As a customer-centric platform, Hekka and our affiliates respect the privacy of our users and take responsibility for protecting the information provided to us while using our services. By this Privacy Policy (referred to as “Policy”), we intend to inform you:

A. This Policy does not apply to services provided by other third parties, nor to products and services with a separate privacy policy provided by us.

B. This Policy explains the data protection practices adopted by us and should be read in conjunction with our Terms and Conditions (“T&Cs”). Please read and understand this Policy carefully before using our services. You agree to be bound by these terms and conditions when using our services. If you have any inquiries or suggestions regarding the Policy, you are free to contact us through any means made available to you.

C. This Policy applies to individuals who use our websites, apps, events, and other services. Users agree to be bound by the terms and conditions of this Policy and the T&Cs.

D. We reserve the right, at our discretion, to amend this Policy over time and modify content within the services. The updated version of the Policy will be accessible on Hekka, and you are requested to review it. If you continue to use the services after the changes are posted, it is deemed that you agree with and acknowledge the modifications or revisions. The new policy shall apply to your continued use of the services. Otherwise, if you do not agree to the terms of the Policy or any future updated version of the Policy, then you must not access or use any of our services.

E. In addition, we may disclose or provide you with additional information about our personal information handling practices for specific parts of our services in real-time. Such notice may supplement this Policy or provide you with other options regarding how we process your personal information.

This Policy will help you understand the following:

1. How we collect your information
2. How we use information
3. Cookies and other similar data collection technologies
4. How the information is shared
5. How we protect your information
6. How you manage your own information
7. Rights of users to request access to and update information
8. How we protect the information of underage users
9. How we operate and transfer data as part of our global services
10. Data retention
11. How to contact us

1. How we collect your information

To provide services, we must process information about you. Please note that we collect your information only for lawful purposes and necessary conditions. You have the option not to provide any data or info sought to be collected, and in such cases, you may not consent to this Policy. Correspondingly, we have the right not to provide the services as far as you are concerned. We collect information in the following ways:

1.1 Information and content you provide

• (a) We collect profiles, messages, and other information you provide when you use our services, including when registering for an account, creating or sharing content, or communicating with other users. Such behavior may include further information about the content you provided, such as metadata, photo location, or the date a file was created. With your consent, we will also collect related information you choose to upload, sync, or import from your device to our services.

1.2 Information and content we collect with your consent

• (a) Your usage. We collect information generated as you use our services as well as information from third parties (like when you access our services through a social media account), including:

  • your mobile phone number and password;
  • the types of content you view or engage with;
  • the features you use;
  • the actions you take;
  • the time, frequency, and duration of your activities;
  • your feedback, the access logs, photos, and videos you viewed while using our services.

• (b) Device information. We collect and record information regarding and from the devices you use according to access you have granted when installing and using our services. We will strictly abide by the rules and regulations for data collection to respect and protect your rights and interests. Information we obtain from these devices may include:

  • (i) Device attributes information such as the operating system, hardware, and software versions, battery level, signal strength, available storage space, browser type, app and file names and types, and plugins.
  • (ii) Device operations: information about operations and behaviors performed on the devices, such as whether a window is foregrounded or backgrounded or mouse movements (which can help distinguish humans from bots).
  • (iii) Device identifiers: device IDs obtained from apps or accounts you use.
  • (iv) Device signals: Bluetooth signals, information about nearby Wi-Fi access points, beacons, or cell towers.
  • (v) Data from device settings: information you allowed us to receive through device settings you activated, such as access to your GPS location, camera, or photos.
  • (vi) Network and connections: information such as the name of your mobile operator or ISP, language, time zone, mobile phone number, IP address, connection speed, and, in some cases, information about other devices nearby or on your network.
  • (vii) Cookie data: data from cookies stored on your device, including cookie IDs and settings.

1.3 Information our partners provide

You can use products or services through links on your account provided by our affiliates, advertisers and app developers. By using the above Services, you grant us permission to receive, gather and analyze personal and transactional info from our affiliates, advertisers and app developers pursuant to your express consent provided to these entities while using their services. Advertisers, app developers, and publishers (like Adjust, Facebook, Google, etc.) can send us information via tools they use, including but not limited to APIs and SDKs. Your use of our services is subject to the privacy policy of these entities and we request you to read and understand the privacy policy of these service providers before using our services. These partners provide information about your activities while you use our services, including info about websites you visit, purchases you make, advertisements you see, and other relevant data, no matter whether you have an account for our services or not. We also receive info about your online and offline actions from third parties who have the rights to provide us with your information so far as you may have provided consent in this regard.

We require each of these partners to have your consent and lawful right to collect, use and share your data before providing any data to us.

2. How we use information

We use the information to provide and support the services, and the data will be processed only for the purposes set out in this Policy. Please refer to the following on how we use this information:

• (a) To provide and optimize our Services We use the information made available to us to deliver, develop, test, and improve our services, including but without limitation to developing research, testing, and troubleshooting new services and features.

• (b) To display and promote products or Services We will display and push the information such as ads according to your browsing and search record, device information, search preference, behaviors, habits, and location to provide personalized browsing and transaction services better.

• (c) To enhance safety, integrity, and security We process the information we obtained to verify accounts and activities, combat harmful conduct, and detect and prevent spam and other bad experiences from maintaining our services' integrity and enhancing your safety and data security.

• (d) To communicate with you We use the information we obtained to send you marketing messages, communicate with you about our services, and allow you to understand our policies and terms. We also use your information to respond when you contact us effectively.

• (e) To send marketing messages We only use the precise information you provide, such as user name, phone number, e-mail, and others, lawfully, as stated at the time of collection, and it may be used in the following ways:

  • To send you regular e-mails;
  • To send you necessary and updated information related to any relevant order;
  • To send you updated information on relevant products or services, Hekka news, and other pertinent messages;
  • To send you periodic SMS messages. We respect and protect your privacy. If you no longer wish to receive e-mails from Hekka, you can easily unsubscribe at the bottom of the e-mail.

• (f) Others Suppose we use the information obtained for other purposes not listed in this Policy. We will promptly inform you and seek your prior permission.

3. Cookies and other data-collection technologies

3.1 Cookies

We will recommend meaningful connections to ensure proper service operations and provide you with a personalized and better user experience. We will collect information from your mobile devices and store information such as your preference in data folders through the usage of Cookies. In essence, Cookies allow us to serve you better and more efficiently. You can control how and whether Cookies are utilized by changing the options on your device or using functionalities available to you. However, blocking cookies related to our services may disable certain features of our services and may otherwise hinder a seamless and excellent user experience.

3.2 Other Similar Technologies

In addition to Cookies, we may use other similar data-collection technologies such as web beacons and pixel tags. For example, when you click the link sent by us through email, we can track this click and your preferences to optimize our customer service experience. A web beacon is usually a transparent image that is embedded within a website or email. With a pixel tag, we can know whether the mail has been opened in the webmail. If you do not wish to be tracked through the above means, you can unsubscribe from our mail list anytime.

4. How the information is shared

With your acceptance of this Policy, we will share or allow third parties to collect your information from our services under the following circumstances and shall also contractually obligate such parties not to share your information with any other party.

4.1 In response to a legal request

We may share your information according to Laws and Regulations, dispute resolution and litigation purposes or legal requests from administrative agencies and judiciary institutions. We will share your information when necessary to achieve the following actions: to detect, prevent and address fraud, violations of our terms or policies, or other harmful or illegal activities; to protect ourselves (our rights, property or services), you or others (individuals involved in investigations or regulatory inquiries); or to prevent death or imminent harm.

4.2 Sharing with affiliates

We may share your information with our affiliates to provide you with better services (recommending information according to your interest) or to protect the assets of other users and the public.

4.3 Change of ownership

We may transfer your information to the new owner, controller, or acquirer when a merger, acquisition, or bankruptcy occurs.

4.4 Sharing with third-party Partners

We work with third-party partners who help us to provide and improve our services to offer you high-quality services. The following are the types of third parties we share information with:

• (a) Partners who use our analytics services We provide aggregated statistics and insights that help to understand how users engage with our services.

• (b) Measurement agencies We share information about you with agencies that aggregate it to provide analytics and measurement reports to our partners.

• (c) Other partners such as vendors and service providers We provide information and content to vendors and service providers, such as those who provide technical services, analyze how our services are used, offer customer service, facilitate payments, conduct surveys, etc.

5. How we protect your information

We endeavor to protect you from unauthorized access or alteration, disclosure, or destruction of your information through responsible and feasible security measures that are universal within the industry. We have implemented reasonable security practices and documented information security policies comprising all relevant security control measures commensurate with the protection of the information assets (including your data). However, despite our commercially reasonable efforts to safeguard your information, it is difficult and impossible for any entity to promise complete security to your data. If you deem your account or information no longer secure, please notify us (per section 11 below) immediately, and we will take necessary actions as expeditiously as possible.

You must be cautious before uploading text, images, and others when engaging in our services, since your voluntarily or publicly sharing of information may involve personal data about you or others.

6. How you manage your own information

You can access and manage your information via the following means: Unless laws and regulations require otherwise, you reserve the right to access, rectify, add and erase your personal information. After deleting information on Hekka, the corresponding data will be removed or anonymized with the backup system update if unable to be removed immediately. You can also modify the scope of your authorization. We will no longer process your information upon your withdrawn access. Please note that your decision does not affect the prior information displayed and processed. Please be aware that functions of our services may require specific data to operate, and thus modifying your scope of authorization may lead to the inability to use our services.

7. Rights of users to request access to and update information

You may access your personal information by sending a request to our Grievance Officer. You may also seek to correct your inaccurate or deficient personal data or delete such information. You may withdraw your consent to provide any or all information or decline to give the same as may be required from time to time. Whereas you choose to do so, your access to the services may be limited, or we might not be able to provide the services to you.

8. How we protect the information of underage users

Our services are not directed at children under the age of 18. If we find that personal information has been collected from people under 18, we will delete that information and terminate that person's account. If the law of the user's residential area has special provisions for users over 18 to use the platform and for the platform to collect the personal information of users over 18, we will comply with the local law. Be sure to get in touch with us immediately if you think we collect information about children under 18 or that is prohibited by local law.

9. How we operate and transfer data as part of our global services

As part of our international operations, we transfer, transmit, store or process your information globally to our affiliates or business partners under the guidance of local laws and regulations per this Policy. You acknowledge and agree that, to the extent permissible under applicable Laws and Regulations, we may transfer or disclose your information to any other entities within or outside your country of residence for providing services to you. In such cases, we place contractual obligations on the recipients to ensure that your information is not disclosed, shared, or transferred further to any other parties. Moreover, we contractually oblige the recipients to take protective measures of the same level as that adhered to your data by us under the reasonable security practices set out in section 5.

10. Data retention

We generally retain data for as long as we need it for the performance of our services and to comply with our legal obligations. We may keep it to evidence our compliance with applicable laws and regulations; an outstanding issue, claim, or dispute requires us to keep the relevant information until it is resolved; or the information must be kept for our legitimate business interests. However, our systems are designed to carry out data deletion inquiries and processes; we cannot promise that all data will be deleted within a specific time frame due to technical constraints and legitimate reasons.

11. How to contact us

If you have any questions or grievances in this Policy relating to processing your information, or you would like to exercise any of your rights, please do not hesitate to reach out to our Grievance Officer, whose contact details are below. We endeavor to redress all grievances received on an expeditious basis.

You can contact our Grievance Officer via online customer service or email us at customerservices@hekka.com.