Hoox Privacy Policy
Last Revised: February 2025
This policy sets forth how HOOXPAY INC. ("we", "our" or "HOOX") collects and uses your information when you visit our website, available at www.hooxpay.com (the "Website").
Respect for the privacy of your personal information is extremely important to us. When you browse our Website, we collect certain information, some of which can be used to personally identify and/or locate you (“Personal Information”).
The Personal Information We Collect
When you use the Website, Personal Information about you will be collected as follows:
Information you provide. When you book a demo, we collect your name, email address, the name of the company you work for and the content of your inquiry. Please use discretion when deciding which information to share with us as part of your demo booking request.
Information Collected from your Device. We may collect information from your device through cookies or other analytics tools. Such information may include your IP address, the time and date of your access to the Website, and information which relates to your activity on the Website. This information will not directly identify you.
For the avoidance of doubt, if we combine Personal Information with Non-personal Information, the combined information will be treated as Personal Information as long as it remains combined.
How we Use Your Personal Information
HOOX will use the Personal Information collected through the Website as follows:
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To contact you regarding the demo you requested and provide you with the requested demo;
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To improve our Website;
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To investigate and resolve disputes in connection with your use of the Website;
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To detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardize or negatively affect the integrity of the Website; and
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To investigate violations and enforce our policies, and as required by law, regulations or governmental authority, or to comply with a subpoena or similar legal process or respond to a government request, or to comply with our contractual obligations.
Third Parties we Share Your Personal Information with
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We will share your information with our service providers who assist us with the internal operations of the Website, such as our website design service provider, in order to operate our Website and manage our business. These service providers 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.
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We will share your information with competent authorities, legal counsels, and advisors, if you abuse your rights to use the Website or violate any applicable law while engaging with us. We will do so in order to respond to, handle, and mitigate suspected violations of law in connection with our business.
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We will share your information with competent authorities if a judicial, governmental, or regulatory authority requires us to disclose your information. We will do so in order to comply with any binding request we receive from a competent authority.
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We will share your information with the target entity of a merger or acquisition, and legal counsels and advisors, if the operation of the Website or our business is organized within a different framework, or through another legal structure or entity. We will do so in order to enable a structural change in the operation of the Website or our business.
Cookies and Related Technologies
Cookies are small data files that are placed on users’ devices or browsers to monitor how users interact with websites and other online services. Cookies can be used to identify your IP address, browser type, domain name, specific web pages through which you click, etc.
HOOX and our service providers only use cookies that are essential for the operation of the Website, as further explained here.
Most web browsers allow you to erase cookies on your computer, block cookies from your computer, or notify you when a cookie is stored on your computer. If you choose to disable or otherwise block certain cookies, you may be unable to use, or experience decreased functionality of, parts of the Website.
International transfer
Since we operate globally, it may be necessary to transfer data, including Personal Information, to jurisdictions outside your country. In these instances, we will transfer your data only in accordance with and based on the safeguards provided by applicable law, including (where relevant) adequacy decisions or standard data protection clauses adopted by the European Commission.
Information Retention
We retain the information that we collect from you for as long as necessary to operate the Website and maintain our customer relations with you. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we may keep records containing your Personal Information, our communications with you, and any other information required by applicable laws and regulations.
We may rectify or remove incomplete or inaccurate information, at any time and at our own discretion.
Data Security
HOOX protects the Personal Information it collects via the Website with reasonable and appropriate physical, electronic, and procedural measures. We use advanced encryption technologies to keep your data and information safe in transit (using HTTPS with RSA 2048 bit key and a signature algorithm of SHA256 with RSA) and at rest (data is encrypted using AES-256 encryption algorithm). We might also use other services to collect your banking information, making sure those service providers use TLS for all information exchanges. To take advantage of TLS, your browser must support up-to-date encryption protection, as found in the latest versions of most common browsers, such as Microsoft Edge, Mozilla Firefox, Google Chrome, and Safari.
Your privacy rights
As a user of our Website, 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 data that is collected and processed when you use the Website. Our offices are located at 1065 SW 8th st., Miami FL 33130, the United States.
Legal basis for processing your personal data. We process your personal data based on the following legal basis:
Purpose or Scenario
Legal Basis
Booking a demo
Our legitimate interest in establishing and maintaining our customer relations with you
Cookies and Analytics
For essential cookies, our legitimate interest in developing and enhancing our business and the Website.
For non-essential cookies, your consent.
Sharing your data with our service providers
Our legitimate interest in the operation of the Website 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 Website and our business
Our legitimate interest in our business continuity.
Data subject rights. If you are in the EEA or the UK, subject to exemptions provided by law, and with proper identification, you may have the following rights in relation to your Personal Information:
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Right to verify your Personal Information (to access, change or update any Personal Information relating to you. For example, if you believe that your Personal Information is incorrect, you may ask to have it corrected);
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Right to see what Personal Information about you we have;
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Right to request that we erase Personal Information about you ("right to be forgotten") under certain circumstances, such as when you object to our processing of your Personal Information based on our legitimate interest and there are no overriding legitimate grounds for the processing. However, notwithstanding such a request, we may still process your Personal Information if it is necessary to comply with our legal obligations, or for the establishment, exercise, or defense of legal claims. If you wish to exercise any of these rights, please contact us through the channels listed in this Policy;
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Right to restrict us from processing Personal Information pertaining to you (except for storing it): (a) if you contest the accuracy of the Personal Information (in which case the restriction applies only for a period enabling us to determine the accuracy of the personal information); (b) if the processing is unlawful and you prefer to restrict the processing of the Personal Information rather than requiring the deletion of such data by us; (c) if we no longer need the Personal Information for the purposes outlined in this Policy, but you require the Personal Information to establish, exercise or defend legal claims; or (d) if you object to our processing based on our legitimate interest (in which case the restriction applies only for the period enabling us to determine whether our legitimate grounds for processing override yours);
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Right to object to our processing of your personal information based on our legitimate interest. However, we may override the objection if we demonstrate compelling legitimate grounds, or if we need to process such personal information for the establishment, exercise, or defense of legal claims.
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Right to withdraw your consent to processing your personal information, easily and at any time, if the basis for our processing is your consent. We may continue to process personal information with respect to which your consent is not necessary. Withdrawing your consent will not affect the lawfulness of the processing we carried out based on your consent before such withdrawal; and
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Right to export Personal Information in a portable format.
If you wish to exercise any of these rights, contact us at: privacy@hooxpay.com. When handling your request, we will ask for additional information to confirm your identity (which may include Personal Information). Please note that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements. If we are not able to provide you with the information that you have asked for, we will explain the reason.
If you wish to raise a complaint on how we have handled your Personal Information, please contact us directly at privacy@hooxpay.com.
If you are not satisfied with our response or believe we are collecting or processing your Personal Information not in accordance with the laws, you can file a complaint to the applicable data protection authority. If you are in the EU, then according to Article 77 of the GDPR, you can lodge a complaint to the supervisory authority, in the Member State of your residence, place of work, or place of an alleged infringement of the GDPR. For a list of supervisory authorities in the EU, click here. If you are in the UK, you can lodge a complaint to the Information Commissioner’s Office (ICO) pursuant to the instructions provided here.
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 Website. 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, email address.
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Directly from you.
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Through the device you use to access our Website.
Additional information about you
Content of demo request.
Professional or employment-related information
Name of employer.
Internet or other electronic network activity information
Information about the device you use to access the Website, 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
Additional information about you
Professional or employment-related information
Internet or other electronic network activity information
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Performing services through the Website.
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Debugging to identify and repair errors that impair existing intended functionality.
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Detecting and preventing security incidents.
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Undertaking activities to verify or maintain the quality or safety of the Website and to improve, upgrade, or enhance the Website.
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
Additional information about you
Professional or employment-related information
Internet or other electronic network activity information
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Our service providers, who will use it only as necessary to assist us in the internal operations of our business and the Website, and not for their own promotional purposes.
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Competent authorities, legal counsels, and advisors if you abused your rights to use the Website or violated any applicable law in the course of doing business with us.
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Judicial, governmental, or regulatory authority if they require us to disclose your information
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Target entity of a merger or acquisition, legal counsels, and advisors If the operation of the Website 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.
Changes to this Policy
This Privacy Policy may change from time to time. We will post any policy changes on this page. You are encouraged to check for the latest policy often. Each version of this Privacy Policy will be identified at the top of the page by its effective date.
Contacting us
If you have any questions about this Privacy Policy or concerns about the way we process your Personal Information, please contact us by e-mailing us at privacy@hooxpay.com.
The details of HOOX are as follows:
HOOXPAY INC
Our data protection officer may be contacted by email at: privacy@hooxpay.com