Privacy Policy

Privacy Policy

Last Revised: December 28, 2020

Hongbog Co., Ltd. (“Hongbog,” “Company,” “we” or “us”) is committed to protect the privacy of the users of our website located at www.hongbog.com (the “Website”) and of the users of the Hongbog device (the “Hongbog Device”) and of the services we provide in connection with use of the Hongbog Device through the Hongbog application (respectively: “User(s)” or “you”; the “Hongbog Services” and the “Hongbog App”), in compliance with applicable privacy and personal data laws and regulations. The Website, the Hongbog Device, the Hongbog Services and the Hongbog App shall be together referred to hereunder as the “Services”. This Privacy Policy (the “Privacy Policy”) is intended to describe our practices regarding the information we may collect from you when you use the Services, the ways in which we may use such information, and the options and rights available to you. This Privacy Policy is supplementary to, and should be read together with, our Terms of Use (the “TOU”), which provides additional information on the Services. Capitalized terms which are not defined herein, shall have the meaning ascribed to them in our TOU.

1. Acceptance of Terms and Conditions

BY ENTERING, CONNECTING TO, ACCESSING OR USING THE SERVICES (OR ANY PART THEREOF), YOU AGREE TO THE TERMS AND CONDITIONS SET FORTH IN THIS PRIVACY POLICY, INCLUDING THE COLLECTION AND PROCESSING OF YOUR PERSONAL AND HEALTH INFORMATION (AS DEFINED BELOW).

IF YOU DISAGREE TO ANY TERM PROVIDED HEREIN, YOU MAY NOT ACCESS AND/OR USE THE SERVICES IN ANY MANNER WHATSOEVER.

IMPORTANT:
YOU ARE NOT OBLIGATED TO PROVIDE US WITH ANY PERSONAL OR HEALTH INFORMATION. YOU HEREBY ACKNOWLEDGE AND AGREE THAT YOU ARE PROVIDING US WITH SUCH INFORMATION AT YOUR OWN FREE WILL, FOR THE PURPOSES DESCRIBED IN SECTION 4 BELOW, AND THAT WE MAY USE, PROCESS AND RETAIN SUCH PERSONAL OR HEALTH INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY AND SUBJECT TO ANY APPLICABLE LAWS AND REGULATIONS.

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
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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
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‍iii. Non-personal Information, which is non-identifying and without reference to the identity of any User, such as technical data that is necessary for the performance and improvement of the Services, such as IP addresses, Wi-Fi network information, operating system, mobile device type, Hongbog Service technical information, referring and exit pages and URLs, the 'click-stream' and activities on the Services, and the period of time the Services were used and related timestamps. For purposes of this Privacy Policy, we will treat any User Personal Information that is anonymized and deidentified in a way that such User can no longer be personally identified as Non-personal Information and may use or share this information in aggregated form for statistical, research or other lawful purposes.

For the avoidance of doubt, we will treat any Non-personal Information connected or linked to any Personal Information as Personal Information as long as such connection or linkage exists. In this context it is important to note that Health Information is included within the category of Personal Information for the purposes of this Privacy Policy.

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.

We will not collect any Personal and Health Information from you or related to you without your explicit approval, which is obtained, inter-alia, through your active acceptance of the TOU and this Privacy Policy.

PLEASE NOTE - If you give us Personal Information about someone else, you must do so only with that person’s express authorization. You should inform them how we collect, use, disclose, and retain their Personal Information according to this Privacy Policy before you provide us with their Personal Information.

4. The Purposes and Legal Basis of the Collection, Processing and Use of Information

4.1. Legal Basis for use. We collect, process and use your Personal Information, which is adequate, relevant and limited to what is necessary in relation to the purposes described in this Privacy Policy, based at least on one of the following legal grounds:

i. In Performing an agreement with you: We collect and process your Personal Information in order to provide you with the Services, following your acceptance of this Privacy Policy and pursuant to the TOU; to maintain and improve our Services; to develop new services and features for our Users; and to personalize the Services in order for you to get a better user experience; and
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ii. With your consent: We ask for your consent and approval to collect and process your Personal Information including specifically any Health Information for the purposes set forth in this Privacy Policy and you have the right to withdraw your consent at any time; and
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iii. Legitimate interest: We process your Personal Information for our legitimate interests while applying appropriate safeguards that protect your privacy. This means that we process your information for things like detecting, preventing, or otherwise addressing fraud, abuse, security, usability, functionality or technical issues with our Services, protecting against harm to the rights, property or safety of our properties, or our users, or the public as required or permitted by law; enforcing legal claims, including investigation of potential violations of this Privacy Policy; defending legal claim made by you or on your behalf against us, in order to comply and/or fulfil our obligation under applicable laws, regulation, guidelines, industry standards and contractual requirements, legal process, subpoena or governmental request, as well as our TOU.

4.2. Purpose of use. We may use the Personal Information that we collect about you for the following purposes:
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• 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
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ii. Protecting Rights and Safety: We may share Personal Information to enforce this Privacy Policy and/or the TOU, including investigation of potential violations thereof; to detect, prevent, or otherwise address fraud, security or technical issues; to respond to claims that any content available on the Services or the Website violates the rights of third-parties; or otherwise if we believe in good faith that this will help protect the rights, property or personal safety of Hongbog, any of our Users, or any member of the general public; and

iii. Our Affiliated Companies: We may share Personal Information internally with Our Affiliated Companies for the purposes described in this Privacy Policy. In addition, when Hongbog or any of Our Affiliated Companies is undergoing any change in control, including by means of merger and acquisition or purchase of all or substantially part of its assets, we may share Personal Information with the parties involved in such event. If we believe that such change in control might materially affect your Personal Information then stored with us, we will notify you of this event and the choices you may have via e-mail and/or prominent notice on the Website or Services; 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

Information regarding the Users will be maintained, processed, and stored by us, and our Service Providers in Republic of Korea, and as necessary, in secured server provided by our Third Party Service Providers. While the data protection laws of Republic of Korea may be different than the laws of your residence or location, please know that Hongbog, and our Service Providers that store or process your Personal Information on our behalf are each committed to keep it protected and secured, and pursuant to this Privacy Policy and industry standards, regardless of any lesser legal requirements that may apply in their jurisdictions. Specifically, each of our Third Party Service Providers who stores or processes your Personal Information either: (i) assured us that it provides adequate safeguards to protect your rights to privacy; or (ii) holds and processes such information on our behalf in a jurisdiction which has been determined to ensure an adequate level protection by the government authority of such jurisdiction. By providing your information, you expressly consent to the place of storage and transfer described above, including transfers outside of the jurisdiction in which the information was provided. We retain the Personal Information we collect only for as long as legitimately needed and to the extent required for the achievement of the purposes listed under Section 4 including without limitation, as reasonably necessary to comply with our legal obligations and/or to protect our legitimate interests. We then either delete from our systems or anonymize it without further notice to you.

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: support@hongbog.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:
www.allaboutcookies.org. Pixel tags (also commonly known as web beacons) are transparent images, iFrames, or Java Script placed on our Website or our advertisements and e-mails, that our Third Party Service Providers use to understand how the Website, advertisements, and e-mails are interacted with. Some of these tracking technologies are provided to us by our Third Party Service Providers who collect and process Personal Information on our behalf. These Third Party Service Providers may have direct contractual relationship with you (e.g. Google and Facebook). Additionally, the services provided to us by such Third Party Service Providers may entail collection and processing of Personal Information by such Third Party Services Providers, in a scope which is broader than the scope of Personal Information we are eventually provided with by such Third Party Services Providers. This means that sometimes these Third Party Service Providers have more access to your Personal Information than we do. To the extent you have direct contractual relationship with any of our Third Party Service Providers, any rights you may have with respect to your Personal Information, collected by such Third Party Service Providers, shall be governed by such contractual relationship. Otherwise, the terms of this Privacy Policy shall fully apply. In this context, you should note that we may use Google Analytics, Facebook, and LinkedIn’s functionality of re-marketing through their tracking cookies and pixel-based retargeting services. This means that if you provided your consent to Google, Facebook, or LinkedIn (the “Social Ad Platforms”) to be provided with personalized commercial offers, you may be served with ads (including advertisements of third parties) based on your access to the Services or Website, outside of the Services, the Website, and across the internet. In such event, the Social Ad Platforms will place cookies on your web browser and use such cookies to serve you ads based on past visits to our Services and Website. Please visit the Social Ad Platforms Privacy policy to find out how they use such information:
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· 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.

‍Learn more about your choices and how to opt-out of tracking technologies: In order to delete or block any tracking technologies, please refer to the “Help” area on your internet browser for further instructions. You may also opt out of third party tracking technologies by following the relevant instructions provided by each such third party in its privacy policy or by visiting www.youronlinechoices.eu,
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: support@hongbog.com
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

The Website and the Services may contain links to External Sites. Hongbog has no control over the privacy practices or the content of these External Sites. As such, we are not responsible for the content or the privacy policies of those External Sites. Please visit the applicable third-party privacy policy and terms of use to find out how they collect and use your information.

12. Minors

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.

13. Changes to the Privacy Policy

This Privacy Notice is effective as of the stated “Last Revised” date stated at the top of this Privacy Notice. Hongbog reserves the right to change this Privacy Policy at any time. Any such changes will be posted on the Website. If we make any material changes, we will notify you by email (sent to the email address specified in your account) or prominent posting on the website prior to the changes becoming effective. By accessing the Website and/or using the Services after we make any such changes to this Privacy Notice, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, our use of the Information is governed by the Privacy Policy in effect at the time we collect the Information. Please refer back to this Privacy Notice on a regular basis.

14. General Information

This Privacy Policy, its interpretation, and any claims and disputes related hereto shall be governed by the laws of Republic of Korea, and you hereby consent to them being litigated in and decided exclusively by a court of Republic of Korea. This Privacy Policy was written in English and may be translated into other languages for your convenience. If a translated (non- English) version of this Privacy Policy conflicts in any way with the English version, the provisions of the English version shall prevail.

15. Have Any Questions?

If you have any questions (or comments) concerning this Privacy Policy, you are welcome to send us an email at: support@hongbog.com, and we will make an effort to reply within a reasonable timeframe. By contacting Hongbog, you agree that you are free to do so, and that you do not provide Hongbog with information which violates any third-party intellectual rights (the “Information”). Without derogating from the aforesaid, all rights, including intellectual property rights, arising from your communication with us will be owned by Hongbog and will be considered as Hongbog’s confidential material. It is clarified that any use of the Information will be at Hongbog’s sole discretion, and Hongbog is not obligated to use all or any part of such Information.