Effective Date: January 22, 2024
LAST UPDATED January 22, 2024
- Sources of Personal Data
- Types of Personal Data We Collect
- How We Use Personal Data
- How We Disclose Personal Data
- Cookies and Other Tracking Technologies
- Data Security and Data Retention
- Children's Privacy
- External Links
- Contact Information / Your Choices
- Data Subject Rights
- Supplemental Information for the U.S.
- Supplemental Information for the EEA, Switzerland and the UK
Hypebeast Hong Kong Limited, together with its subsidiaries and affiliates including those listed in Annex 1 (collectively, "Company" "us," "we," or "our") is committed to protecting the privacy of Personal Data (i.e., information reasonably related to a specific individual). This Privacy Notice describes how we process Personal Data collected through our websites, social media accounts, mobile applications, and other online interactions and communications such as email (collectively, our “Digital Properties”); in-person events, purchases, and other offline interactions; and business-to-business interactions, such as when we interact with the personnel of our business partners, including vendors and business customers (“Business Contacts”).
This Privacy Notice does not apply to information about our own employees, contractors, agents, and job applicants.
Whenever you interact with us on behalf of another individual or entity, such as if you refer a friend to us, you must obtain their consent (or have the legal authority without consent) to share their Personal Data with us.
Changes: We may update this Privacy Notice from time to time. Any updated Privacy Notice will be effective when posted. Please check this Privacy Notice periodically for updates. If required by law, we will contact you directly to provide you with an updated Privacy Notice.
1. Sources of Personal Data
We collect Personal Data about you from the following sources:
- Directly from you. We may collect Personal Data you provide to us directly, such as when you contact us through our Digital Properties, interact with us in person, sign up for offers or newsletters, communicate with us, place or customize orders, or sign up for an account or other services.
- Data collected automatically and through tracking technologies. We may automatically collect information or inferences about you, such as through cookies and other tracking technologies, when you interact with our Digital Properties. This may include information about how you use and interact with our Digital Properties, information about your device, and internet usage information.
- From third parties. We may collect Personal Data from third parties, such as service and content providers, our affiliated companies and subsidiaries, business partners, data brokers, social media companies or other parties who interact with us (including via the HBX Referral Program or affiliate programs for order fulfillment), or, if you are a Business Contact, from a company that employs you.
- From publicly available sources. We may collect Persona Data about you from publicly available sources, such as public profiles and websites.
We may combine and use information and make inferences from information that we receive from the various sources described in this Privacy Notice, including third party sources. We may also use or disclose the combined information and inferences for the purposes identified below.
2. Types of Personal Data We Collect
We may collect the following types of Personal Data about you:
- Identifiers, such as your name, email address, physical address, telephone number, business contact information, and device identifiers (e.g., cookie IDs and IP address).
- Records about you, such as signatures; your physical characteristics if you share your body measurements with us (including height/weight, waist circumference, leg length, and fit preference); payment and delivery details; the content, timing and method of communications you have with us, such as online chats, calls, and emails; and information you share with or upload to our Digital Properties, such as reviews and comments.
- Demographic information, such as age (including birthdates) and gender.
- Commercial information, such as information related to your transactions; products or services purchased, obtained, or considered; subscription information; or other purchasing or consuming histories or tendencies.
- Internet or other electronic network activity information, such as your browsing history, search history, preference information (including marketing and purchasing preferences), account settings (including any default preferences), and other information regarding your interactions with and use of the Digital Properties. For more information about cookies and other device data, please see our Cookies Policy.
- Non-precise geolocation data, such as your location as derived from your IP address.
- Audio, electronic, visual, or other sensory information, such as photographs and audio/video recordings.
- Professional or employment-related information, such as job title, organization, professional affiliations, and other professional information.
- Inferences drawn from any of the information we collect about your preferences or behavior, including to assess the level of interest in our products and services based on frequency of visits and contact and determine your preferred frequency for receiving offers. frequency of visits and contact and determine your preferred frequency for receiving offers.
- Sensitive Personal Data, including the following:
- Social Security number, such as where necessary to provide prizes to contests/sweepstakes winners.
- Precise geolocation.
3. How We Use Personal Data
We may use Personal Data for the following purposes:
- To provide you or your company products and services, such as registering, verifying, and maintaining your account with us; providing and delivering you the goods and services you request, including our rewards programs; providing customer service; processing or fulfilling orders and transactions, including providing payment for our affiliates program; verifying customer information; processing payments; communicating with you about your product, service or subscription; verifying eligibility for certain programs or benefits; soliciting feedback or responding to requests, complaints, and inquiries; and providing similar services or otherwise facilitating your relationship with us.
- For our internal business purposes, such as operating our Digital Properties and customizing the content; maintaining internal business records, such as accounting, document management and other similar activities; enforcing our policies and rules; management reporting; auditing; IT administration of our network, intranet, and other technologies; and IT security management and tasks.
- For our internal research and product improvement purposes, such as verifying or maintaining the quality or safety of our products or services; improving our products or services; designing new products and services; evaluating the effectiveness of our advertising or marketing efforts; and debugging and repairing errors with our systems, networks, and equipment.
- For legal, safety or security reasons, such as complying with legal, reporting, and similar requirements; investigating and responding to claims against us, our personnel, and our customers; for the establishment, exercise or defense of legal claims; protecting our, your, our customers’, and other third parties’ safety, property or rights; detecting, preventing, and responding to security incidents; and protecting against malicious, deceptive, fraudulent, or illegal activity.
- In connection with a corporate transaction, such as if we acquire, or sell or transfer all or a portion of our business or assets including through a sale in connection with bankruptcy and other forms of corporate change.
- For marketing and targeted advertising, such as marketing our products or services or those of our affiliates, business partners, or other third parties (for purposes of this paragraph alone, “we’” or ”our” includes our affiliates, business partners, or other third parties we may be working with to provide marketing). For example, we may use Personal Data we collect to personalize advertising to you on our Digital Properties or third parties’ digital properties; to send you newsletters, surveys, questionnaires, promotions, or information about events; and to conduct and process any contest, raffle sweepstakes, giveaways and/or surveys that we may organize, including to announce the winner of the contest or sweepstakes (as the case may be). You can unsubscribe to our email or text message marketing via the link in the email, texting the word “STOP”, or by contacting us using the information in the Contact Information section below.
We may use anonymized, de-identified, or aggregated information for any purpose permitted by law.
4. How We Disclose Personal Data
We may disclose Personal Data to third parties, including the categories of recipients described below:
- Affiliates and subsidiaries, including parent entities, corporate affiliates, subsidiaries, business units, and other companies that share common ownership.
- Service providers that work on our behalf to provide the products and services you request or support our relationship with you, such as providers that help us generate and collate reviews in relation to our products and services, IT providers, internet service providers, web hosting providers, data analytics providers, and companies that provide business support services, financial administration, or event organization.
- Professional consultants, such as accountants, lawyers, financial advisors, and audit firms.
- Vendors necessary to complete transactions you request, such as shipping companies and logistics providers.
- Other entities in connection with a corporate transaction, such as if we acquire, or sell or transfer all or a portion of our business or assets including through a sale in connection with bankruptcy and other forms of corporate change.
- Business partners that may use Personal Data for their own purposes, such as:
- Advertisers, ad platforms and networks, and social media platforms;
- Brands and other businesses whose products or services we sell or promote through the Digital Properties, or whose ads we allow to be placed on the Digital Properties;
- Commercial data partners to whom we make information available for their own marketing purposes; and
- Partners who work with us on promotional opportunities, including co-branded products and services.
Where required by law, we will obtain your consent prior to disclosing your Personal Data to our business partners. Where recipients use your Personal Data for their own purposes independently from us, we are not responsible for their privacy practices or personal data processing policies. You should consult the privacy notices of those third-party services for details on their practices.
- The Public: There may be opportunities for you to make comments regarding us or our products that we may share with the public, such as comments on our blog posts and reviews on our product pages. Any Personal Data in comments, reviews, or other content that you share in public areas of our Digital Properties may be read, collected, or used by other users or the public.
- Entities to which you have consented to the disclosure.
5. Cookies and Other Tracking Technologies
6. Data Security and Data Retention
We maintain reasonable security procedures and technical and organizational measures to protect your Personal Data against accidental or unlawful destruction, loss, disclosure or use. Your Personal Data will be retained as long as necessary to fulfill the purposes we have outlined above unless we are required to do otherwise by applicable law. This includes retaining your Personal Data to provide you with the products or services you have requested and interact with you; maintain our business relationship with you; improve our business over time; ensure the ongoing legality, safety and security of our services and relationships; or otherwise in accordance with our internal retention procedures. Once you have terminated your relationship with us, we may retain your Personal Data in our systems and records in order to ensure adequate fulfillment of surviving provisions in terminated contracts or for other legitimate business purposes, such as to enable easier future user onboarding, demonstrate our business practices and contractual obligations, or provide you with information about our products and services in case of interest. If you would like to know more about the retention periods applicable to your Personal Data, you can contact us using details provided in the Contact Information below.
7. Children's Privacy
Our Digital Properties are intended for individuals 16 years of age and older. The Digital Properties are not directed at, marketed to, nor intended for, children under 16 years of age. As a general rule, we do not knowingly collect any information, including Personal Data, from children under 16 years of age. If you believe that we have inadvertently collected Personal Data from a child under the age of 16, please contact us at the address in the Contact Information section below, and we will take prompt steps to delete the information.
8. External Links
Our Digital Properties may contain links to external sites or other online services that we do not control, including those embedded in third party advertisements or sponsor information. We are not responsible for the privacy practices or data collection policies of such third-party services. You should consult the privacy notices of those third-party services for details on their practices.
10. Contact Information / Your Choices
If you have questions regarding this Privacy Notice, please contact us at firstname.lastname@example.org.
11. Data Subject Rights
You may have certain rights regarding Personal Data:
- Right to Access/Know. You may have the right to obtain confirmation from us whether we are processing your Personal Data and related information; request information about the categories of Personal Data we have collected about you, the categories of sources from which we collected the Personal Data, the purposes for collecting, selling, or sharing the Personal Data, and to whom we have disclosed your Personal Data and why; or obtain a copy of your Personal Data.
- Right to Data Portability. You may have the right to request to receive your Personal Data that you have provided to us in a structured, commonly used and machine-readable format.
- Right to Rectification/Correction. You may have the right to request that we correct inaccurate Personal Data and to have incomplete data completed.
- Right to Objection. You may have the right to object to the processing of your Personal Data in certain cases.
- Right to Restrict Processing. You may request that we restrict the processing of your Personal Data in certain cases.
- Right to Lodge a Complaint. You may have the right to lodge a complaint with a supervisory authority in the country where you reside or where the conduct that is the subject of the complaint occurred.
- Right to Refuse or Withdraw Consent. In case we ask for your consent to process your Personal Data, you are free to refuse to give it. If you have given your consent, you may withdraw it at any time without any adverse consequences. The lawfulness of any processing of your Personal Data that occurred prior to the withdrawal of your consent will not be affected.
- Right to Not Be Subject to Automated Decision-making. You may have the right to not to be subject to a decision based solely on automated processing and to be given more information about why any such decision was made.
- Subscriptions/Notifications. You can manage your subscriptions and notifications by visiting https://hypebeast.com/subscription.
- Right to Opt Out of Sales/Sharing/Targeted Advertising. You may have the right to opt out of (i) the sale or sharing of your Personal Data and (ii) targeted advertising.
If you are located in the EEA, you may exercise these rights by visit the GDPR Data Request webform. If you are located in the U.S., you may exercise the any of the rights available to you via our webform, or emailing us at email@example.com with the subject line: “Privacy Request: [insert first name, last initial]”. If you are located in any other jurisdiction, please email us at firstname.lastname@example.org with the subject line “Attention: Personal Data Access / Correction / Deletion Request”.
We will not discriminate against you for exercising your privacy rights.
Nevada residents: please contact us at email@example.com to inquire about your right to opt out of the sale of your Personal Data.
Verification: In order to process rights requests, we may need to obtain information to locate you in our records or verify your identity depending on the nature of the request. In most cases we will collect some or all of the following data elements: first name and last initial; date of birth (month/day) if you provided it to us; details of the last activity that you conducted on our Digital Properties (for example, if you last made a purchase, details of that purchase such as date, value, item(s) purchased); and the email address used to conduct your activity on our Digital Properties. In some cases, we may request different or additional information, including a signed declaration that you are who you say you are, and will inform you if we need such information.
Authorized Agents: Authorized agents may exercise rights on behalf of you by submitting a request via email to firstname.lastname@example.org with the subject line “Attention: Authorized Agent Privacy Rights Request” and describe the rights you are seeking to exercise. We may require the agent to demonstrate authority to act on behalf of you by providing signed permission from you. We may also require you to verify your own identity directly with us or to directly confirm with us that you provided the authorized agent permission to submit the request.
Appeal: If we deny your rights request, you may have the right to appeal. To submit an appeal, email@example.com. We will inform you in writing our response to your appeal.
12. Supplemental Information for the U.S.
In addition to the disclosures above, this section provides supplemental information about how we process Personal Data.
Disclosure of Personal Data
We engage in routine practices with our Digital Properties involving third parties that could be considered a sale of Personal Data or sharing of Personal Data for targeted advertising, as those terms are defined under applicable laws. . We do not knowingly sell or share for targeted advertising any Personal Data of minors under the age of 16. Below please find a chart detailing the categories of Personal Data we collected and with whom it was sold, shared, or disclosed for a business purpose in the past 12 months.
|Categories of Personal Data We Collect
|Categories of Third Parties With Whom We Disclose Personal Data for a Business Purpose
|Categories of Third Parties to Whom Personal Data is Sold or Shared for Targeted Advertising
|Identifiers (Section 2.A)
|Records about you (Section 2.B)
|Demographic information (Section 2.C)
|Commercial information (Section 2.D)
|Internet or other electronic network activity (Section 2.F)
|Geolocation data (Section 2.G)
|Audio, electronic, visual, or other sensory information (Section 2.H)
|Professional or employment-related information (Section 2.I)
|Inferences (Section 2.K)
|Sensitive personal information (Section 2.L)
Sensitive Personal Data
We only use Sensitive Personal Information for the following purposes: (i) performing services or providing goods reasonably expected by an average consumer; (ii) detecting security incidents; (iii) resisting malicious, deceptive, or illegal actions; (iv) ensuring the physical safety of individuals; (v) for short-term, transient use, including non-personalized advertising; (vi) performing or providing internal business services; (vii) verifying or maintaining the quality or safety of a service or device; or (viii) for purposes that do not infer characteristics about you.
We offer programs, benefits, and other offerings to consumers related to the collection, retention, or sale of Personal Data that may be deemed a “financial incentive” or “price or service difference” under applicable law. Examples of the programs we offer include:
- Surveys: We may offer our customers opportunities to participate in surveys. In exchange for participation you may be offered a financial incentive, such as a discount or a coupon. As part of these surveys we may collect Personal Data, such as your name, preferences, experiences, beliefs, opinions, and other responses to the survey questions. We estimate that the value of your Personal Data is the value of the offer presented to you. We calculated the value by using the expense related to the offer.
- Limited-Time Promotions or Sweepstakes: From time to time, we may offer incentives limited to a specific time period, such as limited-time sweepstakes, contests and other promotions. In exchange for your participation you may be offered a financial incentive, such as a product giveaway. As part of these limited-time promotions or sweepstakes, we may collect your Personal Data, such as your name, email address, and phone number. We estimate that the value of your Personal Data is the value of the incentive divided by the number of entrants. We calculated the value based on the total program cost.
- One-Time Promotions: We may also offer you one-time coupons, discounts, or other promotions, such as when you provide us your email address and agree to receive marketing emails in exchange for a single-use coupon. We estimate that the value of your Personal Data is the value of the offer presented to you. We calculated the value by using the expense related to the offer.
- Referrals: We may offer you the opportunity to refer or introduce to us another consumer, such as when you provide a friend’s email address, phone number or other contact information in exchange for a discount or rewards points. We estimate that the value of the Personal Data is the value of the offer presented to you. We calculated the value by using the expense related to the benefit. As a reminder, whenever you share another person’s information with us, you must obtain their consent (or have the legal authority to share their information with us without consent).
- Rewards Programs: We may offer you the opportunity to participate in our rewards programs, such as HBX Pro. In exchange for benefits such as free shipping and product discounts, we may ask you to sign up with the program and provide information such as your name, email address, and purchase or transaction history. We estimate that the value of the Personal Data is the value of the offer presented to you. We calculated such value by using the expense related to the benefit.
We may offer these programs at our discretion. Participation in our promotional programs is always optional, and you can terminate program participation at any time as explained in the applicable program terms. You can also contact us at firstname.lastname@example.org to unsubscribe or cancel your participation in any program.
California Shine the Light: If you are a California resident, you may opt out of sharing your Personal Data subject to California Civil Code §1798.83 (the “Shine the Light law”) with third parties for those third parties’ direct marketing purposes. Please contact us at email@example.com if you would like to do so.
California Eraser Law: Any California residents under the age of eighteen (18) who have posted content or information on our Digital Properties can request removal by contacting us at firstname.lastname@example.org, detailing where the content or information is posted, and attesting that you posted it. We will make reasonable, good faith efforts to remove the post from prospective public view or anonymize it so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, third parties may have republished or archived content that we do not control.
13. Supplemental Information for the EEA, Switzerland and the UK
The following terms supplement the above disclosures with respect to our processing of EEA, Swiss, and UK Personal Data, and only apply to the extent that EEA, Swiss, or UK data protection laws apply to our processing of your Personal Data. To the extent applicable, in the event of any conflict or inconsistency between the other parts of the Privacy Notice and the terms of this Section 12, this Section 12 shall govern and prevail with regards to the processing of such EEA, Swiss and UK Personal Data.
Unless otherwise specified, Hypebeast Hong Kong Limited, a body corporate doing business in the Hong Kong Special Administrative Region of the People’s Republic of China, is the controller of your Personal Data.
Legal Bases for Processing
We process the following categories of personal data for the following processing purposes based on the following legal bases:
|Categories of personal data
|To provide you products and services (Section 3.A)
|For our internal business purposes (Section 3.B)
|For our internal research and product improvement purposes (Section 3.C)
|For legal, safety or security reasons (Section 3.D)
|In connection with a corporate transaction (Section 3.E)
|For marketing and targeted advertising (Section 3.F)
International Transfers of Personal Data
Due to the global nature of our operations, some of the recipients mentioned in the How We Disclose Personal Data section of this Privacy Notice may be located in countries outside the EEA, Switzerland or the UK that do not provide an adequate level of data protection as defined by data protection laws in the EEA, Switzerland and the UK. Certain third countries have been officially recognized by the European Commission, Switzerland, and the UK Secretary of State as providing an adequate level of protection. Transfers within our corporate group or to third parties located in third countries that have not received such recognition take place using an acceptable data transfer mechanism, such as the EU and/or UK Standard Contractual Clauses, Binding Corporate Rules, approved Codes of Conduct and Certifications, on the basis of permissible statutory derogations, or any other valid data transfer mechanism issued by the EEA, Swiss or UK authorities.
Please reach out to us using the contact information in the Contact Information section above if you want to receive further information about how we transfer Personal Data or, where available, a copy of the relevant data transfer mechanism.
Data Protection Officer
We have appointed a DPO for purposes of the GDPR. The contact details for our DPO are as follows:
Hypebeast UK Limited (Ref: GDPR), 85 Great Portland Street, First Floor, London, W1W 7LT
Hypebeast Hong Kong Limited has designated Hypebeast UK Limited as its representative in the EU, whose registered address is at Squire Patton Boggs (UK) LLP (Ref: GDPR), Rutland House, 148, Edmund Street, Birmingham, B3 2JR.
Hypebeast Hong Kong Limited, with its registered address at Hypebeast Hong Kong Limited, 40/F, Cable TV Tower, No.9 Hoi Shing Road, Tsuen Wan, Hong Kong
Hypebeast Inc., with its registered address at 9 East Loockerman Street Suite 311, Dover, DE 19901, County of Kent, USA