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PRIVACY POLICY

PRIVACY POLICY

This Privacy Policy was posted on 20 May 2016 and may be updated from time to time. Accordingly, you should check the date of this Privacy Policy and review any changes since the last version. If at any time you do not agree to the terms of this Privacy Policy, please do not use The Website.

1.INTRODUCTION

1.1.The Hula Limited ("HULA") is committed to protecting and respecting your privacy. HULA's website is located at www.theHula.com (the "Website") and is owned and operated by HULA.

1.2.This Privacy Policy, together with HULA's Terms of Use and HULA's Terms and Conditions for Sellers and Buyers, sets out the basis on which any personal data HULA collects from you, or that you provide to HULA, will be processed by HULA. You are strongly recommended to carefully read this (i) Privacy Policy, (ii) HULA's Terms of Use, and (iii) HULA's Terms and Conditions for Sellers and Buyers, to obtain an understanding of HULA's policy and practices with regard to the treatment of personal information and data provided by you on the Website. By visiting the Website, you are accepting and consenting to the practices described in this policy. This Privacy Policy is applicable to both registered and non-registered users, and the provisions herein may be updated, revised, varied and/or amended from time to time as HULA deems necessary.

1.3.HULA pledges to fully meet the requirements of the Personal Data (Privacy) Ordinance, Chapter 486 of the Laws of Hong Kong Special Administrative Region of the People's Republic of China ("Hong Kong") (the "Ordinance"). In doing so, HULA will ensure compliance by its staff to the strictest standards of security and confidentiality in respect of all personal information and data submitted by users via the Website and HULA will not release such information to anyone without the prior consent of the relevant user(s) of the Website (whether registered or not) except to the authorized persons listed under Clause 4 below.

1.4. If you have questions or concerns regarding this Privacy Policy, you should first contact HULA's Customer Service Representative at +852 2544 1511 or Hello@TheHula.com

2.PURPOSE OF COLLECTION OF PERSONAL DATA

2.1.In the course of using the Website, you may disclose or be asked to provide personal information and/or data. In order to have the benefit of and to enjoy various services offered by the Website, you will have to provide HULA with your personal information and/or data, as set out in Clause 3 below. Although you are not obliged to provide the information and/or data as requested by the Website, HULA will not be able to render certain services on the Website if you fail to provide the requested information and/or data. HULA collects information and data on the Website for various purposes, including but not limited to the following:

(i)To process your membership application to the Website;

(ii)For the daily operation of the services provided to you;

(iii)To verify your credit, payment and/or status in relation to the Website;

(iv)To enforce your contractual rights in relation to the Website;

(v)To process all of your payment instructions, credit services and/or direct debit services in relation to the Website;

(vi)To process orders placed by you;

(vii)To disclose your address and contact details to third party courier services to deliver the products to you;

(viii)To identify users who have posted materials, messages, photos, views or comments or such other information (collectively the Information) on the Website;

(ix)To identify which users have viewed the Information posted on the Website;

(x)To provide you with marketing and promotional materials for your enjoyment of benefits as a member of the Website (for further details, please refer to Clause 5 below);

(xi)To offer you tailored content including giving you more relevant search results and marketing and promotional materials;

(xii)To identify users who have enjoyed their benefits as members of the Website by receiving and using marketing and promotional materials;

(xiii)To provide you with a platform and forum for posting product requests and photos, and for sharing, buying and selling luxury products;

(xiv)To compile and analyse aggregate statistics about the users use of the Website and service usage by the users for HULA's internal use;

(xv)To facilitate HULA to use your personal data for purposes relating to the provision of services offered by HULA and marketing services, special events and/or promotions of HULA and/or its clients; and

(xvi)To be able to access your account on the Website.

2.2.HULA strives to only collect personal data which is necessary and adequate but not excessive in relation to the purposes set out herein above. If HULA requires the use of your personal data for a purpose other than those set out herein above, HULA may request your consent to the same.

2.3.If you are under the age of 18, you may not form legally binding contracts and as such cannot be a customer of HULA and/or a user of the services offered on the Website. Accordingly, the Website is not designed for persons who are minors and we do not knowingly collect information from minors. If we become aware that we inadvertently received personal information of a visitor who is a minor, we will delete the information from our records.

3.COLLECTION OF PERSONAL DATA

A.Personal Information

3.1.HULA may ask you for some or all of the personal information and/or data, and non-personal information and/or data (collectively Personal Data) that is not otherwise publicly available, such as:

(i)Name;

(ii)Date of birth;

(iii)Email address;

(iv)Correspondence address;

(v)Credit card or bank account information;

(vi)Payment, billing, or shipping information;

(vii)Telephone number;

(viii)Country of residence;

(ix)Occupation;

(x)Account username; and

(xi)Account password.

B.Non-Personal Information

3.2.HULA does not collect any personally identifiable information from you while you visit and browse the Website, save and except where such information is expressly requested from you. When you access the Website, HULA only records your visits and does not collect your Personal Data. The Website uses cookies to distinguish between users. This helps HULA to improve your experience when you browse the Website and it allows HULA to improve the Website. This includes recording the domain name server address and tracking the pages you visit; HULA stores such information in cookies within your computer. HULA also gathers and stores information, such as internet protocol (IP) addresses, browser type, referring/exit pages, operating system, date/time stamp, and clickstream data in log files. All these are done without you being aware that they are occurring.

3.3.HULA does not link the Personal Data automatically collected in the above manner to any personally identifiable information. HULA generally uses such automatically collected Personal Data to estimate the audience size of the Website, gauge the popularity of various parts of the Website, track your movements and number of entries in HULA's promotional activities and special events, measure your traffic patterns, and administer the Website. Such automatically collected Personal Data will not be disclosed save and except in accordance with Clause 4 below.

3.4.Occasionally, HULA may also collect additional Personal Data from you in connection with surveys and/or special offers. Only duly authorised staff of HULA will be permitted to access your Personal Data, and HULA shall not release such Personal Data to any third parties save and except for the circumstances listed out under Clause 4 below.

4.DISCLOSURE OR TRANSFER OF DATA

4.1.HULA agrees to take all practicable steps to keep all you Personal Data confidential and/or undisclosed, subject to the following.

4.2.HULA will only disclose and/or transfer your Personal Data to HULA's personnel and staff for the purpose of providing services to you, except that HULA may disclose and/or transfer such Personal Data to third parties under the following circumstances:

(i)If HULA sells or buys any business or assets, in which case HULA may disclose the Personal Data;

(ii)If HULA or substantially all of its assets are acquired by a third party, in which case Personal Data held by it about its customers will be among the transferred assets;

(iii)Where the information and/or data is disclosed and/or transferred to any third party suppliers or external service providers who have been duly authorised by HULA to use such information and/or data and who will facilitate the services on the Website, under a duty of confidentiality;

(iv)Where the information and/or data is disclosed and/or transferred to any agents, affiliates or associates of HULA who have been duly authorised by HULA to use such information and/or data;

(v)Where HULA needs to protect and defend its rights and property;

(vi)Where HULA needs to disclose to credit reference agencies, debt collection agencies, fraud detection and/or prevention agencies, relevant pubic authority or law enforcement agency;

(vii)where HULA reasonably believes it to be reasonably necessary to Investigate or prevent fraud or illegal conduct;

(viii)Where HULA considers necessary to do so in order to comply with the applicable laws and regulations, including without limitation compliance with a judicial proceeding, court order, or legal process served on the Website; and

(ix)Where HULA deems necessary in order to maintain and improve the services on the Websites.

4.3.You should take care when using social networking features of the Website since the information you choose to make available can be seen by other users in the selected group. HULA does not monitor the use of such features in the normal course of business although it reserves the right to do so at its discretion.

4.4.Personal Data collected via the Website is transferred, stored and processed in Hong Kong SAR. By using the Website, you are deemed to have agreed to, consented to and authorised HULA to disclose and/or transfer your Personal Data under the circumstances stated above, and to transfer information (including the Information) outside of your country.

5.SUBSCRIPTION TO NEWSLETTER, PROMOTIONAL MATERIALS, AND MARKETING MATERIALS

5.1.HULA may from time to time send to you newsletters, promotional materials and marketing materials based on the Personal Data that you have provided to HULA, if you have consented thereto, or the sending of such materials is permissible under applicable laws and regulations. HULA may use your Personal Data in direct marketing and HULA requires your consent (or an indication of no objection) for that purpose. In this connection, please note that:

(i)Your Personal Data held by HULA from time to time may be used by HULA and/or its authorised personnel or staff in direct marketing;

(ii)The following classes of services, products and subjects may be marketed:

(a)Special events hosted by HULA and/or its affiliates for you;

(b)Products and services offered by HULA and its advertisers (the names of such entities can be found in the relevant advertisements and/or promotional or marketing materials for the relevant products and services, as the case may be); or

(c)Donations and contributions for charitable and/or non-profit making purposes;

(iii)The above products, services and subjects may be provided or (in the case of donations and contributions) solicited by HULA and/or:

(a)Third party service providers providing the products, services and subjects posted in paragraph 4.1(ii)(b) above; and

(b)Charitable or non-profit marking organizations.

5.2.HULA has implemented suitable measures to allow its members to "opt-out" of receiving such materials. In this regard, you may, at any time, choose to sign up for or unsubscribe from receipt of such materials by logging into the registration or user account maintenance webpage, or by clicking on the automatic link appearing in each newsletter or message, or by emailing HULA's Customer Service Representative at: Hello@TheHula.com. Any such request should clearly state the details of Personal Data in respect of which the request is being made. Please note that after opting-out, you may still receive non-marketing messages, such as product updates and service notices as permitted under applicable local laws and regulations.

6.ACCESS

6.1.Under the Ordinance, every user is entitled to request access to or make amendments to his/her own Personal Data kept with HULA by logging into the registration or user account maintenance webpage, or by emailing HULA's Customer Service Representative at: Hello@TheHula.com. Any such request should also clearly state the details of Personal Data in respect of which the request is being made.

6.2.In the event that you wish to access or amend your Personal Data, HULA may request you to provide personal details in order to verify and confirm your identity. HULA shall respond to your requests within 40 days of your request and will endeavour to do so wherever possible.

7.UPLOADING MATERIAL TO WEBSITE

7.1.Whenever you upload material to the Website, or make contact with other users of the Website, you must comply with the content standards set out in HULA's Terms of Use. You warrant that any such contribution does comply with those standards, and you indemnify HULA for any breach of that warranty.

7.2.Any material you upload to the Website will be considered non-confidential and non-proprietary, and HULA has the right to use, copy, distribute and disclose to third parties any such material for any purpose. HULA also has the right to disclose your identity to any third party who is claiming that any material posted or uploaded by you to the Website constitutes a violation of their intellectual property rights, or of their right to privacy.

7.3.HULA will not be responsible or liable to any third party for the content or accuracy of any materials posted by you or any other user of the Website.

7.4.HULA has the right to remove any material or posting you make on the Website if, in HULA's opinion, such material does not comply with the content standards in HULA's Terms of Use.

8.LINKS TO OTHER WEBSITES, MEDIA PLATFORMS, APPLICATIONS

8.1.The Website may provide links to other websites, media platforms, or applications that are not owned or controlled by HULA. Personal Data from you may be collected on these other websites, media platforms, or applications when you visit them and make use of the services provided therein. You are reminded and acknowledge that when and where you decide to click on any advertisement or hyperlink on the Website which grants you access to other websites, media platforms, or applications, the protection of your Personal Data which is deemed to be private and confidential may be exposed in these other websites, media platforms, or applications.

8.2.This Privacy Policy is only applicable to the Website. You are reminded and acknowledge that this Privacy Policy grants no protection over your Personal Data that may be exposed on websites, media platforms, or applications other than the Website, and HULA is not responsible for the privacy practices of such other websites, media platforms, or applications. You are strongly recommended to refer to the privacy policy of such other websites, media platforms, or applications.

9.SECURITY

9.1.The security of your Personal Data is important to HULA. HULA will always strive to ensure that your Personal Data will be protected against unauthorised access. HULA has implemented appropriate electronic and managerial measures in order to safeguard, protect and secure your Personal Data.

9.2.All Personal Data provided by you is only accessible by the authorised personnel of HULA or its authorised third parties, and such personnel are instructed to observe the terms of this Privacy Policy when accessing such Personal Data. You may rest assured that your Personal Data will only be kept for as long as it is necessary to fulfill the purpose for which it is collected. Registered users should safeguard his/her unique Username and Password by keeping it secret and confidential, and should never share these details with anyone.

9.3.HULA uses third party payment gateway service providers to facilitate electronic transactions on the Website. Regarding sensitive information provided by you, such as credit card details for completing any electronic transactions, the web browser and third party payment gateway communicate such information using secure socket layer technology (SSL).

9.4.HULA follows generally accepted industry standards to protect the Personal Data submitted by you to the Website, both during transmission and once HULA receives it. However, no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, while HULA strives to protect Personal Data against unauthorised access, HULA does not guarantee its absolute security.

10.RETENTION OF PERSONAL DATA

10.1.Once HULA has obtained your Personal Data, it will be maintained securely in HULA's system. Subject to legal requirements, your Personal Data will be retained by HULA after deactivation of the relevant service until you request HULA in writing to erase your Personal Data from HULA's database or to terminate your membership of the Website.

11.CHANGES IN THIS PRIVACY POLICY

11.1.HULA reserves the right to update, revise, modify or amend this Privacy Policy in the following manner at any time as HULA deems necessary. You are strongly recommended to review this Privacy Policy frequently. If HULA decides to update, revise, modify or amend this Privacy Policy, HULA will post those changes to this webpage and/or other places HULA deems appropriate, so that you will always be in a position to ascertain what information HULA collects, how HULA uses it, and under what circumstances, if any, HULA discloses it.

11.2.If HULA makes material changes to this Privacy Policy, HULA will notify you on this webpage, by email, or by means of a notice on the home page of HULA.

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