Hoox Privacy Policy
What Happens When Using Our Service
Introduction
Last Revised: February 2025
Welcome to Hoox! Hoox is a Customer Activation Platform for management of dynamic, personalized, real-time and measurable incentives for consumers. Our simulator, available at https://merchant-simulator.hooxpay.com/ (the "Simulator") allows you to simulate the process of providing rewards from your organization to the organization's end-customers, using Hoox. The Simulator was developed and is owned and operated by HooxPay Inc. (the "Company", or "we", "us", "our").
This Privacy Policy (“Policy”) explains how we process your information on the Simulator.
The Simulator is not intended for use by users under the age of 16. We do not knowingly collect or process information about children under the age of 16 or knowingly allow minors under the age of 16 to use the Simulator.
This Policy may be amended from time to time. We will post any change to this Policy on our Simulator at a reasonable time in advance of the effective date of the change.
Contact us
If you have any questions, comments or concerns regarding this Policy or the processing of your personal information on the Simulator, please contact us by email privacy@hooxpay.com
What personal information is collected and why
Scenario | Purposes | Categories of information processed |
|---|---|---|
Requesting a simulation | Providing you with the functionality of the Simulator; our business development | Your name, email address, mobile phone number and the name of the company you work for. Please note that we will use your email address or phone number to provide you with the requested simulation and contact you with further business offers. |
You do not have a legal obligation to provide the above Information; however, if you choose to not share this information with us, we will not be able to provide you with the requested simulation.
Methods and sources for collecting your personal information
We collect the personal information from several sources:
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Directly from you when you use the Simulator.
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Through the device you use to access our Simulator.
We will not share your information with third parties, except in the events listed below or when you provide us your explicit and informed consent.
Sharing your personal information
Scenario | Purposes | Third parties involved |
|---|---|---|
If the operation of the Simulator or our business is organized within a different framework, or through another legal structure or entity | Enabling a structural change in the operation of the Simulator and our business | The target entity of the merger or acquisition, legal counsels, and advisors. |
If a judicial, governmental, or regulatory authority requires us to disclose your information | Complying with a binding request from a competent authority | Competent authorities |
If you abused your rights to use the Simulator or violated any applicable law while engaging with or us | Responding to, handling, and mitigating suspected violations of law in connection with our business | Competent authorities, legal counsels, and advisors |
We will share your information with our service providers who assist us with the internal operations of the Simulator. These companies are authorized to use your personal information in this context only as necessary to provide these services to us and not for their own promotional purposes | Operating the Simulator and managing our business | For list of 3rd parties contact us at privacy@hooxpay.com |
We retain your information for as long as needed to operate the Simulator, and thereafter as needed for record-keeping matters, but no longer than 5 years.
We will retain your information for as long as needed to operate the Simulator. Thereafter, we will still retain your personal information as necessary to comply with our legal obligations, resolve disputes, establish, and defend legal claims and enforce our agreements. However, we will not retain your data for more than five years.
We implement measures to secure your information
We implement measures to reduce the risks of damage, loss of information and unauthorized access or use of information, such as HTTPS with RSA 2048 bit key and TLS. We also never store full payment card numbers or banking credentials on our Simulator.
However, these measures do not provide absolute information security. Therefore, although efforts are made to secure your personal information, there is no guarantee that it will be immune from information security risks.
Data retention and security
Your rights
As a user of our Simulator, you have the following rights in relation to your personal information:
Right to review your information. You have the right to review, either by yourself or through an authorized representative or a guardian, any information we have stored about you in our databases.
Right to request to rectify your information. If, upon reviewing your information, you find your information to be incorrect, incomplete or outdated, you have the right to ask us to rectify your information or delete it. We will inform you within 30 days whether we can comply with your request.
Right to have your personal data deleted, under certain circumstances, such as when the information is no longer necessary for the purposes the information was collected.
Additional Information for Individuals in EEA And UK
Data Controller. HooxPay Inc. is the controller of your personal information processed on the Simulator. Our offices are located at 1065 SW 8th st., Miami FL 33130, the United States.
International data transfers. To facilitate processing your information through the Simulator and by our service providers, we will transfer your information to and within countries such as the United States and Israel. We do so under an adequacy decision or under the terms of a data transfer agreement which contains standard data protection contract clauses with adequate safeguards determined by the EU Commission and the UK Information Commissioner’s Office.
Legal basis for processing your personal data. We process your personal data based on the following legal basis:
Purpose or Scenario | Legal Basis |
|---|---|
Requesting a simulation | Our legitimate interest in providing you with the requested function of the Simulator and our business development. |
Sharing your data with our service providers | Our legitimate interest in the operation of the Simulator and our business. |
Responding to, handling, and mitigating suspected violations of law in connection with our business | Our legitimate interest in defending and enforcing against violations and breaches that are harmful to our business. |
Complying with a binding request from a competent authority | Our legitimate interest in complying with mandatory legal requirements imposed on us. |
Enabling a structural change in the operation of the Simulator and our business | Our legitimate interest in our business continuity. |
Additional Information for Individuals in The United States
HooxPay Inc. is providing the following additional information to its clients residing in the United States, pursuant to applicable state privacy laws in the U.S.
We do not sell your information to any third party, or share it for cross-context behavioral advertising. Furthermore, we do not collect, use or share sensitive information.
We keep the personal information specified below as long as necessary to operate the Simulator. Following that period, we shall see to it that the information is not accessed, other than in extraordinary events such as legal claims.
Categories of personal information we collect and process and their sources
Below are the categories of personal information we have collected and/ processed over the past 12 months, and the source of that information.
Categories of personal information | Details of the personal information that was collected | Sources of information |
|---|---|---|
Identifiers | Name, mobile phone, email address. | 1. Directly from you. 2. Through the device you use to access our Simulator. |
Professional or employment related information | Company name | |
Internet or other electronic network activity information | Information about the device you use to access the Simulator, such as your IP address, time and date of access, type of browser used, language used, etc. |
Business purposes for the collection of personal information
Categories of personal information (per the table above) | Business purposes |
|---|---|
Identifiers Professional or employment related information Internet or other electronic network activity information | 1. Performing services through the Simulator. 2. Debugging to identify and repair errors that impair existing intended functionality. 3. Detecting and preventing security incidents. 4. Undertaking activities to verify or maintain the quality or safety of the Simulator and to improve, upgrade, or enhance the Simulator. |
Disclosures to third parties
Below are the categories of personal information we shared with third parties over the past 12 months, and the categories of third-party entities we share them with.
Categories of personal information (per the table above) | Categories of entities we give the information to, and why |
|---|---|
Identifiers Professional or employment related information Internet or other electronic network activity information | - Our service providers, who will use it only as necessary to assist us in the internal operations of our business and the Simulator, and not for their own promotional purposes. - Competent authorities, legal counsels, and advisors if you abused your rights to use the Simulator or violated any applicable law in the course of doing business with us. - Judicial, governmental, or regulatory authority if they require us to disclose your information - Target entity of a merger or acquisition, legal counsels, and advisors If the operation of the Simulator or our business is organized within a different framework, or through another legal structure or entity. |
Your rights
The right to know. You have the right to know whether we are processing your personal information. If we do, you have the right to know the following information, which we will provide to you after we receive your request and verify your identity:
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The categories of personal information we collected about you.
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The categories of sources from which the personal information was collected.
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The purposes for which we collect personal information.
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The categories of third parties with whom we share personal information.
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The specific pieces of personal information we collected about you.
The right to obtain a copy of your personal information. If your data is available in a digital format, you have the right to obtain a copy of the personal information that you previously provided to us, in a portable and readable format (to the extent this is technically feasible).
The right to delete your personal information. In some cases, state privacy laws provide for the right to request the deletion of your personal information.
The right to correct inaccurate personal information. Once we receive a request from you to correct your data, and verify your identity, we will examine the veracity of the corrected information provided by you, consider your request to correct, and inform you of our decision.
To establish the veracity of the personal information as per your request, we will consider all the circumstances pertaining to the personal information the correction of which is requested. We may also require you to provide documentation in support of your request to correct the personal information.
The right to opt-out of processing for solely-automated profiling. You have the right to opt-out of solely-automated processing of your personal information to evaluate, analyze, or predict your personal aspects related to your economic situation, health, personal preferences, interests, reliability, behavior, location, or movements, where that processing is done in furtherance of a decision that produces a legal or similarly significant effect on you.
The right to non-discrimination as a result of exercising your rights. You have the right to not be discriminated against by us for exercising the rights granted to you under applicable law. If you exercise your rights, we cannot:
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deny you services.
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charge different prices or fees for services, also through discounts, benefits, or fines.
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provide you with a different level or quality of services.
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propose that you receive different prices or tariffs for services.
Please note that we may charge a different fee or provide a different level or quality of services, if the difference is reasonably related to the value we gain from your personal information.
Filing requests
Should you wish to exercise your rights under applicable laws as specified above, please contact us by email at privacy@hooxpay.com
To verify your identity, we will ask you to provide additional information, through a verification process in which you will be asked to provide us with two items of information known to you and to us.
Note you may appoint an authorized agent to file requests to exercise your rights on your behalf. To this end, you must provide your authorized agent with written approval to do so. The authorized agent will have to present us with proof, attesting that you authorized them to act on your behalf. Furthermore, we will require verification of your identity, as explained above.
Our response to your requests
We will respond to your requests within 45 days (or within 90 days, where the law permits and we determine it necessary considering the complexity and number of the requests you have filed). If we take longer than 45 days, we will inform you of the extension within the initial forty-five-day response period, together with the reason for the extension.
We may deny your request in the following cases:
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If we believe in good faith, based on reasons which are documented in writing, that your request is fraudulent or is an abuse of your rights under applicable law.
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If we conclude that the request is irrelevant, based on all the circumstances at issue (e.g., if you requested to correct your personal information, and we find that it is likely to be accurate).
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If it is contrary to federal or state law.
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Due to discrepancy in the required documentation.
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If the fulfilment of your request turns out to be impossible or involves disproportionate effort.
We will provide you with a detailed explanation including sufficient facts to enable you to meaningfully understand why we cannot fulfil your request.
You may appeal our decision to deny your request by submitting a written appeal to privacy@hooxpay.com .