HaphiT Global E+Photonics Solutions

HaphiT understands the importance of privacy. This Privacy Notice (“Notice”) describes how HaphiT uses, discloses, and otherwise processes the personal data described in this Notice, as well as the rights and choices individuals have regarding such personal data.

1. SCOPE

Except as otherwise noted below, this Notice applies to the personal data that HaphiT processes related to:

Users of our websites where this Notice is posted, including www.haphit.com and www.haphit.net (each a “Site” and together the “Sites”), the services we provide through the Sites, and any downloadable software, applications, and other products and services provided by us that display or include a link to this Notice (collectively, the “Services”);

Current, former and prospective customers, vendors and partners;

Individuals who are subscribed to receive news, information and marketing communications from us;

Individuals who register for or participate in our webinars and other events;

Individuals who communicate with us or otherwise engage with us related to our Services.

Individuals who participate in surveys, contests and research conducted by us; and

This Notice does not apply to the personal data that we collect and process related to our employees, personnel, job applicants, and candidates, or to any information that is exempt under applicable privacy laws.

Additional Notices. Additional or supplemental notices and disclosures (each an “additional notice”) may be provided and will apply to certain personal data collected and processed by us. Generally, we provide additional notices in order to clarify our privacy practices in specific circumstances and provide you with additional information about certain processing activities. To the extent there is a conflict with this Notice, the additional notice will control with respect to the personal data subject to that additional notice.

Your use of our Sites and Services, and any dispute over privacy, is subject to this Notice and our applicable terms of service.

2. PERSONAL DATA WE COLLECT

The actual personal data we collect, and how we use it, varies depending upon the nature of our relationship and interactions with you. Also, in some cases (such as where required by law), we ask for your consent or give you certain choices prior to collecting or using certain personal data.

Information Provided Directly. We collect personal data (including where necessary and subject to applicable law and where required with your explicit consent, special categories of personal data (as defined under applicable privacy laws)) that you provide to us, our affiliates or share on the Sites, including related to:

Registration: If you create a login account on any of our Sites that offer this option, we collect certain personal data from you, such as your name, business address, email address, phone number, company name, and job title; where the account registration is related to a purchase through our online store, we also collect billing address and shipping address;

Customer service and support: When you contact us for support or other customer service requests, we maintain support tickets and other records about your requests and related communications. For example, where you use one of our support request forms, we collect details about you, including your name, contact details, state and region, company, request type, request details you provide, your preferred contact, product name and serial number;

Communications: If you contact us by email, mail, phone, chat or otherwise regarding our products or the Services, we collect and maintain a record of name and contact information, contact details, your communications and our responses, including a transcript of the communication and any information (including attachments) you may provide to us. If you call us, we may also record calls and maintain logs and records of those calls;

Transactions and billing information: We also collect personal data about you in connection with a purchase or payment you submit to us. This may include collection of your name, shipping and billing address, credit card and other payment information, and other transaction details. If you use our online shop(s), we may also maintain transactional records about your past purchases, as well as items that you view or add to your online shopping cart; and

Events and other information: We also collect personal data related to your participation in our events as well as other requests that you submit to us related to our Services. For example, if you register for or attend an event that we host or sponsor, we may collect data related to your registration for and participation in such event. When you fill out a ‘Contact Us’ form, sign up for our mailing lists, or otherwise request information from us, we collect and maintain records of your requests. When you complete a survey, we collect personal data about you, including your responses.

Personal Data Collected Automatically. We may collect personal data about how you use our Services and your interactions with us and others, including information we collect automatically (e.g., using cookies and pixel tags), as well as information we derive about you and your use of the Services. Such information includes:

Device and browser information: we use cookies, log files, pixel tags and other technologies to automatically collect information when users access or use our Services, such as IP address, general location information, domain name, browser type, device type, device ID, internet service provider, referring and exiting URLs, operating system, language, clickstream data, and similar device and usage information. We may also collect or derive location information about you, such as through your IP address.

Usage data: we also collect activity information related to your use of our Sites and Services, such as information regarding what pages you accessed and when, date and time of your visit, the links clicked, searches, features used, items viewed, and time spent within the Services. We may also use pixels in HTML emails to understand if individuals read or open the emails we send to you.

Personal Data Collected from Third Parties. We may also collect certain personal data from third parties, such as:

Third-party platforms: Social networks or other platforms (such as Facebook, Twitter, LinkedIn or other third-party social network sites) that you may connect with or share information about us through, or when you log in to our Services using your login information and your username, personal profiles, and the actual social media networks you used. These third-party platforms and services control the personal data they collect and share about you. For information about how they may use and disclose your personal data, including any data you make public, please consult their respective privacy policies; and

Prospective customer information: We may receive lead and prospect information from third parties about prospective customers that may be interested in our Services. We may also engage with third parties to enhance or update our customer information.

Anonymous and Aggregate Data. We use anonymous and aggregate data (i.e., data that is no longer reasonably linked or linkable to an identified or identifiable natural person, household, or personal or household device) related to our business and the Services.

3. LEGAL BASES FOR COLLECTING AND PROCESSING PERSONAL DATA

Certain data protection laws, including the General Data Protection Regulation (“GDPR”), certain countries’ data protection laws, require that we inform you of the legal bases for our processing of your personal data. Pursuant to such data protection laws (where applicable), we process personal data generally for the following legal bases:

Performance of contract: The processing is necessary to perform a contract with you or take steps to enter into a contract at your request;

Compliance with law: The processing is necessary for us to comply with a relevant legal obligation (for example, laws which require us to collect tax information from customers, carry out checks on customers, or which compel us to disclose information to public authorities or regulators);

Our legitimate interests: The processing is in our legitimate interests, subject to your interests and fundamental rights, and notably our legitimate interest in using applicable data to conduct and develop our business activities, such as developing and maintaining relationships with our customers. Where we rely on our legitimate interests as a lawful basis for processing, we take steps to ensure that our legitimate interests are not outweighed by any prejudice to data subject rights and freedoms. This is achieved in a number of ways, including the application of principles of data minimization and security, and by taking steps to ensure that personal data is collected where it is relevant to the lawful business activities, and where using personal data is reasonably necessary for those activities;

Defend our rights: Where the processing is necessary to the establishment, exercise or defense of legal claims; and

With your consent: Where you have consented to the processing (for example, where we are required by local law to rely upon your prior consent for the purposes of direct marketing).

4. PURPOSES FOR COLLECTING AND PROCESSING PERSONAL DATA

The purposes for which we collect, use, disclose and otherwise process personal data vary depending upon the circumstances. Generally, we process personal data for the business and commercial purposes described below:

Services and support: To operate the Sites and Services, including to communicate with you about your use of the Services, provide troubleshooting and technical support, respond to your inquiries and requests, fulfill your orders and requests, process your payments, for customer support purposes, and to carry out our obligations arising from our contracts with you;

Communications: To seek your views or comments on the products or Services we provide and send you communications by post or e-mail, which you have requested or that may be of interest to you, including newsletters, or promotions of our products or Services or events, and to notify you of changes to our products and Services;

Research and analytics: To measure the adequate performance of our interactions with you, improve our Services, for our internal purposes, and for other research and analytical purposes;

Customization and personalization: To tailor content we may send or display on our Sites, including to offer location customization and personalized help and instructions, and to otherwise personalize your experiences;

Marketing and advertising: To promote our products and services on third-party websites, as well as for direct marketing purposes, including to send you newsletters, alerts and information we think may interest you;

Planning and managing events: For event planning and management, including registration, attendance, connecting you with other event attendees, and contacting you about relevant events and Services;

Legal proceedings and obligations: To obtain or maintain insurance coverage, manage risks or obtain professional advice and defend our rights and establish, exercise and defend our legal claims;

Account administration: Facilitate your use of your web account on the Site;

Security and protection of rights: To provide, create and maintain a trusted and safe environment and comply with our legal obligations. For example, to protect our Sites, Services and our business operations; to prevent, detect and investigate fraud, misuse, harassment or other types of unlawful activities; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of this Notice and our applicable agreements and terms of use; and

General business and operational support: To consider and implement mergers, acquisitions, reorganizations, and other business transactions, and where necessary to the administration of our general business, accounting, recordkeeping and legal functions.

Anonymous and Aggregate Data. We use anonymous and aggregate data related to our business and the Services, for research, analytics, development and other purposes.

5. DISCLOSURE OF PERSONAL DATA

In general, we may disclose and make available personal data to third parties as described in this section:

HaphiT Entities: HaphiT Entities are a global group of companies. As such, we may disclose personal data to the HaphiT Entities as part of our business operations and administration of our Sites and Services;

Processors and service providers: We may disclose personal data to third-party processors (including contractors and service providers) who perform services on our behalf. For example, we use third-party processors to provide us with technical support, payment processing, and to perform analytics and other work that we may need to outsource. These processors are bound by law and/or contract to protect the confidentiality of and to implement adequate security measures to protect your personal data. They only process your personal data to provide us with requested services and only act on our documented instructions;

Vendors and business partners: We may also disclose your personal data to other companies, vendors and business partners that perform certain functions for us. These companies are themselves responsible for determining the purposes and/or means of the processing and for the lawfulness of the processing. They include insurance companies, online gateway payment providers, including credit card companies, and banks;

Third-party platforms and services: We may disclose or make available personal data to third-party platforms and providers that we use to provide or make available certain features or portions of the Services, or as necessary to respond to your requests. In some occasions, payments are managed by third parties that will act as separate controllers and will provide you appropriate information on your personal data processing;

Marketing, advertising and analytics providers: We may disclose certain information that includes personal data to third-party ad network providers, sponsors and/or traffic measurement services, who may use this data to improve and measure the effectiveness of our ads and those of third parties. We may also engage third party analytics companies to collect information about Site usage in order to help us to understand how users access and use the Services, to improve our Services and other products and offerings, and for other research and analytical purposes;

In support of our legal and compliance obligations: We may disclose your personal data to others where such disclosure is necessary for compliance with a legal obligation to which we are subject insofar as reasonably necessary for these purposes and as permitted by law, whether in court proceedings or in an administrative or out-of-court procedure;

In connection with a business transaction: We may disclose your personal data in connection with a business transaction (such as a merger, acquisition, restructuring, or transfer of assets), to buyers, their lawyers or professional advisors, where needed to affect the sale or transfer of business assets (such as a merger or acquisition) including related to due diligence conducted prior to such event, where permitted by law; and

Security and protection of rights: We may disclose personal data where we believe it is necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our terms of use and other agreements, to respond to claims asserted against us, or as evidence in litigation in which we are involved. We may also share personal data where necessary in order to protect your vital interests or the vital interests of another natural person, or where we believe necessary to protect the Services, our business operations and our rights, such as to prevent and detect fraud, unauthorized activities and access, and other misuse.

Aggregate and Anonymous data. We may also disclose aggregate and anonymous data related to our business and the Services, subject to applicable laws.

6. COOKIES, ADVERTISING AND TRACKING

We and our third-party providers use cookies, clear GIFs/pixel tags, JavaScript, local storage, log files, and other mechanisms to automatically collect and record information about your browsing activities, and use of the Sites and Services. We may combine this “usage data” with other personal data we collect about you.

Cookies: These are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Sites, while others are used to enable a faster login process or to allow us to track your activities while using our Sites. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Some of the Services may not work properly if you disable cookies.

Pixels (sometimes referred to as tags, pixel tags or clear GIFs) and other technologies: These are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, pixels are embedded invisibly on web pages. We may use pixels (also referred to as web beacons, web bugs or pixel tags) in connection with our Services to, among other things, track the activities users of our Services, help us manage content, and compile statistics about usage of our Services. We and our service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

Advertising and Targeting. We work with third parties, such as ad networks, channel partners, mobile ad networks, analytics and measurement services and others (“third-party ad companies”) to personalize content and display advertising on our Sites and Services, as well as to manage our advertising on third-party sites, mobile apps and online services. We and these third-party ad companies may use cookies, pixels tags, and other tools to collect activity information on our Sites (as well as on third-party sites and services), as well as IP address, location information, device ID, cookie and advertising IDs, and other identifiers. We and these third-party ad companies use this information to provide you more relevant ads and content on our Sites and on third-party sites and apps, and to evaluate the success of such ads and content.

Third-Party Analytics. We may use third-party analytics tools to evaluate use of our Services. We use these tools to help us understand use of, and to improve, our Services, performance, ad campaigns, and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services.

Do Not Track (DNT). Our Sites currently do not respond to Do Not Track signals. You may, however, disable certain tracking mechanisms in the cookie preference settings of your web browser and opt out of certain third-party ad cookies on our Sites.

7. THIRD-PARTY LINKS AND SERVICES

Our Sites may provide links to third-party websites, such as social networking sites. HaphiT has no control over such third-party websites and is not responsible for the privacy practices of such parties. Please note that we are not responsible for the availability of such third-party sites, and do not endorse and are not responsible or liable for any content, advertising, products or other materials on or available from such websites. Haphit is not liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any content, advertising, products, or other materials on or available from such websites. We encourage you to review the privacy policies of these third-party sites.

8. RETENTION OF PERSONAL DATA

We retain your personal data for as long as reasonably necessary to fulfil the purposes for which we collected it (as described in this Notice), and we may also retain your personal data for an additional period of time where necessary to comply with our legal obligations or to establish, exercise or defend our legal rights (including to respond to actual or potential legal claims).

9. YOUR PRIVACY RIGHTS AND CHOICES

Access, Deletion and Correction. You may submit a request to us to access, correct or delete personal data by contacting our Data Privacy Coordinator. We will process your request in accordance with applicable privacy and data protection laws. We may ask you for additional information so that we can confirm your identity or process your request.

Direct Marketing. You may always opt out of our direct marketing emails by clicking the unsubscribing link contained in our marketing or promotional emails or by contacting us as set out below. We may continue to send you transactional or service-related communications, such as service announcements and administrative messages, as far as allowed by applicable laws.

10. SECURITY

We have implemented physical, technical and organizational measures intended to protect the personal data that we process. However, no environment or security procedures or protocols are ever guaranteed to be 100% secure or error-free.

11. PRIVACY OF CHILDREN

Our Sites are not designed for, or directed at, children under the age of 16 and we do not knowingly collect personal data from individuals in this age group. If you believe we have inadvertently collected personal data about a child, please contact us and we will take steps to delete this data.