HOOKII Privacy Policy

Each of the Controller entities listed in end (“HOOKII”, “we”, “us” or “our”), adopts to following Privacy Policy. This privacy policy is addressed to individuals outside our organization with whom we interact, including customers, visitors to our Sites, or recipients of any of our other products, services, personnel of corporate customers and vendors, and visitors to our premises (“you”). We respect your privacy and treat your information with the utmost care.

Please read this carefully -  It is very important for you to understand the following privacy policy.

This Privacy Policy explains how we collect, use, and disclose your information through our websites, mobile applications, products, customer support, and other services (collectively referred to as Product, Products, or Services), as well as any other third party services or products that link to this Privacy Policy.

Intended Audience: Our Sites, products, or services are not directed to children under the age of 18. As a result, our Sites, products, or services do not request or knowingly collect personal information from individuals under the age of 18. If you are not 18 or older, you should not visit or use our Sites, products, or services.

By agreeing to this Privacy Policy in your account setup or by using our Products, or any other third party services or products that link to this Privacy Policy, you consent to the processing of your information as set forth in this Privacy Policy.

COLLECTION 

We collect or obtain personal information about you that we need when :

• You register an account with us,
• You contact us via email or telephone, or by any other means.
• You provide us with your business card.
• You place an order or contact us for purchasing and we provide a Product or Service to you.
• You manifestly choose to make Personal information public via social media (e.g., we may collect information from your social media profile(s), if you make a public post about us).
• You visit any of our Sites or use any features or resources available on or through a Site.
• You use or register to use, any of our Sites, products, or services.
• You use Facebook, Google, Wechat, and other accounts to log in to the Services (“Third-Party Accounts”).

Additionally, when you interact with any third-party content or advertising on our Site (including third-party plugins and cookies), we receive personal information from the relevant third-party provider of that content or advertising.

Additionally, we collect or obtain personal information from third parties who provide it to us (e.g., credit reference agencies; law enforcement authorities; etc.).

We may collect the following personal information with your consent:

• Personal Information. your name, gender, date of birth/age, nationality/district, address, telephone number, and email address.
• Account Information. your related account details, including your user name, contact phone number, email address, passwords, social media account, and third-party avatar.
• Device Information. location information of the device, Wi-Fi List Information, Mac address, Internet Protocol (IP) address, CPU information, memory information, internet service provider, referring/exit pages, language settings, dates and times of connecting to a Site, SD card information, and operating system version.
• Purchase Information. records of purchases and prices, consignee name, shipping address, contact telephone number, email address, details of returns, and warranty details.
• Payment Information. invoice records, payment records, billing address, payment method, last four digits of bank account number or credit card number, cardholder or accountholder name, card or account security details, card ’valid from’ date, card expiry date.
• Views and opinions. any comments, views, and opinions that you choose to send to us, or publicly post about us on social media platforms.
• Other Information that you provide to us directly or we may collect automatically within the necessary scope.

You can also choose to change the scope of consent or withdraw your authorization at any time. After the authorization is withdrawn, we will no longer collect personal information related to these permissions, and we will not be able to continue to provide you with corresponding Services.

However, your decision to withdraw consent or authorization will not affect our previous collection and use of personal information based on your authorization. When we want to use the information for other purposes not specified in this Policy, we will ask for your prior consent.

The purposes for which we use personal information, subject to applicable law, are as follows:

(a)We use your information to fulfill our agreements with you and provide you with our Products or Services, we process your personal information as necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract, including but not limited to:

• Managing your information and accounts, including registration;
• Providing the Products or Services to you, including providing access to certain areas, functionalities, and features of our Products or Services;
• Answering requests for customer or technical support;
• Communicating with you about your account, activities on our Services, and policy changes;

(b) We use your information for various administrative purposes, including but not limited to:

• Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
• Measuring interest and engagement in our Services;
• Improving, upgrading, or enhancing our Services;
• Developing new products and Services; Ensuring internal quality control and safety;
• Authenticating and verifying individual identities, including requests to exercise your rights under this policy;
• Debugging to identify and repair errors with our Products or Services;
• Auditing relating to interactions, transactions, and other compliance activities;
• Sharing information with third parties as needed to provide the Products Services;
• Enforcing our agreements and policies;
• Complying with our legal obligations.

(c)Other purposes as requested by you or as permitted by applicable law.

Automated Decision Making: We may engage in automated decision making including profiling. HOOKII’s processing of your personal information will not result in a decision based solely on automated processing that significantly affects you unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law to engage in such automated decision making. If you have questions about our automated decision making you may contact us as set forth in Contact Us below.

De-identified and Aggregated Information: We may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, and information about the device from which you access our Services or other analyses we create.

Only when we have a valid legal basis , We uses your personal information to:

• Honor our contractual commitments to you (including handling personal data on this basis to allow you to sign up for our services, processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations and so on);
• Communicate with you;
• Screen our orders for potential risk or fraud;
• Provide you with information or advertising relating to our products or services, When in line with the preferences you have shared with us;
• Operate our business and services;
• Provide security for our websites, products, software, or applications;
• Market;
• Preventing fraud;
• Know the customer to whom we are providing services; 
• Comply with our legal obligations (such as our obligation to share data with tax authorities).

comply with our legal obligations

You can opt out of having your information being used by HOOKII for performance-based advertising by accessing your mobile device settings and following the most recent published instructions. If you limit ad tracking, you will still see advertisements (even ones sourced from HOOKII's network), but we will no longer be able to use the personal information described above to serve you with more relevant ads.

In addition, the advertising identifier (along with any information collected about that identifier) that was previously assigned to you will also be disassociated. This means that if at a later stage, you decide to opt back in, we will not be able to use any of your past information for advertising purposes, and you will (for all practical purposes) be a new user of our system.

The information that we collect from you will be processed primarily in the EU and the United States but may be transferred to and stored at/processed in other countries.

We retain personal information only for so long as necessary to fulfill the purposes for which it was collected, including as described in this Privacy Policy or in our service-specific privacy notices, or as required by law.

We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy and our service-specific privacy summaries. When assessing retention periods, we first carefully examine whether it is necessary to retain the personal data collected and, if retention is required, work to retain the personal information for the shortest possible period permissible under law.

We disclose personal information to other entities within the HOOKII group, for legitimate business purposes and the operation of our Sites to you, in accordance with applicable law. In addition, we disclose personal information to:

• you and, where appropriate, your appointed representatives;
• legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;
• accountants, auditors, consultants, lawyers, and other outside professional advisors to HOOKII, subject to binding contractual obligations of confidentiality;
• third party Processors (such as email service providers; marketing/advertising service providers; venue operators; payment services providers; shipping companies; postal carriers; etc.), located anywhere in the world, subject to the requirements noted below:
• any relevant party, regulatory body, governmental authority, law enforcement agency, or court, to the extent necessary for the establishment, exercise, or defence of legal claims;
• any relevant party, regulatory body, governmental authority, law enforcement agency, or court, for the purposes of prevention, investigation, detection, or prosecution of criminal offenses or the execution of criminal penalties;
• any relevant third-party acquirer(s) or successor(s) in the title, in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation);
• any relevant third-party provider, where our Sites and our Apps use third-party advertising, plugins, or content. If you choose to interact with any such advertising, plugins, or content, your personal information may be shared with the relevant third-party provider. We recommend that you review that third party’s privacy policy before interacting with its advertising, plugins, or content.
• If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to:
• (i) only Process the personal information in accordance with our prior written instructions;
• (ii) use measures to protect the confidentiality and security of the personal information; together with any additional requirements under applicable law.

Because of the international nature of our business, we transfer personal information within the HOOKII group, and to third parties, as noted above, in connection with the purposes set out in this Policy. For this reason, we transfer personal information to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located, including China, the EU, the UK, and the US.

If an exemption or derogation applies (e.g., where a transfer is necessary to establish, exercise or defend a legal claim) we may rely on that exemption or derogation, as appropriate. Where no exemption or derogation applies, and we transfer your personal information from the UK or the EEA to recipients located outside the UK or the EEA (as applicable) who are not in Adequate Jurisdictions, we do so on the basis of [Standard Contractual Clauses]. You are entitled to request a copy of our [Standard Contractual Clauses]using the contact details provided below.

Please note that when you transfer any personal information directly to any HOOKII entity established outside the UK or the EEA (as applicable), we are not responsible for that transfer of your personal information. We will nevertheless Process your Personal Data, from the point at which we receive those data, in accordance with the provisions of this Policy.

You have the right to access the Personal Data we hold about you and to ask that your personal information is corrected, updated, or deleted at any time by logging into your account and exercising these rights directly, or by contacting us through the contact information below.Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

You have the right to obtain a digital copy of your personal information or request the transfer of your personal information to another company. Please note though that this right only applies to automated data which you initially provided consent for us to use or where we used the data to perform a contract with you.

You have the right to object to the processing of your personal information where we believe we have a legitimate interest in processing it (as explained above). You also have the right to object to our processing of your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your data which override your rights and freedoms.

You have the right to request human intervention where we are carrying out automated decision making when processing your personal information. This form of processing is permitted where it is necessary as part of our contract with you, providing that appropriate safeguards are in place or your explicit consent has been obtained.

If you have any concerns or complaints regarding the way in which we process your data, please email us directly at service@hookii.com. You also have the right to make a complaint to the data protection regulator in the US or EU or in other competent authority). We would, however, appreciate the chance to deal with your concerns before you approach the data protection regulator, so please do contact us in the first instance.

We may need to request specific information from you to help us confirm your identity and ensure your right to exercise any of the above rights. This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

If you wish to exercise any of these rights, please email us at service@hookii.com.

Cookies are small text files that are sent to or accessed from your web browser or your computer's hard drive. Cookies typically contains the name of the domain (internet location) from which the cookies originated, the"lifetime"of the cookies (i.e., when it expires) and a randomly generated unique number or similar identifier. Cookies also may contain information about Device, such as: user settings, browsing history, and activities conducted while using the Services.

Our Services use the following cookies:

• Strictly necessary cookies, which are required for the operation of the Services. Without them, for example, you would not be able to use your Account.
• Analytical/performance cookies, which allow HOOKII to recognize and count the number of visitors, learn how visitors navigate the Services, and improve the Services.
• Functionality cookies, which HOOKII uses to recognize you when you return to the Services.

To learn more about cookies and web beacons, please email us at service@hookii.com.

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We have taken appropriate safeguards to require that your personal information will remain protected and require our third-party service providers and partners to have appropriate safeguards as well. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system's breach, we may attempt to notify you electronically by posting a notice on our Services, by mail or by sending an email to you.

Another part of our priority is adding protection for children while using the internet. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity.

HOOKII does not knowingly collect any Personal Identifiable Information from children under the age of 13 in EU, or age under 14 in US (or other age as required by local law). If you think that your child provided this kind of information on our website, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.

If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child's account.

The California Consumer Privacy Act of 2018 (“CCPA”) provides California residents with the right to know what categories of personal information HOOKII has collected about them and whether HOOKII disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find this information below:

The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth above this Privacy Policy, respectively.
“Sales” of Personal Information under the CCPA
For purposes of the CCPA, HOOKII does not sell personal information, nor do we have actual knowledge of any sale of personal information of minors under 16 years of age.
Additional Privacy Rights for California Residents
Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.
Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us as set forth in Contact Us below and provide written authorization signed by you and your designated agent.
Verification. To protect your privacy, we will take steps the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include asking you for additional proof of identity and asking questions regarding your account and use of our Services.
If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth in Contact Us below. We will process such requests in accordance with applicable laws.
California Shine the Light. California Shine the Light law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties.
Right for minors to remove posted content. Where required by law, California residents under the age of 18 may request to have their posted content or information removed from the publicly-viewable portions of the Services by contacting us directly as set forth in “Contact Us” below or by logging into their account and removing the content or information using our self-service tools.

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. Please note that we do not currently sell your Personal Information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, or to request that we do not sell your information in the future, please Contact Us as set forth below with the subject line “Nevada Do Not Sell Request”.

The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.

If at any time you find either this Agreement or the Privacy Policy unacceptable, you must immediately cease accessing the App and Websites. Unless HOOKII obtains your express consent, any revised Privacy Policy will apply only to information collected by HOOKII after the revised Privacy Policy takes effect, and not to information collected under any earlier versions of the Privacy Policy.

If you have questions, or if you would like to make a complaint, please contact us electronically at: service@hookii.com.

Or in the alternative, you can contact us at Ofly International Limited.

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