Personal Data (Privacy) Policy Statement (“Privacy Policy”)

Pet-a-hood Limited and/or its subsidiary(ies) and/or affiliates (hereinafter collectively referred to as the “Company”; if the context requires or permits, “Company” may refer to any one of Pet-a-hood Limited and/or its subsidiary(ies) and/or affiliate(s)) pledges to meet fully with the requirements of the Personal Data (Privacy) Ordinance, Chapter 486 of the Laws of Hong Kong.

The Company 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 Petahood.com, its sub-domains, any other websites, media platforms or applications including Petahood mobile applications and/or mobile webs operated/developed by the Company (hereinafter singly or collectively referred to as the "Sites" ) and the Company will not release such information to anyone without the prior consent of the relevant user(s) of the Sites (whether registered or not) (“User(s)”) except to the authorized persons listed under Clause 3 below titled “Disclosure or Transfer of Data”.

Users are recommended to read this Privacy Policy carefully to have an understanding of the Company’s policy and practices with regard to the treatment of personal information and data provided by the Users on the Sites. 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 the Company deems necessary.

If Users have questions or concerns regarding this Privacy Policy, they should first contact us, our contact details are set out under Clause 13 entitled “Contact” below.

1.Purpose of Collection of Personal Data

In the course of using the Sites, Users may disclose or be asked to provide personal information and/or data. In order to have the benefit of and enjoy various services offered by the Sites, it may be necessary for Users to provide the Company with their personal information and/or data. Although Users are not obliged to provide the information and/or data as requested on the Sites, the Company will not be able to render certain services on the Sites in the event that Users fail to do so.

The Company’s purposes for collection of information and data on the Sites include but not limited to the following:

(a) for the daily operation of the services provided to Users; (b) to identify Users who have posted advertisements, materials, messages, photos, views or comments or such other information (collectively “Information”) on the Sites; (c) to identify Users who have viewed the Information posted on the Sites; (d) to provide Users with the services of the Company; (e) to verify the identity of Users who have used services provided by the Sites; (f) to handle and follow up service calls, enquiries, requests and complaints; (g) to provide Users with event information, marketing and promotional materials (for further details, please refer to paragraph 4 headed “Subscription of Newsletter/Promotional Materials/Marketing Materials” below); (h) to identify Users who have enjoyed their benefits as members of the Sites by receiving and using marketing and promotional materials; (i) to provide Users with platforms and forum for posting photos, sharing and discussing their insights in respect of services or products related to pet; (j) to allow members of the Sites to enjoy their benefits as members by enrolling for special events hosted by the Company; (k) to contact Users regarding administrative notices and communications relevant to the Users’ account maintained with the Company (if any), and/or regarding notifications and confirmation in connection with their uses of any of the services offered by the Company via the Sites; (l) to design, develop and improve products and services provided to Users; (m) to compile and analyze aggregate statistics about the Users’ use of the Sites and service usage by the Users for the Company’s internal use; (n) to facilitate the Company to use the Users’ personal data for purposes relating to the provision of services offered by the Company and marketing services, special events and/or promotions of the Company and/or its clients; (o) to enforce the Terms and Conditions and other rights of the Company; (p) to comply with legal obligations and as otherwise agreed by Users as required or permitted by applicable law; (q) for any other purposes relating to the purposes stated above.

The Company will never knowingly collect Personal Information from individuals under the age of thirteen (13) without first obtaining verifiable parental consent. If the User is under the age of 13, he/she should not provide information to the Company. If the Company becomes aware that a person under 13 has provided personal information to the Company without verifiable parental consent, the Company will delete that information as quickly as possible. If any User believes that the Company might have any information from or about a child under 13, please contact the Company at support@petahood.com

The Company strives to only collect personal data which is necessary and adequate but not excessive in relation to the purposes set out hereinabove.

If the Company requires the use of Users’ personal data for a purpose other than those set out hereinabove, the Company may request the Users’ prescribed consent to the same. If User is a minor, the prescribed consent should be given by his/her parent or guardian.

2.Collection of Personal Data

The Company may collect personal information and/or data about a User such as his/her name, log-in ID and password, address, email address, phone number, age, sex, date of birth, country of residence, nationality, education level and work experience that is/are not otherwise publicly available. Occasionally, the Company may also collect additional personal information and/or data from a User in connection with contests, surveys, special offers or reviews.

The Company automatically collects some information from Users’ computers or devices when Users visit the Sites. For instance, the Company will collect Users’ IP address, web browser software and referring websites. The Company may also collect information about Users’ activities conducted via the Sites, such as content viewed, pages visited, and searches and/or services used.

When Users use the Sites on a device, the Company will additionally collect information about the Users’ location if Users have set their devices to send such information to the Sites via the privacy settings on their devices, or if Users have uploaded photos tagged with information regarding their location. The Company may use the information regarding the location collected from the Users’ devices or photos to enhance their use of the Sites by providing them with relevant content.

Only duly authorized staff of the Company will be permitted to access the Users’ personal information and data, and the Company shall not release such personal information and data to any third parties save and except for the circumstances listed out under the Clause 3 entitled “Disclosure or Transfer of Data” below.

3.Disclosure or Transfer of Data

The Company agrees to take all practicable steps to keep all personal information and data of Users confidential and/or undisclosed, subject to the following.

Generally speaking, the Company will only disclose and/or transfer Users’ personal information and/or data to the Company’s personnel and staff for the purposes as set out in Clause titled “Purpose of Collection of Personal Data” above. However, the Company may disclose and/or transfer such information and/or data to third parties under the following circumstances:

(a) where the information and/or data is disclosed and/or transferred to any third party suppliers or external service providers who have been duly authorized by the Company to use such information and/or data and who will facilitate the services on the Sites, who are under a duty of confidentiality; (b) where the information and/or data is disclosed and/or transferred to any agents or associates of the Company who have been duly authorized by the Company to use such information and/or data; (c) where permitted under the “Terms and Conditions”; (d) where the Company needs to protect and defend its rights and property; (e) where the Company 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 Sites; and (f) where the Company deems necessary in order to deliver the services that the Company offer and to maintain and improve the services on the Sites. (g) where the Company may disclose or transfer Users’ information to a third party if the Company sells, transfers, divests, or discloses all or a portion of its business or assets to another company in connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction, or proceeding. Such third party will have to comply with the appropriate confidentiality and security measures.

Personal data collected via the Sites may be transferred, stored and processed in any country in which the Company operate. By using the Sites, Users are deemed to have agreed to, consented to and authorized the Company to disclose and/or transfer their personal information and data under the circumstances stated above, as well as to any transfer of information (including the Information) outside of the Users’ country.

4.Subscription of Newsletter/Promotional Materials/Marketing Materials

The Company may from time to time send to members and Users of the Sites, by way of emails and/or short message service (SMS) notifications, newsletters, marketing and promotional materials and information regarding the Company or its third-party advertisers’ products, services and the like based on the personal information and data that the Users have provided to the Company. The Company may use Users’ data in direct marketing and the Company requires the Users’ consent (which includes an indication of no objection) for that purpose. In this connection, please note that:

(a) the name, log-in ID and password, contact details, age, sex, date of birth, country of residence, nationality, education level and work experience of Users held by the Company from time to time may be used by the Company and/or its authorised personnel or staff in direct marketing;

(b) the following classes of services, products and subjects may be marketed: • pet supplies, pet related products and services; • special events hosted by the Company for members and Users, including but not limited to courses, workshops, and competitions; • reward, loyalty or privileges programmes and related products and services; • special offers including coupons, discounts, group purchase offers and promotional campaigns; • products and services offered by the Company 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); • donations and contributions for charitable and/or non-profit making purposes;

(c) The above products, services and subjects may be provided or (in the case of donations and contributions) solicited by the Company and/or: • third party service providers providing the products, services and subjects listed in paragraph (b) above; and • charitable or non-profit marking organizations;

(d) in addition to marketing the above services, products and subject itself, the Company also intends to provide the data described in paragraph (a) above to all or any of the persons described in paragraph (c) above for use by them in marketing those services, products and subjects, and the Company requires the Users’ written consent (which includes an indication of no objection) for that purpose;

(e) the Company may receive money or other property in return for providing the data to the other persons in paragraph (d) above and, when requesting the Users’ written consent as described in paragraph (d) above, the Company will inform the Users if the Company receives any money or other property in return for providing the data to the other persons.

Suitable measures are implemented to make available to such members the options to “opt-out” of receiving such materials. In this regard, Users may choose to sign up or unsubscribe for such materials by logging into the membership registration or user account maintenance webpage, or clicking on the automatic link appearing in each newsletter/message, or contact the Company, our contact details are set out under Clause 13 entitled “Contact” below.

Such “opt-out” as mentioned above will not affect your ability to receive from the Company fundamental notifications and correspondence (viz. not of marketing or promotional nature) in relation to your use of the services provided by the Company.

5.Cookies and Log Files

The Company does not collect any personally identifiable information from any Users whilst they visit and browse the Sites, save and except where such information of the Users is expressly requested. When Users access the Sites, the Company records their visits only and do not collect their personal information or data. The Sites’ server software will also record the domain name server address and track the pages the Users visit and store such information in “Cookies”, and gather and store information like 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 the Users being aware that they are occurring.

The Company may use “Cookies” to improve the Sites’ internet service and enhance User’s online experience. Cookies are small file that are automatically stored on User’s web browser in User’s computer that can be retrieved by the Sites. Cookies may be used to remember the User’s preferences when the User visits the Sites and enable the Company to tailor the Sites to the User’s needs. The information collected by Cookies is anonymous visitor’s personalized settings information and contains no name or address information or any information that will enable anyone to contact the User via telephone, email or any other means. The Company will not collect any personal data from the Users when the cookies are being used. The User can disable cookies by changing the settings of the User’s web browser. Cookies cannot be used to run programs or deliver viruses to the User’s computer.

The Company does not link the information and data automatically collected in the above manner to any personally identifiable information. The Company generally uses such automatically collected information and data to estimate the audience size of the Sites, gauge the popularity of various parts of the Sites, track Users’ movements and number of entries in the Company’s promotional activities and special events, measure Users’ traffic patterns and administer the Sites. Such automatically collected information and data will not be disclosed save and except in accordance with the Clause 3 entitled “Disclosure or Transfer of Data”.

6.Google Analytics

Google Analytics Advertising Features (“Features”) are implemented on the Site. The Features which the Company has implemented are based on Google Analytics Demographics and Interest Reporting.

Google Analytics is a web analysis service provided by Google which utilizes the data collected to track and examine the use of the Channels, to prepare reports on the Users’ activities and share them with other Google services. Google may use the data collected to contextualize and personalize the marketing materials of its own advertising network. For details on how Google uses data when Users use the Channels, please visit https://www.google.com/policies/privacy/partners.

Users can opt out of Google Analytics here.

7.Links to Other Websites / Media Platforms / Applications

The Sites may provide links to other websites / media platforms / applications which are not owned or controlled by the Company. Personal information and data from Users may be collected on these other websites / media platforms / applications when Users visit such websites / media platforms / applications and make use of the services provided therein. Where and when Users decide to click on any advertisement or hyperlink on the Sites which grants Users access to another website / media platforms / applications, the protection of Users’ personal information and data which are deemed to be private and confidential may be exposed in these other websites / media platforms / applications.

Non-registered Users who gain access to the Sites via their accounts in online social networking tools (including but not limited to Facebook or Google) are deemed to have consented to the terms of this Privacy Policy, and such Users’ personal data which they have provided to those networking tools may be obtained by the Company and be used by the Company and its authorized persons in and outside of the User’s country for the purpose of providing services and marketing materials to the Users.

If a User logins to any Sites with his/her Facebook account, the Company will collect and store the User’s personal profile and information, such as User’s name, profile picture, gender, friend list, which the User has chosen to make available to the Sites. If a User logins to any Sites with his/her Google account, the Company will collect such User’s email address associated with his/her Google account and store such email address in the system of the Company as an unique identifier which will be combined with other personal data of such User collected by the Company when he/she uses services provided by the Company. These Users are deemed to have consented to the Company and its authorized personnel’s access and use of their personal data so obtained for the purposes as stipulated under Clause 1 above and/or share their personal data pursuant to Clause 3 above, subject to the other provisions of the Privacy Policy.

This Privacy Policy is only applicable to the Sites. Users are reminded that this Privacy Policy grants no protection to Users’ personal information and data that may be exposed on websites / media platforms / applications other than the Sites, and the Company is not responsible for the privacy practices of such other websites / media platforms / applications. Users are strongly recommended to refer to the privacy policy of such other websites / media platforms / applications. For the avoidance of doubt, the Company assumes no responsibility or liability for Users’ use of such other websites / media platforms / applications.

8.Security

The security of Users’ personal information and data is important to the Company. The Company will always strive to ensure that Users’ personal information and data will be protected against unauthorized access. The Company has implemented appropriate electronic and managerial measures in order to safeguard, protect and secure Users’ personal information and data.

All personal information and data provided by Users are only accessible by the authorized personnel of the Company or its authorized third parties, and such personnel shall be instructed to observe the terms of this Privacy Policy when accessing such personal information and data. Users may rest assured that their personal information and data will only be kept for as long as is necessary to fulfill the purpose for which it is collected, unless Users request the Company to cease to hold the same or terminate his/her membership account with the Company. Such request may render the Company unable to further provide its services, information and/or promotional materials for your benefit in the future.

Registered Users should safeguard his/her unique Username and Password by keeping it secret and confidential and never share these details with anyone.

The Company follows generally accepted industry standards to protect the personal information and data submitted by Users to the Sites, both during transmission and once the Company receives it. However, no method of transmission over the Internet, or method of electronic storage, is totally secure. The Company cannot guarantee its absolute security. We shall not accept any liabilities therefor.

9.Access to or request for correction of data

The Company would like to help Users keep his/her personal information accurate and up-to-date. To view or edit personal information that has been stored at the Sites, please visit the “Login” section of Petahood.com.

Any User may make a data access request or a data correction request at any time by contacting the Company, our contact details are set out under Clause 14 entitled “Contact” below.

In the event that a User wishes to access or amend his/her personal information and data, the Company may request him/her to provide personal details in order to verify and confirm his/her identity. HKID card number or passport number or business registration certificate number cannot be amended unless such data is proved to be inaccurate.

If Users do make a data access request and if the Company deems the same as appropriate, only a copy of his/her personal data would be provided.

10.Retention of Personal Data

Once the Company has obtained a User’s personal information and/or data, it will be maintained securely in the Company’s system. Subject to legal requirements, the personal information and/or data of Users will be retained by the Company until the User requests the Company in writing to erase his/her own personal information and/or data from the Company's database or to terminate his/her membership of the Sites.

11.Rights Applicable to EU Users

If you are a visitor from the European Economic Area (EEA), your rights under General Data Protection Regulation (GDPR) in relation to your personal data are subject to the protections offered by EU law.

12.Modifications

The Company reserves the right to update, revise, modify or amend this Privacy Policy in the following manner at any time as the Company deems necessary and Users are strongly recommended to review this Privacy Policy frequently. If the Company decides to update, revise, modify or amend this Privacy Policy, the Company will post those changes to this webpage and/or other places the Company deems appropriate so that Users would be aware of what information the Company collects, how the Company uses it, and under what circumstances, if any, the Company discloses it.

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

13.Inconsistency

This Privacy Policy has been drafted, and shall be construed, in the English language. Any translation of the Privacy Policy is solely for reference only. In the event of inconsistency between the English language version and a translated version, the English language version of the Privacy Policy shall always prevail.

14.Contact

Please contact us at support@petahood.com if there is any query.