HCONNECT APP – PRIVACY NOTICE
(March 2022)
Introduction
Your privacy is very important to us and we undertake to protect your personal information privacy. This notice ("Privacy Notice") is provided by HConnect Event Management Limited ("we", "us", "our"), and we hope to let you know the manner in which we collect, use, share, protect or otherwise process personal information relating to you (“HConnect User”, “you”, “your”) as a HConnect User of the HConnect App. We are the data controller in respect of personal information processed relating to you.
Please read this Privacy Notice carefully to understand how we handle the personal information about you that we collect and how we use that personal information. Unless otherwise specified, capitalized terms in this Privacy Notice shall have the same meaning as defined under the HConnect Terms and Conditions.
Changes to this Privacy Notice
We reserve the right to update this Privacy Notice at any time and we will notify you of any material updates or changes to this Privacy Notice on at least an annual basis. We may also notify you in other ways from time to time about the processing of your personal information.
If we change our policy to offer non-public personal information to nonaffiliated third parties other than for the reasons mentioned in this Privacy Notice, we will provide you with an option to exclude your data from inclusion in this information sharing program and certain disclosures may require us to get an "opt in" or "opt out" from you. If this is required, we will do so before information is shared.
What Personal Information We Collect and Use
We collect, use or otherwise process personal information about you, including the following:
Information you share with us when creating and registering for your account on HConnect App and/or any other details you provide to us in connection with such registration. Such information may include your name, title, address, signature, telephone numbers, profile picture and email address;
Information our affiliates have provided us about you (which they have shared with us with your consent or that such affiliate is otherwise permitted to share with us in accordance with the relevant Privacy Notice of that affiliate);
Contents of emails and other correspondence and communications with you (including but not limited to your communications in the form of voice messages, text messages and/or other means via the HConnect App);
Information collected in the process of providing you with services of the HConnect App, including, for example, your device information (including your device model, mobile number, IMEI number, IMSI number), operating system, login IP address, HConnect version number, the method, type and status of network connection, network condition, operation logs, services logs (your searches and views in HConnect, service failures, referral URLs, etc.), location, your activities within the app (such as review of certain articles, number of times for opening the HConnect App), and other information collected via the use of cookies, pixel tags, local storage, and other technologies via the HConnect App or the device you use to access or interact with the HConnect App, that may be used to help us personalize and improve your experience of the HConnect App;
Information you share with us when using HConnect App (including for example meeting schedules in your device calendar and images within your devide album); and
Information from other sources. We may receive information about you from other sources, including through third party services and organizations to supplement information provided by you. This information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business, products, and services.
How We Collect your Personal Information
We collect such personal information:
We may also collect or obtain personal information in the manner as stipulated under the section entitled ‘What Personal Information We Collect and Use’ above. You can choose to share or stop sharing some types of personal information with us by toggling on and off your preferences in the HConnect App settings; other types of information are mandatory to ensure the proper functioning of the HConnect App and cannot be switched off if you wish to use the HConnect App.
In particular, we may also obtain your personal information from our affiliates, third parties and publicly available sources, subject to applicable law and (where necessary) subject to providing notification to you or obtaining your consent. We may also combine information that you provide to us with information that we collect about you from other sources.
Legal Basis and Purposes of Processing your Personal Information
We process your personal information on the following legal basis and for the following purposes in this section.
Where the processing is necessary for the performance of services of the HConnect App, including for example:
Where the processing is necessary for compliance with applicable legal obligations to which we are subject, including:
Where the processing is necessary for the purposes of the pursuance of our legitimate interests, or those of a third party, balanced against your interests or fundamental rights and freedoms which are not overridden, including:
In addition, in limited circumstances, we may occasionally ask for consent for specific activities.
Several of the purposes for processing outlined above may overlap and there may be several purposes which justify our use of your personal information. We will only use your personal information for the purposes for which we have collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose for such collection. If we need to use your personal information for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.
Sharing your Personal Information
We have not sold, and we will not sell, the personal information you share with us. We may disclose information about you to our affiliates (including those who are involved in the operation, administration or management of the HConnect App as well as their representatives and personnel) or to non-affiliated entities.
More specifically, we may share your personal information with the following categories of recipients:
attorneys, accountants, auditors, administrators, advisers, IT service providers or data centers or other service providers or professionals that assist us with the marketing, administration, operation and/or management of the HConnect App;
third party applications for the purposes of providing certain features and functionalities of the HConnect App. For example, we may need to provide your information to third party applications that are used to host events which you have signed up to under the “Features” functions of the “Feed” module on the HConnect App;
where required by applicable laws or regulations or where such provision would facilitate our operations or those of law enforcement agencies, parties to disputes, regulatory or tax authorities and other governmental or public agencies or authorities, including to respond to subpoenas or court orders, judicial processes or regulatory inquiries or investigations; and
other third parties for purposes for which you have allowed or to which you have consented.
Such third parties may in turn use the services of their affiliates or third party service providers to process your personal information where necessary or appropriate. Please note that where your information is provided to a third party who processes the information as a data controller (rather than as a data processor on our behalf), the privacy terms of such third party applications will be governed by the privacy policies of each of these respective third party applications, and we cannot control and are not liable for the collection or processing of your data by such third party controllers.
Sensitive Personal Information
Sensitive personal information includes personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.
If you provide us with such sensitive personal data or we obtain it from a third party, we will process such sensitive personal information only as permitted under applicable law and where we have established a legal basis for such processing. For instance, it may be possible for us to process sensitive personal information where it is necessary for the establishment, exercise or defense of legal claims, or with explicit consent, or for reasons of substantial public interest, or where processing of sensitive information is otherwise authorised by applicable law.
Your Rights
You may have the following rights in relation to personal information that we hold about you (depending on the jurisdiction in which you are located):
Request access — to request confirmation of whether we process personal information relating to you and, if so, to request a copy of that personal information;
Request correction — to request that we rectify or update your personal information that is inaccurate, incomplete or outdated;
Request erasure — to request that we erase your personal information in certain circumstances, such as where we collected personal information on the basis of your consent and you withdraw your consent;
Request the restriction of processing — to request that we restrict the use of your personal information in certain circumstances, such as while we consider another request that you have submitted, for example a request that we update your personal information;
Withdraw consent — in the limited circumstances where our processing of your personal information is based on your consent, to withdraw your consent, although please note that withdrawal of consent (a) does not invalidate the consent-based processing that occurred prior to such withdrawal or processing that is not based on consent; and (b) means that we will no longer be able to perform such consent-based processing activities, and may result in us being unable to provide certain services to you;
Request a machine-readable copy — if applicable in your circumstances, to request that we provide a copy of your personal information to you or to another party in a structured, commonly used and machine readable format in certain circumstances; and
Object to processing — to object to certain of our data processing, such as for direct marketing purposes or where we are relying on legitimate interests (or those of a third party) to which you object based on your particular circumstances.
If you wish to exercise any of your data protection rights or if you consider that we have processed your personal information in violation of applicable law, please contact us as detailed in the section below entitled 'Contact Us'.
If you consider that we have processed your personal information in violation of applicable law and failed to remedy such violation to your reasonable satisfaction, you may also lodge a complaint with the data protection supervisory authority in your country.
Retention of Personal Information
We will keep your personal information for no longer than is necessary to fulfil the purposes of processing of your personal information as outlined above in the section entitled 'Legal Basis and Purposes of Processing your Personal Information'. We will generally retain your personal information throughout your use of the HConnect App and for no longer than five (5) years after you have deleted your HConnect App account. We may retain your personal information for longer if it is considered necessary, for example, in light of actual or potential legal action or a regulatory investigation at the time of its scheduled erasure.
To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and any applicable legal requirements.
International Transfers of Personal Information
This section only applies to the processing of personal information of you if you are located in the EEA, the UK, the Cayman Islands and the People's Republic of China (for the purpose of this notice, excluding Hong Kong, Macao and Taiwan) (the "PRC"). Owing to the international nature of our business, your personal information may in some cases be transferred out of the EEA, the UK, the Cayman Islands and the PRC, as applicable, to recipients who are based in jurisdictions whose legislation is not deemed to provide an "adequate" level of protection to personal information under the European Union's General Data Protection Regulation (the "GDPR"), the UK GDPR (as defined in section 3(10) (as supplemented by section 205(4)) of the UK Data Protection Act 2018), the Data Protection Act of the Cayman Islands (the "DPL") and the Personal Information Protection Law of the PRC (the "PIPL"), as applicable.
Recipients located outside the EEA, the UK, the Cayman Islands and the PRC, to which we may in some cases transfer personal information to provide the services of the HConnect App with which we have worked in the past, currently work with, or may in the future work with, include those located in the following countries: Singapore, USA, PRC and Hong Kong.
In such cases and if required by applicable law, we will take appropriate steps to ensure your personal information being transferred out of the EEA, the Cayman Islands and the PRC, as applicable, is adequately protected in compliance with the GDPR, the UK GDPR, the DPL and the PIPL. For further information on the specific safeguards that may be put in place or to obtain a copy of them, please contact us as detailed in the section below entitled 'Contact Us'.]
Security of Personal Information
To protect your personal information from unauthorized access and use, we limit access to your information to those of our personnel who need to know such information in order to conduct our services. Our personnel are required to maintain and protect the confidentiality of the personal information. We maintain physical, electronic, and procedural safeguards and other technical and organizational security measures to protect your personal information.
Depending on the type and model of your device you may be about to use biometric authentication technology to log into or access the HConnect App (for example, fingerprint authentication/Touch ID or facial recognition/Face ID or other technologies using biometric credentials stored on your device), instead of using a password. Activating such biometric authentication technology on your device for the HConnect App will allow any fingerprint, facial data or other biometric credentials stored on your device now or in future, to be used to access the HConnect App. You should not activate fingerprint authentication/Touch ID or facial recognition/Face ID or other biometric credentials on your device for the HConnect App if you have any other person’s biometric credentials stored on your device. We are not responsible for the fingerprint authentication/Touch ID or facial recognition/Face ID or other biometric sensor/authentication technology on your device and we do not warrant the quality, accuracy or performance of such technologies as a means for securing access to and using the HConnect App. Your biometric credentials are stored locally on your device and we also do not collect or store your biometric data. For more information on the processing of your biometric data, please refer to the privacy notice of your device manufacturer.
If You Choose Not to Provide Your Personal Information
We require your personal information for various purposes explained in the section above entitled `Legal Basis and Purposes of Processing your Personal Information'. Accordingly, if you do not provide personal information that is requested, we may not be able to carry out the necessary activities in relation to such purposes so therefore we may not be able to accept your HConnect App registration. If you revoke any consent you have given following our acceptance of such HConnect App registration, we will no longer be able to perform any consent-based processing activities and as a result we may be unable to provide certain services to you.
Local Laws Affecting this Privacy Notice
In case of any substantial conflicts between this Privacy Notice and any data protection laws applicable in your circumstances, such applicable laws shall prevail and this notice shall be deemed automatically amended to be in compliance with such applicable laws.
For California Residents
We do not and will not share information we collect about you with nonaffiliated third parties except with your consent or to service your account, or as otherwise permitted by law. We will limit our sharing of your personal information with our affiliates as required by California law.
For Vermont Residents
We do not and will not share information we collect about you with nonaffiliated third parties except with your consent or to service your account, or as otherwise permitted by law. We will not share information about your creditworthiness with affiliates or third parties unless you authorize us to do so, or as otherwise permitted under Vermont law.
For Natural Persons within the Territory of the PRC
We do not and will not (a) share your personal information with any third parties or (b) transfer your personal information abroad except with your consent or to service your account, or as otherwise permitted by law. In such cases, we will perform the security obligations to safeguard your personal information being shared or transferred abroad as required by the PIPL.
Contact Us
If you have any questions about this Privacy Notice or wish to discuss your data protection rights with us, please contact us via email on Inquiry@hconnectevent.com.