PRIVACY POLICY

1. OVERVIEW

HYTTO PTE. LTD. (“we”, “us”, or “our”) respects your privacy and is committed to protect the Personal Data (as defined herein) we hold about you. If you have questions, comments, or concerns about this Privacy Policy (“Privacy Policy”) or our processing of Personal Data, please see the bottom of this Privacy Policy for information about how to contact us. We are the data controller of the personal data collected, and are responsible for the processing of your Personal Data.

RealSize is a website offering products information and service for Lovense RealSize Condoms (the “RealSize Website” or the “Services”). Please review the following to understand how we process and safeguard your Personal Data. By using any of our Services, whether by visiting our website or otherwise, and/or by voluntarily providing Personal Data to us, you acknowledge that you have read and understand the practices contained in this Privacy Policy. This Privacy Policy may be revised from time to time, so please ensure that you check this Privacy Policy periodically to remain fully informed.

Warning: The RealSize website may contain or be used to transmit sexually explicit material that is intended for individuals 18 years of age or older. If you are under the age of 18, if such material offends you, or if it is illegal to view such material in your jurisdiction, do not continue.

BY USING OUR WEBSITE, PURCHASING OUR PRODUCTS, OR USING OUR SERVICES, YOU ARE CONSENTING TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND OUR COLLECTION AND USE OF PERSONAL INFORMATION AS OUTLINED BELOW. IF YOU DO NOT AGREE TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICES.

2. SCOPE OF THE PRIVACY POLICY

This Privacy Policy governs all personal data collected by and provided to us and must be adhered to by all persons who access, use, process, control or otherwise deal with personal information on our behalf. This policy applies to visitors to our website and app, individuals, representatives of individuals, or individuals that sign up to use our Services, as well as individuals who provide us with personal information via using or accessing our Services.

If you provide us with information about another person (if, for example, you are a representative of an individual), you must provide the other person with a copy of this Privacy Policy and let the other person know that we use their personal information in the ways set out in this Privacy Policy.

3. PERSONAL DATA WE MAY COLLECT

We collect personal data of an identified or identifiable individual and in this Privacy Policy, personal data means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual (“Personal Data”). These individuals are sometimes referred to as data subjects. In addition, we may collect data that is not identifiable to you or otherwise associated with you, such as aggregated data, and is not Personal Data. To the extent this data is stored or associated with Personal Data, it will be treated as Personal Data; otherwise, the data is not subject to this Privacy Policy.

The type of Personal Data we collect about you depends on your interactions with us and your use of the Services. Generally, we collect the below categories of Personal Data related to the Services from our users:

• Identifiers such as a real name, alias, postal address, internet protocol address, email address, account name, ID number, social security number, driver’s license number, passport number, or other similar identifiers.
• Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
• Biometric information provided by you through certain service provided by us, such as RealSize condoms size quiz.
• Internet or other electronic network activity information, including, but not limited to, user content, browsing history, search history, and information regarding a user’s interaction with an internet website, application, or advertisement.
• Audio, electronic, visual, thermal, olfactory, or similar information.
• Data collected by Lovense related software and shared with this website with the data subject’s license.

We will not collect additional categories of Personal Data other than those categories listed above. If we intend to collect additional categories of Personal Data, we will provide you with a new notice at or before the time of collection.

4. HOW WE COLLECT YOUR PERSONAL DATA

We collect your Personal Data from the following categories of sources:

• Directly from you. When you provide it to us directly to open an account and use the Services, or when you update the information in your account.
• Automatically or indirectly from you. For example, through and as a result of your use of and access to the Services, we also collect IP addresses and browser types from the devices you use.
• From third party sources. From time to time, we may receive personal information about you from third party sources (including from service providers that help us run marketing campaigns or competitions and our partners who help us provide the Services). In all cases, we will only receive such data where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us.

5. LEGAL BASIS FOR PROCESSING PERSONAL DATA

We process Personal Data for, or based on, one or more of the following legal bases:

• Performance of a Contract. By using the Services, you have contracted with us through the Terms and Conditions or others listed in our Services, and we will process certain Personal Data to perform under that contract.
• Legitimate Interests. We may process your Personal Data for our legitimate interests, including complying with any applicable law, rule or regulation, investigation or remedy; enforcing our Terms and Conditions or other contracts binding with you for your using our Service; protecting our, our users’ or others’ rights, property and safety; and detecting and resolving any fraud or security concerns.
• Compliance with Legal Obligations and Protection of Individuals. We may process Personal Data to comply with our legal obligations, including as required by valid legal process, governmental request, and to protect those individuals who use our Services and others.
• You have given us permission to do so, including but not limited to registering online or place an order for any of our products or services, voluntarily completing a customer survey or provide feedback on any of our message boards or via email, or using or viewing our website via your browser’s cookies.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details below.

6. WHY WE COLLECT YOUR PERSONAL INFORMATION

We strive to ensure that the Services can be enjoyed by every user, and to keep the Service appropriate, high-quality and lawful. To do that, we collect and process your Personal Data for the following business and commercial purposes:

• Developing, improving, operating, providing, predicting, or performing, including maintaining or servicing accounts, enhancing the Services and your experience with them, providing customer service, processing or fulfilling transactions, verifying your identity, and processing payments.
• Communicating with you by email and text about the Services, verifying your identity, responding to support inquiries or, sharing information about the Services.
• Auditing related to a current interaction with the user and concurrent transactions.
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
• Debugging to identify and repair errors that impair existing intended functionality.
• Undertaking internal research for technological development and demonstration.
• Undertaking activities to verify or maintain the quality or safety of the Services owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the Services owned, manufactured, manufactured for, or controlled by us.
• Complying with applicable laws, regulations, rules and requests of relevant law enforcement and/or other governmental agencies, or for other purposes, as permitted or required by law.
• Enforcing our Terms and Conditions, End User License Agreement and other usage policies.
• As necessary or appropriate to protect the rights, property, and safety of our users, us, and other third parties.

We will not use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you with notice and obtaining your consent.

7. WHOM WE SHARE YOUR PERSONAL DATA WITH

Our Company is not in the business of selling your Personal Data. Maintaining the privacy of your Personal Data is a vital part of our relationship with you and an important aspect of the Services that we provide. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below:

• Business Transfers. As we develop our business, we might sell or buy businesses or assets, including Personal Data. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.
• Agents, Consultants, and Third Parties. The Company, like many businesses, sometimes contracts other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases, and processing payments. When we employ another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function. Additionally, we reserve the right to use third party analytics service providers and advertising partners to collect personally identifiable information about your online activities over time and across different websites when you use our Services, including details as described in this Privacy Policy. Furthermore, we partner with third parties to provide certain support services to our users. We try to limit how these third parties can use the information they gather from you or that we provide. The processing and storage of any and all information you may provide to any of such third parties, including information they may collect from you, is not governed by this Privacy Policy. You will need to review the Privacy and Cookie Policy of such third party on their websites and accept separately if necessary.
• Legal Requirements. The Company may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of the Company, (iii) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (iv) protect against legal liability.

9. HOW WE PROTECT YOUR PERSONAL DATA

We use reasonable and appropriate physical, technical, and organizational safeguards designed to promote the security of our systems and protect the confidentiality, integrity, availability, and resilience of your Personal Data. Those safeguards include: (i) the encryption of Personal Data where we deem appropriate; (ii) taking steps to ensure Personal Data is backed up and remains available in the event of a security incident; (iii) periodic testing, assessment, and evaluation of the effectiveness of our safeguards; and (iv) permitting only the authorized personnel to access the Personal Data on a need-to-know basis.

In addition, we limit access to your personal information to employees, agents, contractors and other third parties who have a business need for access. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

However, no method of safeguarding information is completely secure. While we use measures designed to protect Personal Data, we cannot guarantee that our safeguards will be effective or sufficient. In addition, you should be aware that Internet data transmission is not always secure, and we cannot warrant that information you transmit utilizing the Services is or will be secure.

If we have reason to believe that there is a breach affecting Personal Data in our possession or under our control has occurred, we will conduct, in a reasonable and expeditious manner, an assessment of whether the breach of Personal Data will result in significant harm to you and if so, we will notify you.

10. RETENTION OF YOUR PERSONAL DATA

We will retain your personal information for the period necessary to fulfil the purposes outlined in this Privacy Policy and in each case in accordance with applicable legal and regulatory requirements in respect of permitted or required retention periods and limitation periods relevant to legal action.

When we no longer need to use your Personal Data, we erase it from our systems and files or anonymize it so that it no longer identifies you.

11. YOUR RIGHTS REGARDING PERSONAL DATA

You have certain rights regarding the collection and processing of Personal Data according to relevant legislations, including but not limited to EU General Data Protection Regulation (GDPR), California Consumer Privacy Act of 2018, Singapore Personal Data Protection Act 2012 and etc. You may exercise these rights, to the extent they apply to you, by contacting us at the information provided at the end of this Privacy Policy, or by following instructions provided in this Privacy Policy or in communications sent to you.

Your rights vary depending on the laws that apply to you, but may include:

(a) The right to know whether, and for what purposes, we process your Personal Data;

(b) The right to be informed about the Personal Data we collect and/or process about you: You have the right to obtain clear, transparent, understandable and easily accessible information on how we use your Personal Data and on your rights;

(c) The right to learn the source of Personal Data about you we process;

(d) The right to know with whom we have shared your Personal Data with, for what purposes, and what Personal Data has been shared (including whether Personal Data was disclosed to third parties for their own direct marketing purposes);

(e) The right to access, modify, and correct Personal Data about you: We strive to maintain the accuracy of any Personal Data collected from you, and will try to respond promptly to update our records when you tell us the information in our records is not correct. However, we must rely upon you to ensure that the information you provide to us is complete, accurate, and up-to-date, and to inform us of any changes. Please review all of your information carefully before submitting it to us. Any updates or corrections to your information may be made through your account settings.

• The right of access: You have the right to access the Personal Data we hold about you (subject to certain restrictions). We may require payment of a reasonable fee taking into account the administrative costs incurred in providing the information which the written estimate of fee will be provided. Any request to access that is for information that cannot be found, trivial or that is otherwise frivolous or vexatious will not be addressed. To exercise your right of access, please contact us using the contact details below.
• The right to rectification: You have the right to demand that your Personal Data be rectified if they are inaccurate or out of date and/or completed if they are incomplete. To exercise your right to rectification, please contact us at the contact details below. If you have an account, it may be easier to modify your own data via the “My Account” function.

(f) The right to erasure/right to be forgotten: In certain cases, you have the right to obtain the erasure or deletion of your Personal Data. This is not an absolute right, as we may be required to keep your Personal Data for legal or legitimate reasons. If you would like us to erase your data, please contact us using the contact details below.

(g) The right to oppose commercial prospecting, including profiling: You can unsubscribe or oppose the receipt of our commercial prospecting messages at any time. Simply click on the “unsubscribe” link in any email or communication we send you. You can also contact us using the contact details below. If you wish to object to profiling, please contact us using the contact details below.

(h) The right to withdraw consent at any time for data processing based on consent: You can withdraw your consent to the processing of your data if this processing is based on consent. The withdrawal of this consent does not affect the lawfulness of the processing based on the consent made before the withdrawal thereof. We invite you to consult the sections “What Personal Information We Collect” and “Legal Bases for Processing Personal Information” to find out if our processing is based on consent. If you wish to withdraw your consent, please contact us using the contact details below.

(i) The right to object to data processing based on legitimate interest: You can object to the processing of your data at any time when the processing is based on legitimate interest. We invite you to consult the table inserted in the sections“What Personal Information We Collect” and “Legal Bases for Processing Personal Information” to find out whether our processing is based on legitimate interest. If you wish to exercise your right to object, please contact us at the contact details below.

(j) The right to data portability: You have the right to move, copy or transmit the data concerning you from our database to another. This only applies to the data you have provided, where the processing is based on your consent or on a contract and is carried out using automated processes. We invite you to consult the sections “What Personal Information We Collect” and “Legal Bases for Processing Personal Information” to find out whether our processing is based on a contract or on consent. For more information, please contact us using the contact details below.

(k) The right to restriction of processing: You have the right to request the limitation of the processing that we carry out on the data concerning you. This right means that the processing of data concerning you which we carry out is limited, so that we can keep this data, but not use or process it. This right applies in specific circumstances provided for by the GDPR, namely:

• the accuracy of the Personal Data is contested by the data subject (i.e. you), for a period allowing the controller to verify the accuracy of the Personal Data;
• the processing is unlawful and the data subject (i.e. you) opposes their erasure and instead demands that their use be restricted;
• the data controller no longer needs the Personal Data for the purposes of processing but these are still necessary for the data subject for the establishment, exercise or defense of legal rights;
• the data subject (i.e. you) has objected to the processing based on the legitimate interests pursued by the controller during the verification as to whether the legitimate reasons pursued by the controller prevail on those of the person concerned.

If you wish to obtain restriction of processing, please contact us at the contact details below.

(l)The right to deactivate cookies: You have the right to deactivate Cookies. Internet browser settings are usually set to accept cookies by default, but you can easily change this by changing your browser settings. Many cookies are used to improve the ergonomics and operation of the website, therefore disabling cookies may prevent you from using certain parts of this site. If you wish to restrict or block all cookies that are placed by our website (which may prevent you from using certain parts of the site), you can do so by going to your browser settings. The Help function of your browser can tell you what to do.

12. YOUR CHOICES

You have choices about certain information we collect about you, how we communicate with you, and how we process certain Personal Data. When you are asked to provide information, you may decline to do so; but if you choose not to provide information that is necessary to provide some of our Services, you may not be able to use or access those Services. In addition, it is possible to change your browser settings to block the automatic collection of certain information.

(a) Communications Opt-Out: You may opt out of receiving email communications from us at any time by following the opt-out link or other unsubscribe instructions provided in any email message received, by contacting us as provided at the end of this Privacy Policy, or by changing your notification preferences in account settings. If you wish to opt out by sending us an email to the address provided below, please include “Opt-Out” in the email’s subject line and include your name and the email address you used to sign up for communications in the body of the email. Note, that if you do business with us in the future, you may not, subject to applicable law, opt out of certain automated notifications, such as order or subscription confirmations, based on business transactions (e.g., e-commerce).

(b) Location Information: If you want to limit or prevent our ability to receive location information from you, you can deny or remove the permission for certain Services to access location information or deactivate location services on your device. Please refer to your device manufacturer or operating system instructions for instructions on how to do this.

(c) Cookies and Web Tracking: Consult our Cookie Policy for more information about how to control and/or opt out of certain web tracking technologies.

13. CHILDREN’S PRIVACY

Our Services are intended for a general audience, and are not directed at children under 18 years of age (the “Age Limit”). We do not knowingly collect information from children under the Age Limit. By using the Services, you represent that you are 18 years of age or older. If you are under the Age Limit, please do not use the Services and do not provide us with your personal information. If you are a parent or guardian and you are aware that an individual (of whom you are a parent or guardian) under the Age Limit has provided us with personal information, please contact us. We will, upon notice or discovery, take all reasonable efforts to erase or destroy any personal information that may have been collected or stored by us about that individual.

14. HOW TO MAKE A COMPLAINT

We take your privacy concerns seriously. We invite you to contact us at the contact details below before submitting any complaint to the competent data protection authority. We will confirm receipt of your complaint and, if we believe necessary, we will open an investigation. If an investigation has been opened following a complaint made by you, then we will contact you with the result as soon as possible. In the unlikely circumstances we are unable to resolve your complaint to your satisfaction, you may lodge a complaint with the data protection authority in your jurisdiction.

15. THIRD-PARTY SERVICES

We may obtain other information, including personal information, from third parties and combine that with information we collect through our website. For example, we may have access to certain information from a third-party social media or authentication service if you log into our services through such a service or otherwise provide us with access to information from the service. Any access that we may have to such information from a third-party social media or authentication service is in accordance with the authorization procedures determined by that service. By authorizing us to connect with a third-party service, you authorize us to access and store your name, email address(es), current city, profile picture URL, and other personal information that the third-party service makes available to us, and to use and disclose it in accordance with this Policy. You should check your privacy settings on these third-party services to understand and change the information sent to us through these services.

16. OTHER IMPORTANT INFORMATION ABOUT PERSONAL DATA AND THE SERVICES

(a) Payment Information: Payments on this website (if there are any) are processed by third-party payment providers. For example, when you make a payment that is processed by a payment provider, you will provide that third party with your credit card number, credit card expiration date, and security code, which they process and store subject to their privacy policy and terms and conditions. We do not receive your full credit card number, credit card expiration date, or the security code. Instead, the payment provider provides us with a “token” that represents your account, your card’s expiration date, card type and the first two and last four digits of your card number. If you are required to provide your name and email address to the payment provider, then they also provide us with that information.

(b) Business Transfer: We may, in the future, sell or otherwise transfer some or all of our business, operations or assets to a third party, whether by merger, acquisition or otherwise. Personal data we obtain from or about you via the Services may be disclosed to any potential or actual third-party acquirers and may be among those assets transferred.

(c) Do Not Track: We currently do not use any cross-site tracking technologies and do not currently process or comply with any web browser’s “do not track” signal or similar mechanisms. Note, however, that you may find information about how to block or reject certain tracking technologies in our Cookie Policy.

(d) International Use: Your Personal Data may be transferred to, and stored, processed in, countries other than the country in which you are a resident. By your use of the Services, you acknowledge that we may transfer your data to, and store your Personal Data in, the above countries, which the protection of such Personal Data given is of a standard comparable to the protection under the applicable personal data protection laws of your country. Such Personal Data may also become accessible as permitted by law in the above countries, including to law enforcement and/or national security authorities in those countries. We will take appropriate safeguards to ensure that your personal information will remain protected in accordance with this Privacy Policy and applicable data protection laws.

(e) Jurisdiction specific term: Specific laws, including but not limited to EU General Data Protection Regulation and California Consumer Privacy Act of 2018, may apply to you or to us as a result of your specific location. If this is the case, and if those laws are inconsistent with any part of the Privacy Policy, those laws will prevail to the extent of the inconsistency.

17. MODIFICATIONS AND UPDATES TO THIS PRIVACY POLICY

We maintain the right in our absolute discretion from time to time modify, alter, and/or update this Privacy Policy, and any such modifications, alterations, or updates will be effective upon our posting of the revised Privacy Policy. Your continued use of the Services following our posting of any revised Privacy Policy will constitute your acknowledgement of the amended Privacy Policy.

18. CONTACT US

If you have any questions about this Privacy Policy, our privacy practices or if you would like to make a request about any personal information we may hold about you, including correction of personal information and making a complaint, please contact us by email [email protected]