Privacy Policy

Shenzhen Howinn Technology Limited (“Howinn”, “us”, “we”, or “our”) operates the Services (as defined herein).    

This Privacy Policy (“Policy”) pertains to the collection, processing, use, or /and disclosure of personal data when you use the Service, and the choices you can make as to that data.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

1. Definitions

Services

“Services” means services operated by Howinn, including the howinn.com website.

Personal Information / Personal Data

“Personal Information” or “Personal Data” are used interchangeably in this Privacy Policy, and include information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device; they do not include publicly available information from government records or deidentified or aggregated consumer information.

Usage Data

Usage Data is data collected automatically either generated by the use of the Services or from the Services infrastructure itself (for example, the duration of a page visit).

Cookies

Cookies are small text files that websites place on your device as you are browsing, and which may include an anonymous unique identifier. In some cases, cookies may be used to track an individual’s online activity, e.g., so that the individual can be targeted with specifically-tailored ads. 

2. Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

Personal Data

While using our Services, we may ask you to provide us with certain data that may constitute Personal Data, including, but not limited to:

  • name/company name

  • nationality

  • email address

  • phone number

  • subject matter

  • usage data

  • cookies

Usage Data

When you access the Services, we may automatically collect certain information about your device, including, but not limited to, the type of device, unique identifiers associated with your device, IP address, operating system, browser type and version, diagnostic data, and others (“Usage Data”).

Cookies and Tracking Data

We use cookies and similar tracking technologies to track the activity on our Services, which we then store. We may also use other tracking technologies such as beacons, tags, and scripts to collect and track information and to improve and analyze the performance of our Services. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Services. Examples of cookies we use include:

  • Session Cookies. We use Session Cookies to operate our Service.

  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.

  • Security Cookies. We use Security Cookies for security purposes.

Use of Data

Howinn uses collected data for various purposes, including:

  • to provide and maintain our Services;

  • to notify you about changes to our Services;

  • to allow you to participate in interactive features of our Services when you choose to do so;

  • to provide customer support;

  • to improve our Services;

  • to monitor the usage of our Services; and

  • to detect, prevent, and address technical issues.

3. Transfer of Data

To the extent permitted by law, your information, including Personal Data, may be transferred to—and maintained on—computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.  

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to any such transfer.

Howinn will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless permitted by law and there are adequate controls in place for the security of your data and other personal information.

4. Disclosure of Data

Legal Requirements

Howinn may disclose your Personal Data in the good faith belief that such action is necessary to (1) comply with a legal obligation or competent government regulation; (2) protect and defend our rights or property; (3) prevent or investigate possible wrongdoing in connection with the Services; (4) protect the personal safety of users of the Services or the public; or (5) protect against legal liability.

5. Security of Data

The security of your data is important to us, and we follow all legal requirements and use commercially acceptable means to safeguard the security of your data. However,no method of data transmission or storage can be 100% secure, so we cannot guarantee the absolute security of your Personal Data.

6. Service Providers

We may employ third party companies or/and individuals to facilitate our Services (“Service Providers”), such as to provide the Services on our behalf, provide services on which the Services rely, assist with developing and maintaining the Services, or assist us in analyzing how our Services are used. These Service Providers will have access to your Personal Data only as required to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

7. Links to Other Sites

Our Services may contain links to other sites that are not operated by us. If you click a third-party link, you will be directed to that third party’s site. We do not control the practices of third parties, and their sites and services are governed by their own privacy policies and terms and conditions, which you should review. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

8. Minors

Our Services are not available to anyone under the age of 18 (“Minor”).

We do not knowingly collect personally identifiable information from any Minors. If you are a parent or guardian and you are aware that your Minor child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Minor children, we will take steps to remove that information from our systems.

9.Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the “right to know”). Once we receive your written request and confirm your identity (see Exercising Your Rights to Know or Delete), we will disclose to you:

  • The categories of personal information we collected about you.

  • The categories of sources for the personal information we collected about you.

  • Our business or commercial purpose for collecting or selling that personal information.

  • The categories of third parties with whom we share that personal information.

  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: sales, identifying the personal information categories that each category of recipient purchased; and disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained. 

  • The specific pieces of personal information we collected about you (also called a data portability request).

10. Right to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) 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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, 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 other applicable laws or regulations, such as 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.

  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

11. Exercising Your Rights to Know or Delete

To exercise your rights to know or delete described above, please submit a request to us using the information in the Contact Us section below.

Only you, or someone legally authorized to act on your behalf, may make a written request to know or delete related to your personal information. To designate an authorized agent, please submit an original notarized authorization to our mailing address along with your request. 

You may only submit a request to know twice within a 12-month period, if such restriction is permitted by law. Your request to know or delete must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include: government-issued identification, or student identification.

  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

You do not need to create an account with us to submit a request to know or delete. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.

For instructions on exercising your sale opt-out or opt-in rights, see Personal Information Sales Opt-Out and Opt-In Rights.

12. Response Timing and Format

We will confirm receipt of your request within ten (10) business days or any shorter timeframe required by law. If you do not receive confirmation within such timeframe, please contact us at the information provided below.

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt, or any shorter timeframe required by law. If we require more time as permitted by law, we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

13. Personal Information Sales Opt-Out and Opt-In Rights

You have the right to direct us to not sell your personal information at any time (the “right to opt-out”). Consumers who opt-in to personal information sales may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by contacting us at the information provided below. 

Once you make an opt-out request, we will wait at least twelve (12) months, or longer period as required by law, before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by contacting us.

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

14. Non-Discrimination

We will not discriminate against you for exercising any of your legal rights. Unless permitted by law, we will not:

  • Deny you goods or services.

  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

  • Provide you a different level or quality of goods or services.

  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by law that can result in different prices, rates, or quality levels. Any legally permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time. 

15. Your Rights Under California’s “Shine the Light” Law

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us at the information provided below.

16. Canada Privacy Rights

Consumers in Canada have the following rights as provided under the Personal Information Protection and Electronic Documents Act (“PIPEDA”):

  • You may ask us about the personal information about you that we hold, how and where we obtained that information, and how that information is or has been used and to whom it has been disclosed.

  • You may request a copy of your personal information. 

  • You may correct or amend personal information in cases where accuracy and completeness is deficient.

Please note that we may deny access to personal information if any of the following situations apply:

  • the information is protected by solicitor-client privilege or the professional secrecy of advocates and notaries or by litigation privilege;

  • to do so would reveal confidential commercial information;

  • to do so could reasonably be expected to threaten the life or security of another individual;

  • the information was collected for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province;

  • the information was generated in the course of a formal dispute resolution process; or

  • the information was created for the purpose of making a disclosure under the Public Servants Disclosure Protection Act or in the course of an investigation into a disclosure under that Act.

We endeavor to substantively respond to a verifiable consumer request within thirty (30) days of its receipt. If we require more time (up to another 30 days), we will inform you of the reason and extension period in writing.

17. EU Privacy Rights

If you are in the EU, you have the following rights under the General Data Protection Regulation (“GDPR”):

  • You may request access to your personal data.

  • You may request the rectification or correction of your personal data 

  • You may request the erasure of personal data.

  • You may request restrictions on the processing of your personal data.

  • You may object to the processing of your personal data.

  • You have the right of data portability.

  • You may withdraw your consent for the processing of your personal data.

To exercise any of these rights, please contact us using the contact information provided below. 

In addition, you have the right to lodge a complaint with a supervisory authority regarding our policies and practices.

18. To Make a Request

To make any request above, please submit it in writing, along with a copy of a government-issued identification, to us at the email or mail address in the Contact Us section below.

19. Changes to This Privacy Policy

We may update our Privacy Policy from time to time by publishing an updated version here. 

20.Contact Us

If you have any questions about this Privacy Policy, or if you would like to contact us to exercise any of your rights under this Privacy Policy, we may be reached as follows:

By email: info@howinn.com

By visiting this page on our website: http://www.Howinn.com

Privacy Policy for Howinn