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Privacy Policy

Welcome to H Market

Below we have set out our privacy policy:

This Privacy Policy explains our practices, including your rights, regarding the collection, use and disclosure of certain information, including your personal information, by HWH General Trading LLC (together with its parents, subsidiaries, representatives, affiliates, officers and directors, “HWH”), with reference to your access and use of the H Market website or application, and/or accessing or using the services contained therein (together, the “Services”), by purchasing something from us (the “Products”) or by your signing up for a personal user Services account or membership to access any of the Services (an “Account”).

Contacting Us

If you have general questions about your account or how to contact Customer Service for assistance, please contact us at the address listed on our website. For questions specifically about this Privacy Policy, or our use of your personal information, cookies or similar technologies, you may also contact us at the same contact information.

The data controller of your personal information is HWH, which also provides the service to you. Please note that if you contact us to assist you, for your safety and ours we may need to authenticate your identity before fulfilling your request.

Collection of Information

We collect and store the following kinds of personal information about you when you access the Services, purchase any Products or establish or hold an Account:

• Information you provide to us: We collect personal information you provide to us which includes:

• your name, email address, address or postal code, telephone number, gender, data of birth / age, nationality, title, username and password. We collect this information in a number of ways, including when you enter it while using the Services, acquire Products, open an Account, interact with our Customer Service, or participate in surveys or marketing promotions; and

• information about your organization, your role within your organization, and the name, address, telephone number and email address of your employer. We collect this information in a number of ways, including when you upload it to your Account, or otherwise provide information to us through the Services or elsewhere.

• Information we collect automatically: We collect personal information about you and your use of the Services, your interactions with us and our advertising, as well as information regarding your computer or other device used to access our service (such as gaming systems, smart TVs, mobile devices and set top boxes). This information includes:

• your activity on the H Market application;

• details of your interactions with Customer Service, such as the date, time and reason for contacting us, transcripts of any chat conversations, and if you call us, your phone number and call recordings;

• device IDs or other unique identifiers, device and software characteristics (such as type and configuration), connection information, statistics on page views, referral URLs, IP address (which may tell us your general location), browser and standard web server log information; and

• information collected via the use of cookies, web beacons and other technologies, including ad data (such as information on the availability and delivery of ads, the site URL, as well as the date and time).

• Information from other sources: We might supplement the personal information described above with personal information we obtain from other sources, including from both online and offline data providers and third-party providers. Such supplemental personal information could include demographic data, interest based data, any views and opinions that you choose to publicly post about us on social media platforms, and internet browsing behaviour.

• Creation of personal information: We also create personal information about you in certain circumstances, such as records of your interactions with us, and details of your purchase history.

Sensitive Personal Information

We do not seek to collect or otherwise process Sensitive Personal Information (as defined below) in the ordinary course of our business. Where it becomes necessary to process your Sensitive Personal Information for any reason, we rely on one of the following legal bases:

• Compliance with applicable law: We may process your Sensitive Personal Information where the processing is required or permitted by applicable law (e.g., to comply with our diversity reporting obligations).

• Detection and prevention of crime: We may process your Sensitive Personal Information where the processing is necessary for the detection or prevention of crime (e.g., the prevention of fraud).

• Establishment, exercise or defence of legal rights: We may process your Sensitive Personal Information where the processing is necessary for the establishment, exercise or defence of legal rights.

 Consent: We may process your Sensitive Personal Information where we have, in accordance with applicable law, obtained your prior, express consent prior to processing your Sensitive Personal Information (this legal basis is only used in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way).

If you provide Sensitive Personal Information to us, you must ensure that it is lawful for you to disclose such data to us, and you must ensure a valid legal basis applies to the processing of that Sensitive Personal Information.

For the purposes of this Privacy Policy, “Sensitive Personal Information” means personal information about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, national identification number, or any other information that are deemed to be sensitive under applicable law.

Use of Information

We use your personal information for a number of purposes, subject to applicable law, including:

• to provide, analyse, administer, enhance and personalise the Services or Products;

• to identify relevant Products or Services that are relevant to you or our other customers;

• to inform the Product mix, customer tastes and changes to Products or Services;

• to enhance the H Market product;

• the management and operation of our communications, IT and security systems; and audits (including security audits) and monitoring of such systems;

• engaging with you for the purposes of obtaining your views on our Services or Products;

• detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law;

• establishing, exercising and defending legal rights;

• compliance with our legal and regulatory obligations under applicable law;

• determine your general geographic location, provide localised content, provide you with customised and personalised recommendations;

• to analyse and understand our audience, improve the Services (including our user interface experiences) and optimise user experience, recommendation algorithms and delivery; and

• to communicate with you concerning the Services (for example by email, push notifications text messaging, and online messaging channels), so that we can send you news about H Market, details about new features, products and content available H Market, and special offers, promotional announcements and consumer surveys, subject to obtaining your prior opt-in consent to the extent required under applicable law, and to assist you with operational requests such as password reset requests.

Legal basis for processing

In processing your personal information in connection with the purposes set out in this Privacy Policy, we may rely on one or more of the following legal bases, depending on the circumstances:

• The processing is necessary in connection with any contract or order that you have entered into with us, or to take steps prior to entering into a contract or order with us;

• We have a legitimate interest in carrying out the processing for the purpose of: (i) providing or improving our Services or Products; (ii) fulfilling our regulatory and compliance obligations; (iii) contacting you, subject always to compliance with applicable law; (iv) detecting, and protecting against, breaches of our policies and applicable laws; or (v) establishing, exercising or defending our legal rights (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms);

• We have obtained your prior consent to the processing (this legal basis is only used in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way); or

• The processing is necessary for compliance with a legal obligation.

Disclosure of Information

We disclose your personal information to other entities within the HWH group in accordance with applicable law, legitimate business purposes and the operation of our Services, and to third parties, as described below:

• Compliance with law and protection of HWH and others: In compliance with international human rights standards and in accordance with “Do No Harm” principles, HWH and other third parties may disclose and otherwise use your personal and other information where we or they reasonably believe such disclosure is needed to (a) satisfy any applicable law, regulation, legal process or governmental request, (b) enforce applicable terms of use, including investigation of potential violations thereof, (c) detect, prevent or otherwise address illegal or suspected illegal activities (including payment fraud), security or technical issues or (d) protect against harm to the rights, property or safety of HWH, users of the Services or the public, as required or permitted by law;

• you and, where appropriate, your appointed representatives;

• accountants, auditors, lawyers and other outside professional advisors to HWH, subject to binding contractual obligations of confidentiality;

• third party processors, located anywhere in the world, subject to the requirements noted below;

• any relevant third-party acquirer(s), 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); and

• any relevant third-party provider, where our Services 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 information, the processor will be subject to binding contractual obligations to: (i) only process the personal information in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the personal information; together with any additional requirements under applicable law.

International transfer of personal information

Because of the international nature of our business, we transfer personal information within the HWH group, and to third parties as noted in the ‘Disclosure of information’ section above, in connection with the purposes set out in this Privacy 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.

Please note that when you transfer any personal information directly to a HWH entity, we are not responsible for that transfer of your personal information. We will nevertheless process your personal information, from the point at which we receive those data, in accordance with the provisions of this Privacy Policy.

Data accuracy

HWH will take reasonable steps to ensure that:

• your personal information that we process are accurate and, where necessary, kept up to date; and

• any of your personal information that we process that are inaccurate (having regard to the purposes for which they are processed) are erased or rectified without delay once we are made aware of such inaccuracy.

From time to time we may ask you to confirm the accuracy of your personal information.

Data minimization

HWH takes every reasonable step to ensure that your personal information that we process are limited to the personal information reasonably necessary in connection with the purposes set out in this Privacy Policy.

Data retention

HWH takes reasonable steps to ensure that your personal information is only processed for the minimum period necessary for the purposes set out in this Privacy Policy. The criteria for determining the duration for which we will retain your personal information are as follows:

(1) we will retain personal information in a form that permits identification only for as long as:

(a) we maintain an ongoing relationship with you (e.g., where you are a user of our Services, hold an Account or you are lawfully included in our mailing list and have not unsubscribed); or

(b) your personal information are necessary in connection with the lawful purposes set out in this Privacy Policy, for which we have a valid legal basis (e.g., where your personal data are included in a contract between us and your employer, and we have a legitimate interest in processing those data for the purposes of operating our business and fulfilling our obligations under that contract; or where we have a legal obligation to retain your personal information),


(2) the duration of:

(a) any applicable limitation period under applicable law (i.e., any period during which any person could bring a legal claim against us in connection with your personal information, or to which your personal information are relevant); and

(b) an additional two (2) month period (or longer subject to applicable law) following the end of such applicable limitation period (so that, if a person brings a claim at the end of the limitation period, we are still afforded a reasonable amount of time in which to identify any personal information that are relevant to that claim),


(3) in addition, if any relevant legal claims are brought, we continue to process personal information for such additional periods as are necessary in connection with that claim.

During the periods noted in paragraphs (2)(a) and (2)(b) above, we will restrict our processing of your personal information to storage of, and maintaining the security of, those data, except to the extent that those data need to be reviewed in connection with any legal claim, or any obligation under applicable law.

Once the periods in paragraphs (1), (2) and (3) above, each to the extent applicable, have concluded, we will either:

• permanently delete or destroy the relevant personal information; or

• anonymise the relevant personal information.

Access to Your Account and Profiles

In order to provide you with ease of access to your account and to help administer H Market and provide the Services, we use technology that enables us to recognise you as the account holder and provide you with direct access to your account without requiring you to retype any password or other user identification when you access the Services.

Your Choices

You can opt in to receive mobile push notifications from H Market. If you subsequently decide you no longer wish to receive these notifications, you can use your mobile device’s settings functionality to turn them off.

Your Information and Rights

You can request access to, and copies of, your personal information, or request correction of any out-of-date or inaccurate personal information we hold about you.

You can most easily do this by visiting the My Account (or relevant profile) portion of our website, where you have the ability to access and update some of information about your account. You must be signed in to access you “Account.” You may also request, on legitimate grounds, that we delete personal information that we hold about you by deleting your account, or restrict the processing of your personal information (however this may result in us being unable to provide the Services or Products to you).

You have the right to have certain of your personal information transferred to another data controller, in a structured, commonly used and machine-readable format, to the extent applicable. Where we process your personal information on the basis of your consent, you have the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the processing of your personal information in reliance upon any other available legal bases).

To make requests, or if you have any other question regarding our privacy practices, please contact us. Please also see the Your Choices section of this Privacy Policy for additional rights and choices regarding your information.

We may reject requests that are unreasonable or not required by law, including those that would be extremely impractical, could require disproportionate technical effort, or could expose us to operational risks such as free trial fraud.

You also have the right to lodge complaints regarding the processing of your personal information with a data protection authority (where applicable).

Subject to applicable law, you may also have the following additional rights regarding the processing of your personal information:

• the right to object, on grounds relating to your particular situation, to the processing of your personal information by us or on our behalf; and

• the right to object to the processing of your personal information by us or on our behalf for direct marketing purposes (however this may result in us being unable to provide the Services or Products to you).

Security of your information.

We use appropriate administrative, logical, physical and managerial security measures to safeguard your personal information against loss, theft and accidental or unauthorised, destruction, disclosure, access, use and modification, in accordance with applicable law. Unfortunately, no measures can be guaranteed to provide 100% security.

Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your personal information, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any personal information that you send to us are sent securely.

Other Websites, Platforms and Applications

The Services may be provided through and/or utilize features (such as voice controls) operated by third party platforms, or contain links to sites operated by third parties whose policies regarding the handling of information may differ from ours. For example, you may be able to access the Services through platforms such as gaming systems, smart TVs, mobile devices, set top boxes and a number of other internet connected devices. These websites and platforms have separate and independent privacy and data policies, privacy policies, notices and terms of use, which we recommend you read carefully. In addition, you may encounter third party applications that interact with H Market.

Cookies and similar technologies

When you visit a website or use our Services we will typically place Cookies (as defined below) onto your device, or read Cookies already on your device, subject always to obtaining your consent, where required, in accordance with applicable law. We use Cookies to record information about your device, your browser and, in some cases, your preferences and browsing habits. A “Cookie” is a small file that is placed on your device when you visit a website (including our websites). In this Privacy Policy, a reference to a “Cookie” includes analogous technologies such as web beacons and clear GIFs.

We process personal information to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding Services or Products that may be of interest to you. If we provide Services or Products to you, we may send information to you regarding our Services, Products, upcoming promotions and other information that may be of interest to you, using the contact details that you have provided to us, subject always to obtaining your prior opt-in consent to the extent required under applicable law.

You may unsubscribe from our promotional email list at any time by simply clicking on the unsubscribe link included in every promotional email we send. After you unsubscribe, we will not send you further promotional emails, but in some circumstances we will continue to contact you to the extent necessary for the purposes of any Services or Products you have requested.


You must be 18 years of age or older to use the Services or purchase any Products. In certain jurisdictions, the age of majority may be older than 18, in which case, you must satisfy that age in order to become a member.

Changes to This Privacy Policy

We will update this Privacy Policy from time to time in response to changing legal, regulatory or operational requirements. Your continued use of H Market after any such updates take effect will constitute acceptance of those changes. If you do not accept any updates to this Privacy Policy, you may cancel your use of H Market. To see when this Privacy Policy was last updated, please see the “Last Updated” section below.

Last Updated:

10 November 2019

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