This Privacy Policy explains how information about you is collected, used and disclosed by Hito, Inc. (“Hito,” “we” or “us”) when you use our website https://www.hito.xyz (“Website”), hardware products, or when you otherwise interact with us. This Privacy Policy also describes your choices regarding use, access and correction of personal information collected about you through our Website. Please read this Privacy Policy carefully and ensure that you understand it before you start to use our Website.

This Website is owned and operated by, or on behalf of Hito. We are the data controller in respect of personal information of our users based in the European Economic Area (“EEA”).

By accessing and using the Website, you acknowledge that you have read and understood the content of this Privacy Policy. We reserve the right to update this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the Privacy Policy and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you a notification). We encourage you to review the Privacy Policy whenever you access the Website or otherwise interact with us to stay informed about our information practices and the ways you can help protect your privacy.

INFORMATION YOU PROVIDE TO US THROUGH THE WEBSITE

We collect and process information you provide directly to us via the Website. Personal data submitted through the Website includes the details you submit when you create an account, participate in any interactive features of the Website, fill out a form, pay for products, communicate with us via third party social media sites, request customer support or otherwise communicate with us. The types of information we may collect include your name, email address, mailing address, phone number and any other information you choose to provide. To the extent you provide credit card information through the Website, that information is collected and processed by our third-party payment processor pursuant to their Privacy Policy and practices. Our payment processor is Stripe and their privacy policy can be found here https://stripe.com/en-gb-us/privacy

INFORMATION WE COLLECT AUTOMATICALLY WHEN YOU USE THE WEBSITE

When you access or use the Website we automatically collect information about you, including:

• Log Files: We gather certain information about your use of the Website, including the type of browser you use, access times, pages viewed, your IP address and the page you visited before navigating to the Website, and store it in log files. We do not monitor or log data collected from your servers when using the Website, but we may log or monitor information about your access to our Website.
• Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect information, including cookies and web beacons. For more information about cookies, and how to disable them, please see our Cookie Policy page https://hito.xyz/policy_cookie%20.html and Your Choices below.

INFORMATION WE COLLECT FROM OTHER SOURCES

We may also obtain information from other sources and combine that with information we collect through our Website for purposes of advertising and user authentication. For example, if you create or log into your Hito account using your Google Apps credentials via single sign-on, we will have access to certain information such as your name and email address as authorized in your Google Apps profile settings.

USE OF INFORMATION

We may use information about you to:

• Enable you to have full access to the Website;
• Provide, maintain and improve the Website;
• Provide and deliver the products you purchase, process transactions and send you related information, including confirmations and invoices;
• Send you technical notices, updates, security alerts, and support and administrative messages;
• Respond to your comments, questions and requests, and provide customer support;
• Create your Hito account and identify you when you sign-in to your account in accordance with your agreement with us;
• Communicate with you about products, services, offers, promotions, rewards, and events offered by Hito and others, and provide news and information we think will be of interest to you;
• Monitor and analyze trends, usage and activities in connection with the Website;
• Detect, investigate and prevent fraud and other illegal activities and protect the rights and property of Hito and others;
• Personalize and improve the Website and provide advertisements, content or features that match user profiles or interests;
• Notify you about important changes to the Website, including changes or updates to this Privacy Policy;
• Link or combine with information we get from others to help understand your needs and provide you with better service;
• Consider you for possible employment at Hito in connection with an application that you submit; and
• Carry out any other purpose described to you at the time the information was collected.

SHARING OF INFORMATION

We may share your personal information as follows or as otherwise described in this Privacy Policy:

• With vendors, consultants and other service providers we have vetted and approved who need access to such information to carry out work on our behalf only to the extent necessary for the performance of any contract we enter into with you. This includes companies providing the following services for our Website: hosting services, authentication services, cyber security and anti-fraud services, and advertising;
• In response to a request for information if we believe disclosure is permitted by, in accordance with, or required by, any applicable law, regulation or legal process such as to comply with a subpoena or applicable court order;
• With any person to whom disclosure is necessary to enable us to enforce our rights under this Privacy Policy or under any agreement we enter into with you or to protect the rights, property and safety of Hito or third parties;
• In connection with, or during negotiations of, any merger, sale of Hito assets, financing or acquisition of all or a portion of our business by another company;
• Between and among Hito and all companies affiliated with Hito who may act for us for any of the purposes set out in this Privacy Policy, including our current and future parents, affiliates, subsidiaries and other companies under common control and ownership;
• With analytics and search engine providers that assist us in the improvement and optimization of our Website, subject to our Cookies Policy; and
• With your consent or at your direction.

We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.

LAWFUL BASIS FOR PROCESSING YOUR INFORMATION

We are required to state the lawful basis under which we process the personal data of our users from the EEA. Accordingly, the lawful bases upon which we process your personal information are as follows:

• Where it is necessary to obtain your prior consent to the processing concerned in order for us to be allowed to do it, for instance in relation to direct marketing, we will obtain and rely on your consent in relation to the processing concerned;
• Otherwise, we will process your personal data only where the processing is necessary for compliance with a legal obligation to which we are a subject; or
• For the purposes of the legitimate interests pursued by us in promoting our business, providing the Website to our customers pursuant to or legal agreements with them, and in ensuring the security, accessibility and improvement of our Website and the development of new technology and products.

EXTERNAL LINKS

The Website may, from time to time, contain links to external sites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites. We are not responsible for the privacy policies or the content of such sites.

LOG-IN FEATURES

We may allow you to sign up and log in using your Google account. If you sign up using your Google email account, Google will ask your permission to share certain information from your Google account with us. This may include your first name, last name, gender, general location, your timezone and birthday. This information is collected by Google and is provided to us under the terms of Google’s privacy policy, which you can find here: https://policies.google.com/privacy?hl=en-US. You can control the information that we receive from Google using the privacy settings in your Google account.

ADVERTISING AND ANALYTICS SERVICES PROVIDED BY OTHERS

We allow the following companies to serve advertisements on our behalf across the Internet and in applications: Google AdWords, Google analytics, Marketo, Twitter, Facebook, Adroll, Quora, Bing ads, Linkedin, Terminus, Demand base, Instagram, and Reddit using email address and cookies that are collected. These entities use technologies including cookies, web beacons, device identifiers and other tools to collect information about your use of the Website and other websites and applications, including your IP address, web browser, pages viewed, time spent on pages or in apps, links clicked and conversion information. This information may be used by Hito and Hito service providers to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Website and other websites and better understand your online activity. For more information about cookies, please see below and for further information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please see Hito’s Cookie Policy at https://hito.xyz/policy_cookie%20.html

MARKETING

Where permitted in our legitimate interest or with your prior consent where required by law, we will use your personal information for marketing and to provide you with promotional update communications by email about our products. You can object to further marketing at any time by selecting the “unsubscribe” link at the end of all our marketing and promotional electronic communications to you, or by contacting us using the contact details set out at in the Your Choices and Your Rights sections of this Privacy Policy.

SECURITY

We take reasonable steps, including physical, technical and organizational measures, to protect your personal information from unauthorized access and against unlawful processing, accidental loss, destruction and damage. Unfortunately, transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information submitted to us.

Your personal information will be retained by Hito for the duration of your account and may be retained for a period after this time as necessary and relevant to our legitimate interests, our terms of agreement with you and in accordance with applicable legal obligations. This may include retention necessary to meet our tax reporting requirements as well as time required to enforce the relevant terms of agreement or to identify, issue or resolve legal proceedings. We may retain a record of your stated objection to the processing of your data, including in respect of an objection to receiving marketing communications, for the sole legitimate purpose of ensuring that we can continue to respect your wishes and not contact you further, during the term of your objection.

TRANSFER OF INFORMATION TO THE U.S.

Hito is based in the United States. By accessing or using the Website or otherwise providing information to us, you understand that your information will be subject to processing, transfer and storage in and to the U.S. where you may not have the same rights and protections as you do under local law.

YOUR RIGHTS

EEA individuals have rights in relation to their personal data, which is processed by Hito. If you are an EEA data subject, you may, by emailing us at order@hito.xyz:

• Request access to the personal data concerned.
• Request that any incorrect personal data about you that we are processing be rectified.
• Request that we erase the personal data concerned.
• Withdraw your consent at any time where we are processing personal data relating to you on the basis of your prior consent to that processing, after which we shall stop the processing concerned.
• Lodge a formal compliant with the Information Commissioner in Ireland (or your local EEA supervisory authority if you live outside the UK) if you have a complaint about any processing of your personal data being conducted by us.

YOUR CHOICES

Account Information

Our customers may access, update or change personal information they have provided by logging into the Website or emailing us at mk@hito.xyz . Subject to the terms of their agreements with us, customers may deactivate their accounts by emailing us at mk@hito.xyz, but note that we may retain certain personal information as necessary to comply with our legal obligations or for legitimate business purposes, such as to resolve disputes or enforce our agreements. We may also retain cached or archived copies of personal information for a certain period of time.

If you are an individual with whom one of our customers interacts with respect to the Website (e.g., an employee of a customer), as noted above, you should direct any requests regarding access, modification or deletion of personal information to the applicable customer.

Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Website. For more information, please see Hito’s Cookie Policy at https://hito.xyz/policy_cookie%20.html

Promotional Communications

You may opt out of receiving promotional emails from Hito by following the instructions in those emails or by emailing mk@hito.xyz. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

CONTACT US

If you have questions or concerns about this Privacy Policy, please contact us at: Hito, Inc., mk@hito.xyz.