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Privacy Policy - Overview

Welcome to HMCG! HMCG, Inc. is the owner of HMCG (“HMCG,” “we,” and “us”) and we care about your privacy.  We have developed this Privacy Policy (this “Policy”) to describe the information we collect, how that information may be used, with whom it may be shared, and your choices, in connection with your use of our website, including the Site hosted on the domain www.hmcg.it, mobile applications that we may make available, and all services provided by us in connection with such Sites, and any of our products and services that link to this Policy (collectively, our “services.”).
Please read this Policy carefully before using our services.

Information We Collect

We may collect information in several ways, so we have explained the types of information that we collect in each context below. Please note that this Policy does not apply to any information that you share with Brands (a third party provider, manufacturer, or seller of certain retail products that are available for product registration and other features on or through our services), or other users directly. For information about how Brands or other users handle your information, please consult such Brands and users about their privacy practices.

Information You Provide to Us

  1. Your Account Information and Your Submissions:
When you use our services, you may provide certain information directly to us.  For example, when you register for an account with HMCG, we require that you provide us with your contact information including your first and last name, email and physical address, and phone number. You may also optionally provide us with photos and provide us with information about your product purchase activity and association with Brands.
The services also may allow you to provide us with information relating to Brands and products that you have purchased, such as testimonials, product endorsements, content, comments, questions, feedback, ideas, and suggestions.
  1. Your Communication with Brands and Other Users:
The services may permit you to communicate with Brands and other users (as applicable) of the services.  In most cases, HMCG only provides users with each other’s contact information, and the actual communication occurs off of our services (and take no part in those communications).  Similarly, if you register a product or connect with a Brand through the services, we will collect appropriate information to facilitate those processes.
  1. Your Communication with Us:
We collect information when you communicate with us. The specific types of information we collect will depend on the forum in which you communicate with us.  For example, if you send us an email, we will collect your email address and the content of your email.
  1. Your Purchases:
Purchases and payment transactions between users and Brands are between those users and Brands only, and HMCG is not a party to those transactions.  However, HMCG may charge fees for use of certain HMCG services, and in such cases, we may collect your payment information such as your credit card.

Information We Automatically Collect

  • As with most apps and websites, when you use our services we automatically receive and collect information about you and your device.  This information includes the following:
    • Information about your device, such as the operating system, hardware, system version, Internet Protocol (IP) address, device ID, and device language.
    • The specific actions that you take when you use our services, including but not limited to the pages and screens that you view or visit, search terms that you enter, how you interact with our services, and information about your interactions with Brands and other users.
    • The time, frequency, connection type, and duration of your use of our services.
    • Information about your internet, wireless and mobile network connections, such as mobile phone number, service provider, and signal strength.
    • Location information, such as GPS information (described in more detail below).
    • Information regarding your interaction with email messages, for example, whether you opened, clicked on, or forwarded the email message.
    • Identifiers associated with cookies or other technologies that may uniquely identify your device or browser (as further described below).
    • Pages you visited before or after navigating to our website.

Location Information

We and our service providers may collect location information through the services. The type of location information we collect depends on your settings in the device you use to access the services. If you access the services on your mobile device, we may directly collect precise geographic location information and sensor data via Global Positioning System (GPS), cellular network information, and other location-based features. You can turn off direct location collection (or, on some operating systems, continuous direct location collection) through your device settings or by deleting the mobile application from your device. Please note that even if you disable location collection through your device, we still may collect your IP address, which may contain certain limited location information.

Cookies and Analytics

As most websites and mobile applications do, we use analytics partners to collect certain information about how our services are used. We and our analytics partners use cookies, web beacons, and other technologies to receive and store certain types of information whenever you interact with our services through your computer or mobile device. A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the website again, the cookie allows that site to recognize your browser. Cookies may store unique identifiers, user preferences and other information. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some website features or services may not function properly without cookies. We use cookies to analyze and improve our services, to store user preferences, track user trends, and provide relevant advertising to you.
By using our services, you consent to the processing of your information by our analytics partners in the manner and for the purposes set out above. Currently, our analytics partners include, without limitation, Google Analytics. In order to ensure that you understand how our analytics partners handle your information and how they interact with our services, you should visit their privacy policies for more information, as HMCG has no ability to control or monitor our analytics partners’ data collection or data use practices with respect to such information.
At the present time our services do not respond to “Do Not Track” signals or similar mechanisms with the exception of users accessing our services from the EEA or UK. For EEA and UK users, you can manage tracking cookies using our cookie consent banner. Please see our Cookies Policy for further information.

How We Use Your Information

  • In general, we collect information from you so that we can provide our services, operate our business, and provide information that you request from us. This includes the following uses and purposes:
    • Create and administer your account.
    • Provide, operate, improve, maintain, and protect our services.
    • Provide you with technical and other support.
    • Connect you with Brands that you have registered products with, expressed interest in, or we think you may like.
    • Send you services and company updates, marketing communication, and other information about HMCG and our services, and products and services of Brands and other third parties, that we think you may be interested in.
    • Conduct research and analysis, and monitor and analyze trends and usage.
    • Register you for contests or other promotions that we or Brands may offer.
    • Enhance or improve user experience, our business, and our services, including the safety and security thereof.
    • Send you push notifications through our app.
    • Personalize our services to you.
    • Communicate with you and respond to inquiries.
    • Connect users to facilitate return or lost/stolen and found products.
    • Operate our business and perform any other function that we believe in good faith is necessary to protect the security or proper functioning of our services.
    • As necessary to comply with any applicable law, regulation, subpoena, legal process, or governmental request.
    • Enforce contracts and applicable Terms of Service, including investigation of potential violations thereof.
    • Detect, prevent, or otherwise address fraud, security or technical issues.
    • Protect against harm to the rights, property or safety of HMCG, our users, Brands, or the public as required or permitted by law.

How We Share Your Information

  • We do not rent or sell your personal information (any information that identifies you or is identifiable to you).
Like most companies, we share information in certain circumstances with third parties through operation of our services and our business.  Below we explain when that happens.
HMCG is a Data Processor / Service Provider for its Brand Customers
Brands that purchase services from HMCG (“Brand Customers”), and not HMCG, determine how and why personal data submitted to the HMCG service is used, either by or at the direction of such Brands. With respect to such personal information, (1) HMCG is a “data processor” (“Data Processor”) under the EU General Data Protection Regulation (“GDPR”) and a “service provider” under the California Consumer Privacy Act (“CCPA”), and (2) HMCG Brand Customers are the controllers under GDPR (“Data Controller”). This Privacy Policy describes how HMCG processes personal information as a Data Processor for the purpose of providing the HMCG service to our HMCG Brand Customers pursuant to the applicable data processing terms with those Brands.
As Data Controllers, HMCG’s Brand Customers are responsible for disclosing the rights of individuals (“Data Subjects”) with respect to their personal information and other information regarding the collection and use of that personal information, in accordance with the GDPR, CCPA, and other laws requiring such disclosures.
HMCG is a Data Controller for its Brand Customer’s data
HMCG is a Data Controller for the data of Brand Customers that purchase services from HMCG. As a Data Controller, HMCG is responsible for disclosing the rights of its Brand Customers with respect to their information and other information regarding the collection and use of that information, in accordance with the GDPR, CCPA, and other laws requiring such disclosures.
Other Users and Brands
Some of your account information may be publicly visible to users and Brands, and it may be displayed to other users and Brands to facilitate interaction within the services.  When you communicate with other users and Brands, you will provide information and content, to other users and Brands. Similarly, if you register a product through the services, we will share your account information with the applicable Brand.
If you purchase a product from a Brand through our services, we will share information with the Brand as necessary to complete your transaction.  This includes your account information, purchase details, and product information.
Please note that HMCG has no control over how Brands will use your information, which use may include sending you marketing communications.  We encourage you to review each Brand’s privacy policy and all other applicable terms from each Brand prior to registering a product.  We will not disclose your information to a Brand unless you register a product from that Brand.  If you do want us to share your information with a certain Brand, do not register any products from that Brand.
Service Providers
We use third parties to assist us with operating our business and providing our services, such as our technology vendors that help us maintain our services and partners that assist us with our marketing and communication.  These service providers will have access to your information in order to provide services to us.
Payment Processors
If you purchase services from HMCG (excluding any purchases you make from Brands), your credit card or debit card information (such as card type and expiration date) and other financial data that we need to process your payment may be collected and stored by the payment processors with which we work, as well as third party processors that assist us with recurring payment options. We may also collect some limited information, such as your postal code, mobile number, and details of your transaction history. In addition, the payment processors generally provide us with some limited information related to you, such as a unique token that enables you to make additional purchases using the information they’ve stored, including recurring payments, and your card’s type, expiration date, and certain digits of your card number. Other Services
If you sign up or log in to our services through other services such as Apple, Google, or Facebook, link your account on our services with other services from third parties, or share your HMCG account activity with other services, we share your information with those third party services at your direction. Note that when you use other services to sign up or login to our services, we may receive limited information about you from those other services.
As Directed By You and With Your Consent
Except as otherwise provided in this Policy, we share information with companies, organizations or individuals outside of HMCG only at your direction or when we have your consent to do so.  As a reminder, when you register a product or request to connect with a brand through the services, you are directing us to provide your information to the applicable Brand.
Legal Proceedings
We may share information with third party companies, organizations, governmental authorities, or individuals outside of HMCG if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
  • Meet any applicable law, regulation, subpoena, legal process or governmental request;
  • Enforce a contract, including but not limited to any applicable Terms of Service, including investigation of potential violations thereof;
  • Detect, prevent, or otherwise address fraud, security or technical issues; or
  • Protect against harm to the rights, property or safety of HMCG, our users, Brands, or the public as required or permitted by law.

Sale or Merger

We may share information about you as part of a merger or acquisition. If HMCG, Inc. is involved in a merger, asset sale, financing, liquidation or bankruptcy, or acquisition of all or some portion of our business to another company, we may share your information with that company before and after the transaction closes. In such a case, unless otherwise directed by applicable law, your information would remain subject to the terms of the applicable privacy policy in effect at the time of such transfer.

Aggregate Information

We may de-identify or aggregate information so that you are not identified as an individual, and use and provide that information to third parties without restriction. We may also provide aggregate usage information to third parties (or allow third parties to collect that information from you), who may use such information to understand how often and in what ways people use our services, Brand engagement, purchase patterns and habits, just to name a few. However, we never disclose aggregate usage or de-identified information to a third party (or allow a third party to collect such information) in a manner that would identify you as an individual person.

Choices about Your Information

We strive to provide you with choices with respect to your information.  Also remember, you can opt not to disclose certain information to us – but keep in mind some information may be needed to create a HMCG account or to take advantage of some of our services and features.

Modification and Access to Your Information

You can access and modify most of your information through your account.  If you would like to modify or access additional information that is not available through your account, please contact us at support@hmcg.it.  We may ask you to verify your identify or provide additional information before we act on your request.  We may reject or deny requests for certain reasons, such as when we believe a request is fraudulent.
If you are an EEA or UK citizen, you have specific Rights under data protection regulations. HMCG is committed to you being able to freely exercise your Rights. Your Rights include, under certain circumstances, the Right to:
  • Be informed: you have the right to be informed if and how your personal data is being processed.
  • Access, rectification, or erasure: you have the right of access to personal data we hold about you in our records. You are also entitled to have your personal data corrected if it is inaccurate, or to have it erased if we do not have a legitimate reason for retaining your data.
  • To request data portability: for personal data which you have provided to a controller, where processing was based on your consent, or where processing is done by automated means, you have the right to obtain a digital copy of your personal data, request the transfer of your personal data to another company or request to move your data from one IT system to another in a safe and secure way.
  • To request restriction of processing: you have the right to restrict the processing of your personal data where you are contesting the accuracy of that information, you have objected to processing (as described below), or where the processing is unlawful. Where processing is restricted, we are may need to retain sufficient information about you to ensure that the restriction is respected in future.
  • To object to automated decision-making including profiling: you have the right not to be the subject of any automated decision-making or profiling by us.
  • To withdraw consent: in cases where we are relying on your consent for the processing of your personal data, you have the right to withdraw your consent at any time. In respect of the e-marketing we conduct, an unsubscribe (withdraw consent) option is included with every e-marketing communication we send.
  • To object to processing: where your personal data is being processed based on the legitimate interests of a data controller or third party, you have the right to object to that processing.
  • To complain to the relevant supervisory authority: should you have any concerns or complaints regarding the way in which we process your data, please email us directly at support@hmcg.it.

Deleting Your Information or Your Account

You may unsubscribe from HMCG marketing communications at any time by following the “unsubscribe” link at the bottom of any such communication. Most promotional communications will also offer recipients choices about receiving additional messages.

Marketing

You may unsubscribe from HMCG marketing communications at any time by following the “unsubscribe” link at the bottom of any such communication. Most promotional communications will also offer recipients choices about receiving additional messages.

International Transfer

We are based in the United States, and our services are hosted there. If you are using our services from another country, the laws governing our collection and use of information may be different from the laws of your country. By default, if you decide to use our services, or share your information with us, you are agreeing to be governed by the laws of the United States, and agree to the transfer of your information to the United States.
However, at HMCG, we endeavour to take all steps necessary to ensure that there is an appropriate transfer mechanism in place to protect your personal data and comply with our data protection obligations. For EU and UK citizens, please contact us if you want further information on the countries to which we may transfer personal data and the specific mechanism used by us when processing your personal data outside the EEA and UK.

Children

Our Services are not directed at children under 16, and we do not knowingly collect information from children under 16. If you are under 16, please do not attempt to use our services or send any information about yourself to us.  If you are the parent of a child under the age of 16, and you believe he or she has shared information with us, please contact us at support@hmcg.it so that we can remove such information from our systems.

Security of Your Information

We use reasonable security measures, including measures designed to protect against unauthorized or unlawful processing and against accidental loss, destruction or damage to your information.  We also take certain measures to enhance the security of our services, however, since the Internet is not a 100% secure environment, we cannot guarantee, ensure, or warrant the security of any information you transmit to us. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. It is your responsibility to protect the security of your login information.

Retention of Information

We retain information in accordance with applicable laws. The length of time we keep information depends on the type of information and whether we have an on-going business or legal need to retain it (for example, if you have an account with us, or to comply with applicable legal, tax or accounting requirements).

Transactions and Purchases from Brands and Users; Third Party Websites and Services

PLEASE NOTE: Purchases and payment transactions between Brands and users made through or in connection with our services are transactions between the Brands and users only, and not with HMCG or any of our affiliates. We are not the seller of any product or service offered by Brands and are not a party to any payment transaction facilitated through the services for such products or services.  Similarly, we are not responsible or liable for any information shared between you and a Brand or user on our services, nor the content of any communication between you and a Brand or user on our services.
Our services may contain links to other websites and services operated by third parties and may include social media features such as Facebook, Twitter and Pinterest buttons or links. These third-party websites and services may collect information about you if you click on a link or visit those websites or services. Your interactions with these features and third parties are governed by the privacy policy of the third party, not by this Policy.

California Residents

If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information to third parties for the third parties’ direct marketing purposes. With respect to these entities, this Policy applies only to their activities within the State of California. To make such a request, please send an email to shop@hmcg.com.
The California Consumer Privacy Act (“CCPA”) provides consumers with specific rights regarding their Personal Information. Californian residents have the right to request that businesses subject to the CCPA disclose certain information about their collection and use of their Personal Information over the past 12 months. In addition, Californian residents have the right to ask such businesses to delete Personal Information collected from them, subject to certain exceptions. If applicable businesses sell Personal Information, Californian residents have a right to opt-out of that sale. Finally, applicable businesses cannot discriminate against Californian residents for exercising a CCPA right. Similarly, businesses subject to the CCPA must indicate whether they honor “Do Not Track” settings in the browser for California residents.
HMCG does not currently come within scope of the CCPA and therefore adheres to the practices set out in this Privacy Policy. HMCG does not monitor or follow any ‘Do Not Track’ browser requests. Our practices for tracking can be found in our Cookie Policy.

Nevada Residents

Nevada customers can opt out of the sale of their personal information.   We do not sell personal information today, and we do not have plans to sell personal information in the future.   However, Nevada customers have the legal right to opt out of the sale of their personal information, even if their information is not currently being sold.  You may opt out by emailing a request to support@hmcg.it.  In your request, please specify that you wish to “Opt-out of Sale of Personal Information in Nevada.”   Please allow 60 days for a response.

Changes to this Policy

We may make changes to this Policy from time to time. When we do, we will post the updated version on this page. We encourage you to read this page each time that you use our services so that you will be aware of any changes, and your continued use of our services shall constitute your acceptance of any such changes. Changes to this Policy take effect from the date of publication, unless stated otherwise.

Contact Us

If you have any comments, questions, concerns, or suggestions about Policy, or about our privacy practices in general, please contact us at store@hmcg.com.