Last Revised: December 28, 2020
1. Acceptance of Terms and Conditions
IF YOU DISAGREE TO ANY TERM PROVIDED HEREIN, YOU MAY NOT ACCESS AND/OR USE THE SERVICES IN ANY MANNER WHATSOEVER.
2. Information we may collect
We may collect three types of data and information from our Users:
i. Personal Information, which is information that identifies an individual or may, with reasonable effort, identify an individual, either alone or in combination with other information, all unless anonymized, such as name, iris image, e-mail address, residence, gender or date of birth. Some technical parameters may also be considered as Personal Information, such as IP address and UDID (Unique Device Identifier); and
ii. Health and Wellness Related Information (“Health Information”), which is Personal Information that corresponds to a measurement of your physical/mental objective and/or subjective state data, such as height, weight, medical conditions that you have experienced or experiencing, and real-time assessment of current condition of stress and cholesterol, health condition of four organs, including brain, liver, lung, and kidney, as analyzed via use of the Hongbog Services and through the Hongbog App, and any Personal Information we derive from such information; and
3. How do we collect information?
We collect personal information from you and any devices (including mobile devices) you use when you: use or access our Services, register for an account with us, provide us information on a web form or other text field, update or add information to your account, or through correspondence you and we conduct with each other.
More specifically we collect and use the following categories and types of information:
3.1. Personal information you provide us when you use our Services. Generally, this category refers to any information, data or content you actively and voluntarily create or provide through our Services such as:
• Contact information such as your name, e-mail address, or/and telephone number that you provide through the Services when you fill our online form or register for an account with us or when you update your account details;
• Information provided during the course of the Services, or other contents generated in relation to the course of performance;
• Health Information and any other information you provide us in the scope of your use of the Hongbog Services, the Hongbog App, and the Hongbog Device, or other information that you generate related to such use, such as your name, e-mail address, date of birth, gender, social media account, telephone number, iris image, and real-time analysis result, etc.;
• The contents of your interaction with our customer support or sales departments, which may include text/video/audio recording and transcripts of such communications including information you enter in our “Contact Us” online form or any similar input.
3.2. Personal information we collect automatically when you use our Services. In other words, we are aware of your usage of the Services and Website and may gather, collect, and record the information relating to such usage, including by using our Third Party Service Providers as detailed in Section 5 (sharing information with third parties) below, and by using “cookies” and other tracking technologies, as further detailed in Section 8 (Local Storage and Third Party Software/Service, Cookies and other Tracking Technology) below. We collect information about your interaction with and use of our Services, including in certain cases about your impressions of and reactions to our advertisements, and information related to our communications with you. This is information we receive from devices (including mobile devices) and software you use when you access our Services. This information could include the following: Device ID or unique identifier, device type, device model name, device manufacturer, device display resolution, operating system, Mac address, Android ID, serial number, ID for advertising, unique device token, information regarding your clicks and “clicks stream”, views and engagement with our advertisement and Services, information concerning your traffic to and from the Website, your referral URL to and from our Website, ad data, your IP address, your login information, and location information as can be derived from your IP address. We collect and process Personal Information which is derived from other Personal Information we collect or obtain from you. This means that we process Personal Information in order to provide you with the output of the Hongbog Services such as recommendations, suggested analysis and other insights we may offer through use of the Hongbog Services. Please take into consideration that certain portions of such above mentioned information may also be collected from your device or software, when the Hongbog App is running in the background, i.e. when it has been launched but not used. Please keep in mind - that most mobile devices and auxiliary software, allow you to control or disable the use of certain collectable information including location services, by any application, in the device's settings menu.
4. The Purposes and Legal Basis of the Collection, Processing and Use of Information
4.2. Purpose of use. We may use the Personal Information that we collect about you for the following purposes:
• To provide timely, reliable and value-added Services to our Users;
• To verify the identity of our Users;
• To personalize the Services and content provided to you, to customize and improve your use experience of the Services, and to enable you to retrieve your information;
• To be able to contact Users for the purpose of providing them with technical assistance, support, handle requests and complaints and collect feedback;
• To send you updates, notices, notifications, and additional communications regarding the Services;
• To study and analyze the information on an aggregated, statistical basis to discover patterns and anomalies, to study complications, treatment methods, and improvements, and to perform other health related research and development;
• To enable us to further develop, customize, and improve the Services based on Users’ common preferences, uses, third party services, features and functionalities, statistical and research purposes, attributes and anonymized data, etc.;
• To prevent, detect, mitigate, and investigate fraud, security breaches, or other potentially prohibited or illegal activities;
• To display or send to you marketing and advertising material and general and personalized content and advertisement via the Services, the Website, e-mail, telephone, mobile devices, and/or when you visit other sites;
• To perform functions or services as otherwise described to you at the time of collection;
• To comply with any applicable rule or regulation, to protect our legal interests, and/or to respond to or defend against (actual or potential) legal proceedings against us or our affiliates.
5. Sharing Information with Third Parties
Hongbog will not share or otherwise allow access to any Personal or Health Information it collects to any third party, except in the following cases:
i. Law enforcement, legal proceedings, and as authorized by law: We may disclose Personal Information to satisfy any applicable law, regulation, legal process, subpoena, or governmental request; and
iv. Third Party Service Providers: We are partnering with a number of selected service providers, whose services and solutions complement, facilitate, and enhance our own. These Third Party Service Providers include any person, including agents, contractors, or third party service providers, who provides administrative, marketing, telecommunications, computer, data processing, or other services; hosting, database and server co-location services (e.g. Cafe24); data analytics services (e.g. Google Analytics) in connection with the operation of our business and provision of our Services to you. Such Third Party Service Providers may have access to or process on our behalf Personal Information and Health Information, which we collect, hold, use, analyze, process, and/or manage. We remain responsible for any Personal Information processing done by Third Party Service Providers on our behalf in accordance with the terms hereof, except for events outside of its reasonable control and except for such Third Party Service Providers with whom you have a direct contractual relationship; and
v. Your known health care providers, care management services or health care payers: In some instances, we will be working with you in conjunction with your own health care providers, care management services, or health care payers (insurance companies) (any such party is one of “Your Service Providers”). To the extent your relationship with us originates from one of Your Service Providers, we may provide your Personal Information and Health Information to that party for its use in connection to the services it provides to you. Any Personal Information and Health Information we provide back to Your Service Providers will be subject to those third parties’ own privacy policies and practices, and you should confer with Your Service Providers if you have any questions regarding their own usage and treatment of your Personal Information and Health Information.
6. Storage, Transfer, and Retention of your Information
7. Deletion, Withdrawal of Consent, modification or obtaining a copy of Personal Information
If the law applicable to you grants you such rights, you may ask to access, correct, or delete your Personal Information that is stored in our systems or that we otherwise control. You may also ask for our confirmation as to whether or not we process your Personal Information or ask to withdraw any consent you have previously provided to Hongbog in connection with our use and processing of your Personal Information. Exercising such rights of deletion and/or withdrawing such consent may result in our inability to provide you with our Services and in such event, we may notify you of termination of our engagement with you or otherwise cease providing you with our Services. Subject to the limitations in law, you may request that we update, correct, or delete inaccurate or outdated information. You may also request that we suspend the use of any Personal Information while we verify the status of that data and the accuracy of which you contest. Subject to the limitations in law, you may also be entitled to obtain the Personal Information you directly provided us in a structured, commonly used, and machine-readable format and may have the right to transmit such data to another party. If you wish to exercise any of these rights or withdraw your consent, please contact us at: email@example.com. When handling these requests, we may ask for additional information to confirm your identity and your request. Please note, upon request to delete your Personal Information, we may retain such data in whole or in part to comply with any applicable rule or regulation and/or to response or defend against legal proceedings versus us or our affiliates, or as we are otherwise permitted under such law applicable to you. To find out whether these rights apply to you and on any other privacy related matter, you can contact your local data protection authority if you have concerns regarding your rights under local law.
8. Local Storage and Third Party Software/Service, Cookies, and other Tracking Technology
8.1. Local Storage. When you access or use the Services, we may use industry-wide technologies which store certain information on your smartphone, your computer, or other mobile device (“Local Storage”), and which will allow us to enable automatic activation of certain features and make your experience in the use of our Services much more convenient and effortless. The Local Storage used by the Services is created per session and all the Information provided during the course of the Services, or other contents generated in relation to the course of performance shall remain on the Local Storage in an anonymized and encrypted form. When connected to the internet in any means, such information will also be uploaded to Hongbog’s server in the same anonymized and encrypted form. We also use certain monitoring and tracking technologies, including ones offered by Third Party Service Providers in order to collect and process Personal Information we specified above. These technologies are used in order to maintain, provide, and improve our Services on an ongoing basis, in order to provide a better experience to our Users and to provide our Users and potential users with more relevant advertisements of our Services. For example, these technologies enable us to: (i) keep track of and apply our Users’ and potential users’ preferences and authenticated sessions in Hongbog Services and Website; (ii) better secure our Services by detecting abnormal behaviors; (iii) identify technical issues and improve the overall performance of our Services; (iv) monitor and analyze our ads’ performance; (v) deliver to you targeted advertisements that are more tailored to you based on your browsing activities and inferred interests.
8.2 Cookies: Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. This information enables us to distinguish you form other users of the website, which helps us to provide you with a good experience when you browse the website. This information is also used to track visitor use of the website and to compile statistical reports on website activity, allowing us to improve the website. Learn more about cookies here:
· Google Adwords: https://policies.google.com/technologies/ads
· Facebook: https://www.facebook.com/about/privacy/
· LinkedIn: https://www.linkedin.com/legal/cookie-policy
If you wish to opt-out of such re-targeting and tracking functionality of the Social Ad Platforms, you may do so at the following links:
· Google Adwords: https://adssettings.google.co.il/authenticated
· Facebook: https://www.facebook.com/settings/?tab=ads
· LinkedIn: https://www.linkedin.com/help/linkedin/answer/34318?query=opt-out%20pixel
PLEASE NOTE – such tracking and targeting by Social Ad Platforms is provided pursuant to your engagement with such Social Ad Platforms, and the actual nature and scope of Personal Information collection and processing performed by such Social Ad Platforms is not transparent to us. If you would like to learn more or make further inquiries with respect to such nature or scope please refer to each of such Social Ad Platforms directly.
http://optout.networkadvertising.org/?c=1, or http://www.aboutads.info/choices/. PLEASE NOTE – (i) Deleting any of our tracking technologies or disabling future tracking technologies may prevent you from accessing certain areas or features of our Services or may otherwise adversely affect your user experience; (ii) we do not respond to the ‘Do Not Track’ setting on your browser as the protocol and form for such setting has not yet been generally accepted; (iii) when you opt out of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or on our online Services. It merely means that the online ads that you do should not be based on your interests; (iv) we are not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.
9. Direct Marketing
From time to time, you may provide us with personal information for the purposes of helping us to improve your overall experience with us or helping us to provide relevant information about our Services and promotions.
By registering to our Services and/or providing us with your e-mail address or any other contact information (including without limitation through any form on our Website), you expressly agree to receive promotional content, messages, or calls from Hongbog or our partners (acting on our behalf).
Accordingly, we or our affiliated representatives, shall be permitted to call you or send you promotional content or messages by e-mail, SMS, direct text messages, and similar forms of communication. If you wish not to receive such promotional messages or calls, you may withdraw your consent by sending a written notice to Hongbog by e-mail to the following address: firstname.lastname@example.org
or by pressing the “Unsubscribe” link contained in the promotional communications you receive. Please note that we may also contact you with important information regarding your use of our Services and/or Website. For example, we may notify you (through any of the means available to us) of changes or updates to our Services, payment issues, service maintenance, etc. You will not be able to opt-out of receiving such service messages.
10. How We Protect Personal Information
We maintain administrative, technical, and physical safeguards designed to protect Personal Information and Health Information we obtain through our Services against accidental, unlawful or unauthorized destruction, loss, alternation, access, disclosure, or use. Our Services, or parts thereof, are hosted on Cafe24, which provides advanced security features. Hongbog employs industry standard security procedures, including secured transmission protocols, SSL and advanced authentication.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we do not and cannot guarantee that unauthorized access will never occur. We urge you to use the strongest password combination available on your mobile device and employ reasonable physical security means to protect unauthorized access. In particular, e-mail you send or receive may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail. To the extent your local jurisdiction’s laws require us to notify you or local authorities of any breach of the security of your Personal Information, we will comply with such laws.
11. External Websites
To use our Services, you must be over the age of 18. Without relieving you of your responsibility to comply with the TOU and the terms hereof we reserve the right (without obligation) to request proof of age at any stage so that we can verify that persons under the age of 18 are not using our Services. In the event that it comes to our knowledge that a person under the age of 18 is using our Services not in accordance with the above mentioned terms, we will make all efforts to promptly delete any Personal Information (as such term is defined in herein) with regard to such User.
14. General Information
15. Have Any Questions?