve our products, services or technology.

In addition to the specific disclosures of Personal Information set out in this section, we may disclose your Personal Information: (a) where such disclosure is necessary for compliance with a legal obligation to which we are subject, including a subpoena, court order or search warrant; (b) enforce our Terms of Service, this Privacy Statement, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims regarding violations of third party rights; (d) respond to your requests for customer service; (e) protect the rights, property or personal safety of Hoihc and its employees, its agents and affiliates, its users and/or the public; and/or (f) with other companies and organizations for fraud protection, spam/malware prevention, or to protect your vital interests or the vital interests of another natural person.

We reserve the right to transfer your Personal Information in the event of bankruptcy or a sale or transfer of all or a portion of our business or assets, an acquisition, merger or divestiture and all due diligence efforts for these items.

4. INTERNATIONAL DATA TRANSFERS

Hoihc is a global business based in HongKong. Hoihc, and our affiliated companies, have offices and facilities in worldwide locations including the European Union/EEA, UK, Latin America, Asia and Africa. Your Personal Information may be transferred to other jurisdictions.

Our customers and the users of our Sites may be located anywhere in the world. The Privacy Laws in some countries may not provide protections equivalent to those in your country of residence, and your government may or may not deem such privacy protections adequate. We may process your information in, or transfer your information to, the HK or other countries.

In the event of transfer of Personal Information subject to the GDPR or UK GDPR to a country which has not been deemed to ensure an adequate level of protection for such Personal Information, we will implement appropriate safeguards, which may include further assessments and additional safeguards, in accordance with relevant legal requirements.

5. YOUR RIGHTS REGARDING ACCESS TO AND CONTROL OVER PERSONAL INFORMATION

Depending on the jurisdiction in which you reside and the Privacy Laws applicable to your Personal Information, you may have the following rights, which may require a verified request to exercise:

Information and Access - You may request to access your Personal Information, receive supplemental information about your Personal Information, receive information on the public and private entities to whom your Personal Information has been provided, and/or be provided with a copy of your Personal Information.

Data Portability - You may have the right to request a portable copy of your Personal Information. Data Portability does not apply to paper records, and must not prejudice the rights of others, or involve sensitive company information.

Right not to be subject to decisions based solely Automated Decision Making- You may have the right not to be subject to decisions based solely on automated processing (i.e., without human intervention).

Right to lodge a complaint- You may have the right to lodge a complaint with a supervisory authority in the country where you reside, where you work, or where the potential infringement took place. For additional information on relevant supervisory authorities.

Hoihc may charge a reasonable fee or reject your request if your request is not valid under applicable law, repetitive or excessive. We may also request information from you to verify your identify before you receive a response. Hoihc may reject your request if your identity cannot be validated.

This Privacy Statement does not create, extend or modify any EU Data Subject rights, UK Data Subject rights, consumer rights under any US State or Hoihc obligations, except as provided by the GDPR, UK GDPR, CCPA or other applicable Privacy Law.

6. SENSITIVE PERSONAL INFORMATION

Unless specifically requested by us or required by law, we ask that you not send us, and you not disclose, on or through the Sites or otherwise to us, Sensitive Personal Information, which may include, depending on the jurisdiction and without limitation, your religion, ethnicity, political opinions, ideological or other beliefs, health, biometrics or genetic characteristics, criminal background, trade union membership, or administrative or criminal proceedings and sanctions. The requirements for collecting and processing Sensitive Personal Information vary by jurisdiction, but in the event, we collect or process Sensitive Personal Information, we will abide by all applicable Privacy Laws.

7. PERSONAL INFORMATION SUBMITTED BY CHILDREN

Some of the content on our Sites may be directed toward children under age 13. However, we do not knowingly collect or solicit personal information from children under age 13 without parental consent, unless permitted by law. If we become aware that we have collected personal information from a child under age 13 without parental consent or unless otherwise permitted by law, we will delete it in accordance with applicable law. If you believe that a child may have provided us with Personal Information without parental consent or as otherwise not permitted by law, please contact us as detailed below in the “Contact Us” section.

8. COOKIES, WEB BEACONS AND OTHER TRACKING TECHNOLOGIES

Our Sites use Cookies and other similar technologies in accordance with applicable Privacy Laws. Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies help with a variety of website functions including allowing users to “log in” to websites (making your navigation of websites more efficient), remembering your preferences (such as language), and generally improving your experience on our Sites. Cookies can also help ensure that the advertisements and content you see online are more relevant to you and your interests. We may also include web beacons in marketing e-mail messages or our newsletters to determine whether messages have been opened and links contained within clicked on. Similar technologies to accomplish similar goals may include, pixels, web beacons, JavaScript and any other means of storing or accessing information on the device.

Additionally, our Sites may be configured to recognize general global privacy control (“GPC”) or Do Not Track (“DNT”) signals from most browsers’ settings. As not all browsers and extensions have a standard signal it may be possible that your specific GPC or DNT signal is not technically recognized by our Sites.

9. SECURITY

There is no perfect security. We have implemented appropriate and commercially reasonable organizational, technical, and administrative safeguards to protect Personal Information. You are responsible for maintaining the secrecy of any credentials that can be used to access any account or service with Hoihc. If you should suspect any unauthorized activity, please report this to us immediately.

10. LINKS TO THIRD-PARTY SITES

We are not responsible for the practices employed by any websites or services linked to or from the Sites, including the information or content contained within them. We encourage you to investigate and ask questions before disclosing Personal Information to third parties, since any Personal Information disclosed will be subject to the applicable third party’s privacy policy.

11. EMAIL MARKETING COMMUNICATIONS

If, where required by applicable law, you have provided consent, or otherwise if you have not directed us not to send you marketing messages, we may send you marketing messages via email and/or mail to keep you updated on our products and services.

We will process opt-out/unsubscribe requests as quickly as possible in accordance with applicable Privacy Laws, and in most cases, within 10 days. However, Hoihc consists of many entities and associated service providers so it may take time for all our systems to reflect these updates. We ask for your understanding that during this period you may still get messages from us while your request is being processed. Please note that when you unsubscribe from our marketing email there may be a delay in the discontinuation of our ads directed to you on third party sites.

12. EMAIL MARKETING COMMUNICATIONS

13. CHANGES TO OUR PRIVACY STATEMENT

We reserve the right, at our sole discretion, to change, modify, add, or remove portions from this Privacy Statement at any time. We shall notify any such changes in accordance with applicable Privacy Laws.

Any material changes to this Privacy Statement will be posted on this webpage. Unless otherwise indicated, any changes to this Privacy Statement will apply immediately upon posting to the Sites. It is your responsibility to review our Privacy Statement each time you provide Personal Information to us as the Privacy Statement may have changed since the last time you used our Sites or services.

1. YOUR PRIVACY IS IMPORTANT TO US