2. GENERAL INFORMATION
Protecting the personal data of users and customers is something we take very seriously, and we comply with the applicable data protection law provisions. We only collect, process and use your personal data if a statutory provision allows us to do so or if you have granted your consent to this collection, processing and use. The same applies to the processing and use of personal data for advertising and marketing purposes. We can also collect information on this website that does not, in itself, allow us to draw any direct conclusions as to your identity. In certain cases, however – particularly if it is combined with other data – this information can constitute “personal data” within the meaning of the data protection laws. In addition, we can also use this website to record information that does not allow us to identify you either directly or indirectly; this applies, by way of example, to summarize information on all users of this website.
- what information we collect in connection with the use of this website and the functions it offers (e.g. placing an online order via this website) and how we process and use this information and
- what information we collect in connection with visits to this website and how we process and use this information.
3. DATA PROCESSED, LEGAL BASIS AND PURPOSES OF THE PROCESSING
Depending on the services provided by our website and used by you, your choices and the configuration of your device (with respect in particular to cookies and other trackers), personal data concerning you (your "Data") collected and processed by Hooman Group Ltd mainly include: Your family name, first name, title, e-mail address, postal address and telephone number, your bank account details for the purposes of online sales, your billing and delivery address, information on the mode of payment, your past purchases, your preferences and interests, as well as your connection logs. For each activity using your Data, we will establish an appropriate lawful basis. Therefore, Data shall be collected either with your express consent, or where necessary to fulfil your orders (performance of a contract), for the pursuance of our legitimate interests when the processing is required for the management of our (the data controller's) daily business activities, or for compliance with our legal obligations. The lawful bases we rely upon for key activities in relation to this website are identified in sections 3.2 to 3.6 below.
Your Data shall be collected for the following purposes:
- to answer your questions sent via e-mail, contact forms and chats
- to enable you to create a guest account or customer account) and thereby purchase our products online;
- to manage any purchase orders that you may place online and their delivery as well as the applicable warranties;
- register your products online, to get access to additional services
- to ensure the security of your online transactions, to prevent fraud and payment defaults for more details);
- to manage and optimise the customer relationship as described in further detail in sections 3.2 to 3.6 below;
- subject to your consent: to send you information about our offers, news and events (newsletters, invitations and other publications);
- to carry out statistical analysis regarding how this website is used (e.g. number of hits, duration of visits etc.) and of customer order behaviour. The Data that is indispensable for us to fulfil the purposes that are described above is marked with an asterisk on the various pages of the website. Should you not fill in these mandatory fields, we may not be able to process your requests and/or to provide you the requested products and services. Other Data is purely optional and allow us to know you better and to improve our communications and services accordingly. Further information on purposes and legal basis for specific processing scenarios can be found below.
3.2 Registration and customer account
This website gives you the opportunity to register and create a customer account. If you create a customer account, you will automatically be allocated a personal account which is linked to the e-mail address you have provided. You can use your e-mail address for various Hooman Group processes and procedures (e.g. placing an online order). This is why you can also create a customer account independently of a specific online order. In order to create the customer account, we collect the data indicated in the corresponding registration form, in particular your title, first name and family name, postal address and e-mail address, as well as a password that you select yourself (“Master Data”). The mandatory fields in the registration form must have been completed in order to register and create a customer account. When we confirm your registration, we will allocate you a personal account under which we will store your Master Data in our customer database. If you use your customer account for an online order or to use a further service, we will save the data collected in connection with the online order/use of the further service under your Hooman customer account. We can process and use the data stored under your Hooman account to respond to enquiries about or requests for customer support, for example if you pose a question about registration, about your user account or other functions of your Hooman account to us or another customer support provider (customer support partner).
We may grant customer support partners limited access to the data stored on our customer database as regards your Hooman account for this purpose, in compliance with data protection regulations (and usually within the scope of a contract stipulating said services). When you pose a request to us or a customer support partner, the content of this request is stored under your Hooman website account. This personal information is used solely for handling your enquiry.
The legal basis of any processing of your Master Data described in this section is performance of a contract.
We can also give you the opportunity, outside of this website, to register for further services using your Hooman website account. In this case, your Master Data will also be used for the further service in question. We will provide you with separate information on the handling of your personal data in connection with the relevant further service.
You can place an online order on this website even without registering and creating a customer account ("Guest Order"). In this case, too, we need the data that is relevant to the order (in particular your first name and family name, billing and delivery address, information on the mode of payment and the corresponding payment details) and that you have to enter during the order process. The mandatory fields in the registration form must have been completed in order to place a Guest Order. We save the information that is collected and arises in connection with a Guest Order in our order data-base in order to process the online order and then to fulfil statutory retention obligations.
If you place an order (on this website, by phone or in a store) by creating or using an existing Hooman life website account, we will save the information that is collected and arises in connection with the order in our customer database; this is also done in order to manage any purchase orders and their delivery as well as the applicable warranties. The legal basis of any processing of your personal data described in this section is performance of a contract and compliance with legal obligations (for example, our obligations under consumer protection law).
3.4 Functions on this Website
On this website, we can offer you further optional functions for which personal data or other information has to be collected, e.g. if you participate in a survey on this website or send us questions or feedback. We will only collect, process and use such data and information to the extent that is required for the function in question (e.g. to answer your question or process your feedback). Some of this processing is necessary for taking steps at your request to enter into a contract with you. Additional processing is necessary for the purpose of the legitimate interests pursued by Hooman Group Ltd: We have a legitimate interest in improving our services as well as our website itself and in carrying out, inter alia, surveys in this regard. Such legitimate interest of Hooman Group is appropriately balanced with the interests of the users within the limitations abovementioned.
3.5 Direct Marketing without your consent
In certain cases, sending you direct advertising without your explicit consent is permissible by law. This may, for example, relate to the use of an e-mail address that we have received in connection with the sale of goods or services. In the latter case, we will draw your attention to this possibility and to your right to object when we collect the e-mail address. In all cases, you have an absolute right to prevent (i.e., opt-out of) direct marketing at any time.
The processing of your personal data described in this section is necessary for the purpose of the legitimate interests pursued by Hooman Group Ltd. We have a legitimate interest in direct marketing as long as we comply with the legal requirements for marketing (e.g., requirements for electronic marketing communications).
3.6 Connection logs
We record every time this website is visited and every time a file stored on this website is accessed. This pseudonymous information is saved for internal system-related and statistical purposes as well as security reasons. The information recorded includes the name of the file accessed, the date and time of access, the volume of data transmitted, notification regarding successful access, information on the web browser used, the requesting domain and the IP address of the requesting computer. The processing of your personal data described in this section is necessary for the purpose of the legitimate interests pursued by Hooman Group Ltd: We have a legitimate interest in saving connection logs for the purposes of determining disruptions and for security reasons (e.g., to investigate attack attempts) and in order to learn more about how our website is used. Such legitimate interest of Hooman Group Ltd is appropriately balanced with the interests of the users within the limitations abovementioned.
In order to make our website as user-friendly as possible, we – like many other companies – use “cookies”.
Cookies are small text files that are sent when visiting an internet page and are stored in a user’s browser. In case the respective internet page is accessed again, the user’s browser sends back the content of the cookies and, thus, allows for the recognition of the user.
Typically cookies do not collect personal data but may be used to create a user profile. In this case, you will be informed about this below.
3.8 Website Analysis
We use analysis services on this website to allow us to record information on the use of this website (e.g. pages or sections that are particularly popular) and to constantly improve our offering.
The processing of your personal data described in this section is necessary for the purpose of the legitimate interests pursued by Hooman Group Ltd: We have a legitimate interest in collecting statistical information about the usage of our website in order to improve our offering.
3.8.1 Google Analytics
You can set your browser software to prevent cookies from being saved. Please note, however, that if you do so, you might not be able to use all of the functions offered by this website. You can also prevent Google from storing the data generated by the cookie relating to your use of the website (including your IP address) and from processing this data by downloading and installing the browser plug-in that is available here.
3.9 Tracking and Facebook Pixel
We use tracking tools including the Facebook Pixel on this website to better understand your preferences by analysing your behavior on our website and offer you products or services more in line with your interests.
The processing of your personal data described in this section is necessary for the purpose of the legitimate interests pursued by Hooman Group Ltd: We have a legitimate interest in efficient online marketing as long as you don’t object.
3.9.2 Facebook Pixel
This website uses the so-called Facebook Pixel (Website Custom Audience Pixel) without the so-called "extended matching". Pseudonymous information about your use of this website (e.g. products you have viewed, unique ID numbers that may distinguish you from other users) is transmitted to Facebook Inc, 1601 South California Avenue, Palo Alto, CA 94304, USA ("Facebook"). This can allow Facebook to identify you across multiple websites. We are responsible for processing of this data together with Facebook and use this information to identify target groups of our website for advertising purposes and in order to target them on Facebook. The processing takes place through Facebook in the USA. For the USA, there is no adequacy decision of the European Commission. However, Facebook Inc. is certified under the EU-U.S. Privacy Shield Agreement. Further information about the certification can be found here: https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active You can revoke the data collection by deactivating advertising based on partner data in your Facebook settings at https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen or by clicking here.
3.10 Social plugins
"Social plugins" for a number of social networks have been incorporated into this website. These allow you to recommend content and offerings available on our website to your friends and other people you know.
Our social plugins are not activated by default. If you choose to activate a social plugin by clicking on it, you can transmit data to the operator of the social network in question. This data can include, in particular, your IP address, browser information and operating system, screen resolution, installed browser plugins such as Adobe Flash Player, where visitors originated from if they followed a link (referrer), the URL of the current page or in-formation on the use of a certain service on this website.
The processing of your personal data described in this section is necessary for the purpose of the legitimate interests pursued by Hooman Group Ltd: We have a legitimate interest in processing our user’s data upon their request if they activate the plugin and request to share information with a social network. The section below provides you with information on the social plugins on this website. You can find further information on the scope and purpose of the collection, processing and use of your (personal) data and, where appropriate, on the data protection settings in the data protection information of the relevant social network
3.10.1 Facebook & Instagram plugins
Plugins relating to the social network Facebook, 1601 South California Avenue, Palo Alto, CA 94304, USA (a territory where the level of protection of privacy is not equivalent to the one enjoyed in the European Union) ("Facebook") have been integrated into this website. You can recognize them by the Facebook logo or the “Like” button on our page. You can find an overview of the Facebook plugins here.
When you visit our website, the plugin establishes a direct connection between your browser and the Facebook server. This informs Facebook that you have visited our page using your IP address.
If you click on the Facebook “like” button while you are logged in to your Facebook account, then you can link the content of our website with your Facebook profile. This allows Facebook to allocate the visit to our website to your user account.
We would like to point out that, as the website provider, we are not aware of the content of the data transmitted or the manner in which it is used by Facebook. You can find further information on the handling of your data in the Facebook Data Policy here.
Plugins relating to the social network YouTube, 901 Cherry Avenue, San Bruno, CA 94066, USA - a territory where the level of protection of privacy is not equivalent to the one enjoyed in the European Union - ("YouTube") have been integrated into this website. You can recognize them by the YouTube logo on our page. You can find an overview of the YouTube plugins here. We would like to point out that, as the website provider, we are not aware of the content of the data transmitted or the manner in which it is used by YouTube. You can find further information on the handling of your data by YouTube here.
- RECIPIENTS OF THE DATA
Your Data shall be processed by Hooman Group Ltd. It is not going to be transferred or made accessible to any third party with the exception of (i) possible subcontractors of Hooman Group Ltd (e.g., carriers, providers of hosting and maintenance services of the Site and of Digital Data Capture payment and fraud management service providers, web analysis providers etc.), for purely technical and logistical reasons or third parties that have been engaged to perform any of the functions listed in clause 3.1 above for us, (ii) with third parties offering tracking technologies or social plugins (e.g. Facebook plugin) as described at 3.9 and 3.10 above, and (iii) in case of a reorganization of Hooman Group Ltd, including total or partial transfer of assets, merger, takeover, de-merger, and in general any reorganization transaction; and (iv) as otherwise described in this section 4.
Your Data may be disclosed to affiliated companies of Hooman Group Ltd for purposes of management and optimization of the customer relationship as set forth in section 3, and, subject to your consent, to send you information about the offers, news and events of Hooman Group Ltd. Your Data may also be disclosed where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods or services requested by you.
Finally, Hooman Group Ltd may disclose your Data to third parties if such disclosure is required by law, by a regulatory provision or by a court ruling, or if this disclosure is necessary to ensure the protection and defence of its rights.
- TRANSFERS OF DATA ABROAD
We also forward personal data to affiliated companies, third parties or subcontractors who are located outside of Hong-kong, including, among others, territories like the European Economic Area ("EEA") countries and the USA. In such cases we ensure prior to the transfer that the transfer is subject to appropriate safeguards required under the Personal Data Ordinance (“PDPO”) by having agreed upon appropriate binding legal obligations and data protection clauses.
In case we forward your personal data to countries outside the EU this has been indicated in this Policy. A copy of the safeguards implemented by Hooman Group Ltd as well as an overview of third country recipients may be obtained by sending a request to Hooman Group Ltd.
- RETENTION PERIOD OF YOUR DATA
We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.
- PROTECTION OF PERSONAL DATA
To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
- YOUR RIGHTS
In accordance with applicable data protection laws and regulations, you may have a right to request access to and rectification of your Data (including Data related to your profiling).
The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above in clause 3.1 above by submitting your request in writing or via email at the contact details provided below. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods and/or services to you and we shall, in such circumstances, notify you before completing the processing of your request. For example, should you oppose the use of your Data for the building up of your client profile; you will no longer benefit from customised offers or services.
Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
These rights may be exercised or any questions, feedback and complaints may be delivered directly at the following email address email@example.com. You may be asked for proof of identity and may be charged a reasonable fee for an access request. If there are any applicable charges, we will inform you of the fees before processing your request.
We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by contacting at the contact details provided above.
We will respond to your access and rectification requests as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under applicable law).
Furthermore, you may request at any time that we stop sending you information about our offers, news and events by following the unsubscribe information included to that effect in each e-mail or SMS text message that we send you.
In terms of direct marketing, you may, at any time, require that we cease to use your Data.
- COLLECTION OF DATA ON THIRD-PARTY WEBSITES
Links on this website may take you to third-party websites that are not within our sphere of control. As a result, please read the terms and conditions of use and data protection information on these websites to find out more about the collection, processing and use of (personal) information on these websites.
- CHANGES TO THIS POLICY
We may change this Policy from time to time in order to reflect changes in the law and/or our privacy practices. In this case we will inform you accordingly in advance. Your continued use of our Site, online features and services thereafter constitutes your acknowledgement and acceptance of such changes.
The website https://www.thehoomanlife.com (also the "Site") is operated by Hooman Group Ltd, having its registered office at 2107, 21/F, CC WU Building, 302-308 Hennessy Road, Hong Kong and its related corporations (“HOOMAN”), in its capacity as data controller for the purposes of applicable data protection laws and regulations.
In order to make our website as user-friendly as possible, we – like many other renowned companies – use “cookies”.
- THE TYPES OF COOKIES WE USE AND THEIR PURPOSES
Cookies may be set either by the Site (“first party cookies”) or by third party websites who run content on the website you are looking at (“third party cookies”).
The cookies used on our website are categorised, as follows:
- Cookies which are “strictly necessary” for the functionality of the website’s platforms. These cookies are essential in order to enable users to move around the website and fulfil express requests from you as a user of the website (e.g., cookies which serve the purpose of identifying or authenticating our users so you do not need to log in again very time you visit the website or cookies that temporarily store certain user entries like shopping cart content or content of an online form).
- “Functionality” cookies which allow the website to remember choices you make and your preferences for example where you register/sign-up for events, products and/or services or to set the language or the currency.
- “Performance/Analytics” cookies which collect information about how users navigate the website, for example, which pages users access most frequently. They identify how users interact with our website, any errors that occur, which pages are not used often, which pages take a long time to load, which pages users tend to visit and in what order. These cookies do not collect any information which could identify you and are only used to help us improve how our website works and understand what interests our website’s users (e.g., clicked ad banners, visited subpages, search queries asked).
- “Targeting or advertising” cookies used to deliver adverts relevant to an identified machine or other device (not a named or otherwise identifiable person) which are tailored to interests associated with the website activity tied to that machine or device (e.g., clicked ad banners, visited subpages, search queries asked). For example, if a cookie on a third party website recognises that a particular product was purchased from a particular device, that cookie may “talk to” marketing cookies on the website to ensure advertisements about similar products displayed on the website are accessed from that device. These cookies are also used to limit the number of times a user sees an advertisement as well as to help measure the effectiveness of an advertising campaign. They may also remember that the website has been visited from a device and share that information with marketing organisations. The marketing cookies on our website are operated by third parties with our permission. Marketing cookies are used to monitor from which advertising source a user was directed towards our website so that we know whether it is worth us investing in that particular advertising source.
We will capture your consent to the use of certain cookies set out in this Policy when you first access the website and if we introduce any new cookies to the website (unless they are strictly necessary cookies). If so, when you first visit the website, a small banner will appear advising you to agree to the cookies that we set on the website.
If you reject cookies, we will not set any further cookies on your device, except the “strictly necessary” cookies detailed above (including, unavoidably, a cookie to remember that you don't want any cookies set when you visit the website). You can usually set your browser to warn you when a cookie is being sent or to remove or reject cookies. Each browser is different, so look at your browser ‘Help’ menu to learn the correct way to modify your cookie settings. If you choose to remove or reject cookies, it will affect many features or services on our website.
If you agree to cookies from our website by continuing to use the website, we will set cookies on your device. If you wish to delete the cookies we have set on your device, you can do this via your web browser settings.
- STORAGE PERIODS
The various cookies used by us have different storage periods, at the end of which your data will no longer be stored. However, cookies implemented on our Site shall be kept in accordance with applicable laws and regulations for a period of time that does not exceed thirteen (12) months.
- HOW CAN I MANAGE MY COOKIE INSTALLATION PREFERENCES?
In addition to what is stated in this document, you can manage your preferences pertaining to cookies directly on your browser and prevent, for example, third parties from installing them on your device. In addition, through the browser preferences, you can delete previously installed cookies. Please note that by disabling all cookies, the operation of this website may be compromised. You can find more information as to managing cookies in their browsers by going to the following link: www.youronlinechoices.com.
You may disable first party technical cookies referred to in the table by clicking on the links or, in the case of third parties technical cookies by clicking on the information notices and the forms for consent of such third party. Notwithstanding, the deactivation of such cookies may compromise the correct surfing and the functionalities of the Site.
You may disable first party profiling cookie referred to in the table by clicking on the links indicated or, in the case of third parties cookies, by accessing the information notices and the form for consent of such third party.
- CHANGES TO THIS POLICY
- CONTACT/ADDRESS DETAILS (INCLUDING CONTACT DETAILS OF OUR DATA PROTECTION OFFICER)
If you have any questions about this Policy, please contact us at firstname.lastname@example.org
The table below lists the cookies we collect and what information they store.
|Cookie Name||Cookie Description|
|FORM_KEY||Stores randomly generated key used to prevent forged requests.|
|PHPSESSID||Your session ID on the server.|
|GUEST-VIEW||Allows guests to view and edit their orders.|
|PERSISTENT_SHOPPING_CART||A link to information about your cart and viewing history, if you have asked for this.|
|STF||Information on products you have emailed to friends.|
|STORE||The store view or language you have selected.|
|MAGE-CACHE-SESSID||Facilitates caching of content on the browser to make pages load faster.|
|MAGE-CACHE-STORAGE||Facilitates caching of content on the browser to make pages load faster.|
|MAGE-CACHE-STORAGE-SECTION-INVALIDATION||Facilitates caching of content on the browser to make pages load faster.|
|MAGE-CACHE-TIMEOUT||Facilitates caching of content on the browser to make pages load faster.|
|SECTION-DATA-IDS||Facilitates caching of content on the browser to make pages load faster.|
|PRIVATE_CONTENT_VERSION||Facilitates caching of content on the browser to make pages load faster.|
|X-MAGENTO-VARY||Facilitates caching of content on the server to make pages load faster.|
|MAGE-TRANSLATION-FILE-VERSION||Facilitates translation of content to other languages.|
|MAGE-TRANSLATION-STORAGE||Facilitates translation of content to other languages.|