Who we are
Suggested text: Our website address is: https://hooheo.com.
Website Privacy and Security
Last Updated: July 21, 2022.
- Personal Information we collect in our stores, on our websites, through our call-centers or through our repair centers, and the purposes for which we use it.
- Personal Information we collect in order to determine your suitability for employment if you apply for a job with us.
- Personal Information we transfer to third parties.
- How long do we retain Personal Information.
- How we keep your Personal Information safe.
- Rights you have and how you can execute such rights.
“Personal Information” is information that can be used either directly or indirectly to identify you. Examples of Personal Information include your name and your email address.
We and our service providers process personal data related to you in order to provide you with the full range of services and features we offer. This includes data necessary to set up a customer account and data required to receive products and services and applying for employment.
We may use your data for marketing purposes to provide you with personalized offers about our products and services, unless you opt-out (for US customers) or with your consent (for Canadian customers).
We and our service providers access your data in order to provide services to you as described in this Privacy Notice.
We have implemented physical, organizational, contractual and technological security measures with a view to protecting your Personal Information and other information from loss or theft, unauthorized access, disclosure, copying, use or modification.
Location of your data
Data we use will be primarily stored in the United States with us and our cloud service providers.
1. What personal data do we use, for which purposes and on which legal basis?
In order to provide you with our services and the full range of features, we and our service providers use your data (including your name, email address and IP address) for the following purposes:
- When you create an online customer account, to manage your account, to provide access to your shopping cart, to display purchased, reserved and registered products, or to present other products presumably of interest to you, to verify your identity if you forgot your password and to process your product reviews.
- When you choose to provide us further information, such as date of birth, address, personal settings, a wish list and your gender, to enable us to personalize both your profile and our recommendations for you.
- When you order goods online, in this case we additionally need your address, telephone number and payment information, to process your purchase, send you confirmation or back-in-stock notification and scan transactions for fraudulent activity.
- When you place products in your shopping cart, but have not checked out these products, we use your email address to send you an abandoned cart reminder.
- When you book a Virtual Shopping appointment with us, we ask for your name, telephone number, email address and shopping preferences to offer you a remote shopping experience. Additionally – to facilitate purchasing – you can leave a shipping address.
- When you order goods to be picked-up in one of our stores by someone other than you, we need contact details such as name and email address of the pick up person.
- When you purchase a product in a Hooheo Jewelry retail store and request an e-receipt, to process your request.
- When you participate in loyalty programs, recommend our products to others, redeem a gift card, or when we offer you discounts and bonuses etc. we use this information in addition to purchase-related information to determine whether you are eligible for additional discounts and special offers.
- When you share any pictures/materials with us for publication on social media for such publication.
- When you enter a sweepstake, contest/competition, or promotion sponsored by us to administer and promote the sweepstakes, contest/competition or promotion.
- When you return or exchange a product or when you send us your product for warranty or repair service, to process the request and any communication in connection with it.
- When you contact us to answer your requests, provide customer support and handle your inquiry.
In principle (unless we have a legal or other legitimate reason to maintain it), we delete information related to you
- upon your request,
- after expiry of the relevant legal retention period,
- once we do not have any business purpose for retaining the data anymore.
In addition to those just described, we want to explain certain of our processing activities to you in more detail:
1.1 Recruiting process
We process your data in order to determine your suitability for employment if you apply for a job with us. For the application process we collect the information from your application and the information included in your CV/resume and cover letter, which may include contact details, academic background, job history, skills and competencies, as well as the IP address from the device you are applying from etc. Your application data will not be kept for longer than is legally allowed, or as required by applicable law.
1.2 Video surveillance
We process data gained from video surveillance in some of our stores and campuses for purposes allowed by law including: security, loss and fraud prevention reasons. We share this data in the cases described in Section 3. The duration of the data storage depends on the governing national law unless storage is otherwise permitted (see Section 4).
1.3 Interest based advertising
We may contact you for direct marketing purposes via email, mail, or other electronic communication methods (e.g. social media) unless you have opted-out from receiving direct marketing messages (for US customers) or with your consent (for Canadian customers). For certain types of direct marketing methods (e.g. text messaging, or in Canada, email marketing), we will obtain your explicit consent prior to sending you direct marketing messages. To select which marketing information may be of interest to you and to personalize ads and offers we
- use publicly available information (e.g. from your social media profiles),
- analyze your account information and how you use our services including our website, ads on third party websites and our newsletter,
- use information of your redemption of a gift card, participation in a sweepstake, contest, competition, or survey,
- use information collected by our service providers or partners (e.g. Google).
- use information collected when you request an e-receipt in our stores or fill out an onboarding form.
1.4 Cross-device targeting
In order to save your preferences, analyze your usage of our websites, provide interest-based advertising to you and deliver tailored ads across multiple devices, we try to link the different devices you are using to you. Technically, we are storing cookies on all the devices you are using and link those cookies within our internal database.
1.5 Log files, Cookies and similar technologies
Every time you visit our website, our system stores data related to your browser, its version, the operating system of your computer, your IP address, date, length and time of your visit, the website you accessed before and the sites you visit following links on the Hooheo Jewelry page. We use this information for our legitimate security interest and we delete log files without undue delay.
1.6 Your reviews and shared content
When you post a product or seller review or upload an image or other material to our website, or when you share content with us on third party websites, such as social networks, we may publish and use this information on our website and third party websites. Information shared with third party websites is not necessarily under our control and we do not control and do not assume responsibility for the use of that information by such third party websites.
2. Where do we get Personal Information from?
Most of the Personal Information we process we received from you or your actions, be it because you entered the data during the registration process, placed an order, applied for a job vacancy or because we track your usage of our website, or newsletter, etc. However, we also may receive information about you from other sources, such as, other Hooheo Jewelry companies, and, if publicly available, from third party websites. In some cases we receive Personal Information about you from our service providers and partners, e.g. from Facebook, Google, etc.
3. When do we share Personal Information?
We will share your Personal Information in the following cases:
3.1 Legal obligation and internal purposes
We disclose your Personal Information
- in order to comply with relevant laws, regulatory requirements and to respond to lawful requests, court orders, and legal processes, including requests to meet national security or law enforcement requirements,
- in order to protect and defend the rights or property of us or third parties,
- in an emergency, in order to protect the safety of our employees, or any person.
3.2 Joint Processing within Hooheo Jewelry
Your information may be combined with other Personal Information that Hooheo Jewelry companies have obtained about you that might be covered by other Hooheo Jewelry Privacy Policies (e.g. wearable data, goods you have purchased on a different Hooheo Jewelry company website or from a Hooheo Jewelry store in another country, repair transactions). We may also make your data available to Hooheo Jewelry companies for analytic purposes, or if you apply for a job with us (for information about Hooheo Jewelry companies click here www.hooheo.com). We base this joint processing on an intra-group agreement, allocating the responsibilities of the respective group entities. According to this agreement, each Hooheo Jewelry company will be responsible for the data processing related to its own business operations and will remain responsible for the Personal Information jointly processed with others. For you as our customer this means that the Hooheo Jewelry entity you are in touch with is responsible for processing your data and answering your requests. If you are not sure about the entity responsible in your case please contact email@example.com.
3.3 Links to Third-Party Websites and Services
On some pages we allow you to share Personal Information with third parties, such as social networks like Facebook. In these instances you are agreeing to the data being shared and the shared data being subject to the privacy policies of the third party. We do not control and do not assume any responsibility for the use of Personal Information by such third parties. For more information about the third party’s purpose and scope of their use of Personal Information in connection with sharing features, please visit the privacy policies of such third parties.
3.4 Third party advertising
3.5 Public Disclosure
Any Personal Information that you include in the text of a product review may be made public in the product review section of our product pages. We may also make your wishlist public on our website when you enable this function.
3.6 Sharing with third parties
We involve other companies for the provision of services, who are allowed to use Personal Information only on our behalf and must not use it for their own purposes, unless permitted by law.
The following is a list of categories of services and functions along with example recipients:
- to enable the functionality of our online application portals (e.g. IBM)
- to provide customer care services (e.g. Salesforce, 8×8, Transcosmos)
- to provide a virtual shopping experience (e.g. Squarespace)
- providing hosting and general IT services (e.g. Amazon Web Services and Google)
- using data cleansing and enrichment techniques (e.g. Acxiom Corporation)
- for social media services (e.g. Facebook or Google)
- providing payment services (e.g. PayPal, CyberSource)
- for transport and logistics services (e.g. FedEx).
- for direct marketing campaigns (e.g. Google, Facebook).
- to administer sweepstakes, contests and competitions.
3.7 Transfer of Assets
We may transfer your Personal Information to a third party in the event of a transfer of all or some of our assets to a third party.
4. For how long do we use Personal Information?
We will retain your Personal Information as long as necessary to provide you with functionality and services as described above under Section 1, as long as reasonably necessary to further our legitimate interests or as long as we are required or allowed to by law. Examples include: to support a transaction with you, the defense against, or the establishment of legal claims and legal obligations (e.g. tax law, or the principle of accountability, which requires us to demonstrate that our processing complies with applicable data protection laws). In order to verify whether you opted out or in to marketing activities, for example, we store your respective choice (e.g. via a cookie or a declaration).
5. How do we keep your Personal Information safe?
We have implemented physical, organizational, contractual and technological security measures with a view to protecting your Personal Information and other information from loss or theft, unauthorized collection, use and disclosure.
Despite the measures outlined above, no method of information transmission or information storage is 100% secure or error-free, so we unfortunately cannot guarantee absolute security. You must also do your part by keeping your password safe.
6. What are your rights?
6.1 Access to and your rights regarding your Personal Information
If you have an account on this site, you have the ability to view and change the Personal Information you provided to us within the My Account section of the website and/or using the contact details in Section 11 below. You may access information we hold about you, request a correction where data is incorrect or a deletion of your data, unless we have to keep your data for legal reasons. We encourage you to address any concerns you may have regarding our use of your Personal Information by using the contact details provided below.
6.2 California Residents
The California Consumer Privacy Act of 2018 (CCPA) provides California residents with specific rights regarding their Personal Information. If you are a California resident you have the right to request the disclosure of
- the categories of Personal Information we collected about you
- the categories of sources from which the Personal Information is collected
- the business or commercial purpose for collecting or selling Personal Information
- the categories of third parties with whom we share Personal Information and
- the specific pieces of Personal Information we have collected about you.
You have the right to request that we delete any Personal Information that we have collected, subject to certain exceptions defined in CCPA.
To exercise your access and deletion rights described above you have to submit a verifiable request to us by (1) sending us an email at firstname.lastname@example.org or (2) calling us at +1 (831) 316-3158. The verifiable request must contain sufficient information to allow us to verify you and to properly understand and respond to your inquiry. As part of our verification process we will send you an email with a link to verify your email address. Following this we will ask you one further verification question. Once the verification process is complete we will send you emails with login credentials to our secure privacy portal for you to access, download or instruct us to delete your data.
We will respond to your verifiable request within 45 days of receipt. If we require more time (up to 90 days) we will provide you with notice and explanation of the reason.
We may not be able to fulfil your deletion request in part or completely if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Furthermore you have the right to request that in case we sell your Personal Information, or disclose it for a business purpose, we disclose to you:
- the categories of Personal Information that we collected about you,
- the categories of Personal Information that we sold about you and the categories of third parties to whom the Personal Information was sold, by category or categories of Personal Information for each third party to whom the Personal Information was sold and
- the categories of Personal Information that we disclosed about you for a business purpose.
In case we have sold your Personal Information you have the right, at any time, to direct us not to sell your Personal Information. This right may be referred to as the right to opt-out. You may opt out of the sale of your Personal Information by completing the webform here. You may also submit your request to opt-out by sending us an email at email@example.com or calling us at +1 (831) 316-3158.
You may use an authorized agent to submit a request to access, delete and to opt-out on your behalf if you provide the authorized agent written permission to do so and verify your own identity directly with us. “Authorized agent” means a natural person or a business entity registered with the Secretary of State that a consumer has authorized to act on their behalf. We may deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf, unless you have provided the authorized agent with power of attorney, pursuant to Probate Code sections 4000 to 4465.
We do not knowingly collect personal information from California residents between the ages of 13 and 16.
In the preceding 12 months, we have collected the following categories of Personal Information about California residents:
- Identifiers such as real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) such as signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
- Protected classification characteristics under California or federal law such as age (40 years or older) and sex (gender).
- Commercial information such as including products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Internet or other similar network activity such as browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
- Audio / Visual such as audio, electronic, visual, thermal, olfactory, or similar information (e.g. recordings of calls with customer care).
- Inferences drawn from other personal information such as a profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
We have collected the Personal Information directly from you, e.g during your account registration, your purchases and through your usage of our website and from Consumer data resellers, from employment applications you submit to us, through transactions in our stores and interactions with our customer care or warranty and repair services. We may use or disclose the Personal Information we collect for “business purposes” or “commercial purposes” such as security, debugging/repair, performing services on behalf of the business or service provider, advance a person’s commercial or economic interests, quality, safety maintenance and verification of a service or device, enabling or effecting a commercial transaction etc.
In the preceding 12 months we have sold and/or disclosed the following categories of Personal Information:
|Sold||Disclosed for a business purpose|
|Identifiers||Consumer data resellers, Advertising and Social networks||Affiliates, Service providers, Logistic, Payment processors, Public auditing|
|Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))||N/A||Affiliates, Service providers, Logistic, Payment processors, Public auditing|
|Protected classification characteristics under California or federal law||N/A||Affiliates, Service providers, Public auditing|
|Commercial information||Consumer data resellers, Advertising and Social networks||Affiliates, Service providers, Payment processors, Public auditing|
|Internet or other similar network activity||Advertising and Social Networks||Affiliates, Service providers, Payment processors|
|Audio / Visual||N/A||Affiliates, Service providers|
|Inferences drawn from other personal information||N/A||Affiliates, Service providers|
We do not discriminate against you because you exercised any of your rights under the California Consumer Privacy Act, including, but not limited to, by:
- Denying goods or services to you; charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties,
- Providing a different level or quality of goods or services to you,
- Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may charge you a different price or rate, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to you by your data (e.g. your identifiers). In addition, we may offer financial incentives, including payments to you as compensation, for the collection of Personal Information, the sale of Personal Information, or the deletion of Personal Information. We may also offer a different price, rate, level, or quality of goods or services to you if that price or difference is directly related to the value provided to you by your data. We may enter you into a financial incentive program only if you give us prior opt in consent which clearly describes the material terms of the financial incentive program, and which may be revoked at any time. We shall not use financial incentive practices that are unjust, unreasonable, coercive, or usurious in nature.
7. Data Storage in the U.S.
Personal Information we collect will be primarily stored in the United States with Hooheo Jewelry member companies and our service providers, see examples in the list in Section 3.6. To the extent permitted by applicable law we also use and transfer Personal Information in and to other countries and territories. Your information may thus be subject to U.S. and foreign laws and accessible to U.S. and foreign governments, courts, law enforcement and regulatory agencies.
8. Age Requirements and Children’s Online Privacy Protection Act (“COPPA”)
We do not knowingly collect, maintain or use Personal Information about children under 16. Persons under the age of 16 may not use our website without supervision from a responsible adult. We will never request Personal Information from a child under 16 without verifiable parental consent. If we become aware that a child under 16 has sent Personal Information without prior parental consent, we will remove his or her Personal Information from our records.
9. What happens if we change this Privacy Notice?
This Privacy Notice is effective as of July 19, 2021, and may be updated from time to time. We will notify you of material changes by posting a prominent notice on our website or by sending you an email.
10. Links to and from other websites
Whenever we provide links to other websites on our website, this is in the interest of our users and should be understood as a courtesy. Some pages to which we link and pages that link to our websites are not under our control. In such cases we are neither responsible for the content of these pages nor for compliance with the applicable data protection regulations of those providers. We recommend that you carefully read the privacy statements of these third parties to learn how your Personal Information is stored, used or shared.
11. Who are we and how can you contact us / Contact Details
Please address any questions, concerns, inquiries, complaints, or requests regarding our practices concerning Personal Information to Hooheo Jewelry at:
Telephone Number: +1 (831) 316-3158
Attention: Hooheo Manager
13929 N US 75-Central Expy 1000, Dallas, TX 75243, USA
You can also get in touch with our data protection team and the responsible data protection officer we designated in every case required by law per email using firstname.lastname@example.org.
This website is provided by Hooheo Jewelry, 901 S. Central Expressway, Richardson, TX 75080, USA, email: email@example.com.