Hoppy 私隱政策

Interpretation and Definitions

Interpretation

The words whose initial letters are capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

Account means a unique account created for You to access our Service or parts of our Service.

Affiliate means an entity that controls, is controlled by, or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

Application refers to Hoppy, the software program provided by the Company.

Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to 10botics LTD, Units 01 and 02, 12/F, THE 80|20, No. 161 Wai Yip Street, Kwun Tong.

Country refers to: Hong Kong SAR China

Device means any device that can access the Service such as a computer, a cell phone or a digital tablet.

Personal Data is any information that relates to an identified or identifiable individual.

Service refers to the Application.

Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.

Transaction Data refers to data related to purchases made within the Service, which the Company receives from the platform providers (Apple or Google), including the item purchased, transaction amount, date, and a transaction identifier.

Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Email address
• Usage Data

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device's unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit Our Service or when You access the Service by or through a mobile device.

Information Collected while Using the Application

While using Our Application, in order to provide features of Our Application, We may collect, with Your prior permission:

• Pictures and other information from your Device's camera and photo library

We use this information to provide features of Our Service, to improve and customize Our Service. The information may be uploaded to the Company's servers and/or a Service Provider's server or it may be simply stored on Your device.

You can enable or disable access to this information at any time, through Your Device settings.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service, including to monitor the usage of our Service.
• To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
• To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
• To provide You with news, special offers, and general information about other goods, services and events which We offer that are similar to those that you have already purchased or inquired about unless You have opted not to receive such information.
• To manage Your requests: To attend and manage Your requests to Us.
• For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
• For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

We may share Your personal information in the following situations:

• With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.
• For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
• With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
• With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
• With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
• With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Email Communications

The Company uses Your Personal Data to contact You with essential service-related and security updates, as outlined in the "To contact You" purpose under Use of Your Personal Data.

Promotional and Marketing Communications

We also use Your Personal Data, including your Email address, to provide You with news, special offers, and general information about other goods, services, and events which We offer or which are offered by Our business partners that are similar to those that You have already purchased or inquired about, or which We believe may be of interest to You.

Opt-In and Opt-Out

You have the right to opt-out of receiving any, or all, of these promotional communications from Us by following the unsubscribe link or instructions provided in any email We send, or by contacting Us directly. Please note that even if You opt-out of receiving marketing emails, We reserve the right to send You non-marketing administrative emails, such as those concerning Your Account, data security, or your use of the Service.

Transaction Data

Collection of Payment Information

The Service offers paid products and/or services solely through Apple Store In-App Payments and Google Play In-App Payments.

When You elect to make a purchase through the Service, Your transaction is processed directly by the respective platform (Apple or Google). We do not collect, process, or store Your financial account information, such as credit card numbers, bank account details, or payment card security codes. This sensitive information is provided by You directly to, and is managed solely by, the platform's payment processor.

Data We Receive

The Company receives certain limited data related to Your transactions from Apple or Google to fulfill Your purchase and manage Our accounts. This Transaction Data may include, but is not limited to:

• The item or service purchased;
• The purchase price;
• The date and time of the transaction;
• A transaction identifier; and
• A limited portion of Your account information (e.g., Your country or zip code) necessary for tax or regulatory compliance.

Use of Transaction Data

We use this Transaction Data for the following purposes:

• For the performance of a contract: To process and fulfill the purchases You make within the Application.
• To manage Your Account: To verify Your entitlement to the purchased features, products, or services, and to maintain a record of Your purchase history.
• Compliance and Security: To comply with legal and regulatory obligations, including tax requirements, and for security, anti-fraud, and anti-cheating purposes.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ from those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.

Our Service may give You the ability to delete certain information about You from within the Service.

You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us.

Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

Your Privacy Rights

Depending on Your jurisdiction, You may have specific rights regarding Our collection and use of Your Personal Data. We are committed to honoring these rights.

General Data Protection Regulation (GDPR) Privacy

If You are a resident of the European Economic Area (EEA), the United Kingdom (UK), or Switzerland, You have certain data protection rights, and We aim to take reasonable steps to allow You to correct, amend, delete, or limit the use of Your Personal Data.

Your rights, in certain circumstances, include:

• The Right to Access - The right to request copies of Your Personal Data We hold.
• The Right to Rectification - The right to request that We correct any information You believe is inaccurate or complete information You believe is incomplete.
• The Right to Erasure (Right to be Forgotten) - The right to request that We erase Your Personal Data, under certain conditions.
• The Right to Restrict Processing - The right to request that We restrict the processing of Your Personal Data, under certain conditions.
• The Right to Object to Processing - The right to object to Our processing of Your Personal Data, under certain conditions.
• The Right to Data Portability - The right to request that We transfer the data that We have collected to another organization, or directly to You, under certain conditions.
• The Right to Withdraw Consent - Where Our processing of Your Personal Data is based on Your consent, You have the right to withdraw this consent at any time.

If You wish to exercise any of these rights, please contact Us using the "Contact Us" section at the end of this Privacy Policy.

California Privacy Rights (CCPA/CPRA)

If You are a California resident, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), grants You specific rights regarding Your Personal Information.

Right to Know and Access

You have the right to request that We disclose the following information to You, generally over the preceding 12 months:

• The categories of Personal Information We have collected about You;
• The categories of sources from which the Personal Information is collected;
• The business or commercial purpose for collecting, selling, or sharing that Personal Information;
• The categories of third parties to whom We disclose Personal Information; and
• The specific pieces of Personal Information We have collected about You.

Right to Delete

You have the right to request the deletion of Your Personal Information that We collected from You, subject to certain exceptions. (This is generally covered by your existing "Delete Your Personal Data" section.)

Right to Correct

You have the right to request the correction of inaccurate Personal Information that We maintain about You.

Right to Opt-Out of Sale or Sharing

• The Company does not sell Personal Data for monetary consideration as the term "sell" is traditionally understood.
• However, We may share Personal Data with Service Providers to provide cross-context behavioral advertising, which may be considered "sharing" or a "sale" under California law.
• You have the right to direct Us to stop "selling" or "sharing" Your Personal Information at any time (the "Right to Opt-Out").

Right to Limit Sensitive Personal Information (SPI) Use

The Company collects certain Personal Data (such as precise geolocation data in Usage Data) that may be considered Sensitive Personal Information. We only use this SPI as necessary to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services. We do not use Your SPI for purposes that require a Right to Limit under CPRA.

Non-Discrimination

We will not discriminate against You for exercising any of Your CCPA/CPRA rights.

Exercising Your CCPA/CPRA Rights

To exercise the rights described above, please submit a verifiable Consumer Request to Us by:

• Email: hi@hoppy.day

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially reasonable means to protect Your Personal Data, We cannot guarantee its absolute security.

Children's Privacy

Our Service is designed to be used by children, and We collect Personal Data from children under the age of 13. This practice requires us to comply with the Children's Online Privacy Protection Act (COPPA) in the United States and other similar international laws.

Parental Consent and Verification

In compliance with COPPA and other applicable laws:

1. We require verifiable parental consent before collecting, using, or disclosing any Personal Data from a child under the age of 13.
2. The Personal Data We collect from children is limited to what is reasonably necessary for the child to use the Service's features.
3. We will provide parents or guardians with direct notice of the information We collect from their children, how We use it, and how it may be disclosed.

Parental Rights Under COPPA

As a parent or guardian, You have the right to:

• Review the Personal Data We have collected from Your child.
• Revoke Your consent for the further collection, use, or disclosure of Your child's Personal Data.
• Request the deletion of Your child's Personal Data.
• Refuse to permit the Company to collect any further Personal Data from Your child, while still allowing Your child to access the portions of the Service that do not require such information.

To exercise any of these rights concerning your child's account, please contact Us using the "Contact Us" details provided below. We will take steps to verify your identity as the child's parent or guardian before fulfilling any request.

Data Collection and Use

The information collected from children will be the same types of data collected from other users (e.g., Email address, Usage Data, Pictures and other information from your Device's camera and photo library), and it will be used only for the purposes disclosed in the "Use of Your Personal Data" section, which are necessary to operate and improve the Service.

Global Parental Consent

If We need to rely on consent as a legal basis for processing Your child's information and Your country (outside of the US, such as those subject to GDPR) requires consent from a parent for users under a certain age, We may require Your parent's consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

California Online Privacy Protection Act (CalOPPA) Notice

In compliance with CalOPPA, We agree to the following:

"Do Not Track" Signals

We do not support Do Not Track ("DNT"). Do Not Track is a preference You can set in Your web browser to inform websites that You do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of Your web browser.

Policy Updates

We will post any changes to Our Privacy Policy on this page and update the "Last updated" date at the top of the Privacy Policy.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

By email: hi@hoppy.day

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