Privacy

We do not rent or sell your personal information (any information that identifies you or is identifiable to you).

Like most companies, we share information in certain circumstances with third parties through operation of our services and our business.  Below we explain when that happens.

HMCG is a Data Processor / Service Provider for its Brand Customers

Brands that purchase services from HMCG (“Brand Customers”), and not HMCG, determine how and why personal data submitted to the HMCG service is used, either by or at the direction of such Brands. With respect to such personal information, (1) HMCG is a “data processor” (“Data Processor”) under the EU General Data Protection Regulation (“GDPR”) and a “service provider” under the California Consumer Privacy Act (“CCPA”), and (2) HMCG Brand Customers are the controllers under GDPR (“Data Controller”). This Privacy Policy describes how HMCG processes personal information as a Data Processor for the purpose of providing the HMCG service to our HMCG Brand Customers pursuant to the applicable data processing terms with those Brands.

As Data Controllers, HMCG’s Brand Customers are responsible for disclosing the rights of individuals (“Data Subjects”) with respect to their personal information and other information regarding the collection and use of that personal information, in accordance with the GDPR, CCPA, and other laws requiring such disclosures.

HMCG is a Data Controller for its Brand Customer’s data

HMCG is a Data Controller for the data of Brand Customers that purchase services from HMCG. As a Data Controller, HMCG is responsible for disclosing the rights of its Brand Customers with respect to their information and other information regarding the collection and use of that information, in accordance with the GDPR, CCPA, and other laws requiring such disclosures.

Other Users and Brands

Some of your account information may be publicly visible to users and Brands, and it may be displayed to other users and Brands to facilitate interaction within the services.  When you communicate with other users and Brands, you will provide information and content, to other users and Brands. Similarly, if you register a product through the services, we will share your account information with the applicable Brand.

If you purchase a product from a Brand through our services, we will share information with the Brand as necessary to complete your transaction.  This includes your account information, purchase details, and product information.

Please note that HMCG has no control over how Brands will use your information, which use may include sending you marketing communications.  We encourage you to review each Brand’s privacy policy and all other applicable terms from each Brand prior to registering a product.  We will not disclose your information to a Brand unless you register a product from that Brand.  If you do want us to share your information with a certain Brand, do not register any products from that Brand.

Service Providers

We use third parties to assist us with operating our business and providing our services, such as our technology vendors that help us maintain our services and partners that assist us with our marketing and communication.  These service providers will have access to your information in order to provide services to us.

Payment Processors

If you purchase services from HMCG (excluding any purchases you make from Brands), your credit card or debit card information (such as card type and expiration date) and other financial data that we need to process your payment may be collected and stored by the payment processors with which we work, as well as third party processors that assist us with recurring payment options. We may also collect some limited information, such as your postal code, mobile number, and details of your transaction history. In addition, the payment processors generally provide us with some limited information related to you, such as a unique token that enables you to make additional purchases using the information they’ve stored, including recurring payments, and your card’s type, expiration date, and certain digits of your card number.

Other Services

If you sign up or log in to our services through other services such as Apple, Google, or Facebook, link your account on our services with other services from third parties, or share your HMCG account activity with other services, we share your information with those third party services at your direction. Note that when you use other services to sign up or login to our services, we may receive limited information about you from those other services.

As Directed By You and With Your Consent

Except as otherwise provided in this Policy, we share information with companies, organizations or individuals outside of HMCG only at your direction or when we have your consent to do so.  As a reminder, when you register a product or request to connect with a brand through the services, you are directing us to provide your information to the applicable Brand.

Legal Proceedings

We may share information with third party companies, organizations, governmental authorities, or individuals outside of HMCG if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:

• Meet any applicable law, regulation, subpoena, legal process or governmental request;
• Enforce a contract, including but not limited to any applicable Terms of Service, including investigation of potential violations thereof;
• Detect, prevent, or otherwise address fraud, security or technical issues; or
• Protect against harm to the rights, property or safety of HMCG, our users, Brands, or the public as required or permitted by law.