PRIVACY NOTICE

Data privacy is of high importance for Hockerty and we want to be open and transparent with our processing of your personal data.

We therefore have a policy setting out how your personal data will be processed and protected.

Why do we use your personal data?

We will use your personal data to manage your purchase online at Hockerty by processing your orders and returns via our online services and send you notifications of delivery status or in the event of any problems with the delivery of your items.

We will use your personal data to send you informative and promotional communications exclusively related to the group / service offered by Hockerty.

We will use your personal data to manage your payments.

We will also use your data in order to handle complaints and warranty matters for products.

Your personal data is being used to identify you and to validate your legal age for shopping online and to confirm your address with external partners.

We will use photographs you voluntarily upload to provide you with our Virtual Try-On feature, which generates an image showing how a garment would look on you. Your photograph is processed solely for this purpose and is not used for any other reason, including training of artificial intelligence models.

What kind of personal data do we process?

We will process the following categories of personal data:

• contact information such as name, address, e-mail address and telephone number
• task profile information
• order information
• purchase history
• photographs and images uploaded for the Virtual Try-On feature, and the virtual try-on images generated from them

Who has access to your personal data?

Your personal data that is forwarded to third parties, is only used to provide you with the services mentioned above, companies to validate your address, communication agencies to send you order confirmation, warehouse and distribution suppliers in connection with the delivery of your order. Payment service providers for your payment.

Please be aware that many of these recipient companies have an independent right or obligation to process your personal data.

We never pass, sell or exchange your personal data with third parties outside the Hockerty Group. Data sent to third parties will only be used to provide you with our services. We will detail the categories of third parties that access your data for each specific processing activity.

Transfer of your personal data

Your information, including Personal Data, is processed at the Company's operational offices and at any other location where the parties involved in the processing are located. This means that this information may be transferred to others and held on other computers located outside your state, province, country or other governmental jurisdiction where data protection laws may differ from those in your jurisdiction.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to such transfer.

Hockerty will take all steps reasonably necessary to ensure that your data is treated securely and according to this Privacy Policy and no transfer of your personal data to any organisation or country will take place unless there are adequate controls in place, including the security of your data and other personal information.

KLARNA

We will not share your details with Klarna without your consent. Upon choosing to checkout with Klarna, you consent to us sharing your details with Klarna, such as your name, email address, billing/shipping address, order details, bank account/card details. You can rest assured that we handle your personal data in accordance with the current and applicable data protection law and in accordance with Klarna's Privacy Statement.

TRUSTPILOT

Hockerty may contact you via email to invite you to review any services and/or products you received from us -to collect your feedback and improve our services and products- (the “Purpose”). We use an external company, Trustpilot A/S (“Trustpilot”), to collect your feedback which means that we will share your name, email address and reference number with Trustpilot for the Purpose. If you want to read more about how Trustpilot processes your data, you can find their Privacy Policy here.

VIRTUAL TRY-ON FEATURE

Hockerty offers an optional Virtual Try-On feature that allows you to see how garments look on you by uploading a photograph. The use of this feature involves the processing of your image and is subject to the following conditions.

What data is processed: The photograph you upload and the virtual try-on image generated from it.

Purpose: Solely to generate your virtual try-on image. Your photograph is not used to identify you, is not shared with third parties for marketing purposes, and is never used to train artificial intelligence models.

Google Gemini: To generate the virtual try-on image, your photograph is processed by Google LLC acting as our data processor, using the Google Gemini service. Google processes your photograph solely on our behalf and in accordance with our instructions and Google's Cloud Data Processing Addendum, which prohibits Google from using your data for its own purposes or for model training.

Retention: Your original uploaded photograph is deleted immediately upon generation of the virtual try-on image. The generated try-on image is stored for 7 days so you can access it, after which it is permanently and automatically deleted.

Your responsibility: The Virtual Try-On feature is intended for personal use only. By uploading a photograph, you confirm that you are the subject of the photograph and that you have the right to submit it for processing. You must not upload photographs of other individuals or of minors. Hockerty is not responsible for photographs uploaded in violation of these conditions.

Legal basis: The processing of your photograph is based on your explicit consent, given at the time of upload. You may withdraw your consent and request early deletion of your image at any time by contacting us at dataprotection@hockerty.com. We will process such requests within 72 hours.

How long do we save your data?

We will keep your data as long as you are an active customer.

You have the right to terminate your account at any time; if you choose to do so, your account will cease to exist and you will be considered inactive. We will retain your personal data in the event of a legal requirement or pending litigation.

Photographs uploaded for the Virtual Try-On feature are deleted immediately after the try-on image is generated. Generated virtual try-on images are stored for 7 days and then permanently deleted. You may request earlier deletion by contacting dataprotection@hockerty.com.

Who is the controller of your personal data?

The Swiss company AFT GmbH is responsible for the processing of the personal data that you provide to us and is responsible for such personal data in accordance with the applicable data protection regulations.

• AFT GmbH
• Flurstrasse 30 Büro 309
• 8048 - Zürich
• Switzerland
• Company registration number: CH-02040402173

Where do we store your data?

The data that we collect from you is stored within the European Economic Area (“EEA”) but may also be transferred to and processed in a country outside of the EEA. Any such transfer of your personal data will be carried out in compliance with applicable laws.

For transfers outside the EEA, Hockerty will use Standard Contractual Clauses and Shields as safeguards for countries without adequacy decisions from the European Commission.

What is the legal ground for processing?

The processing of your personal account data is based on the consent you give us when you create your Hockerty account.

The processing of your data to provide you with relevant product information is based on our legitimate interest.

If you place an order, the processing of your personal data by Hockerty is necessary for the of the order fulfillment and delivery service on your behalf.

What are your rights?

Right to access:

You have the right to request information about the personal data we hold on you at any time. You can contact Hockerty and we will provide you with your personal data via e-mail.

Right to portability:

Whenever Hockerty processes your personal data, by automated means based on your consent or based on an agreement, you have the right to get a copy of your data transferred to you or to another party. This only includes the personal data you have submitted to us.

Right to rectification:

You have the right to request rectification of your personal data if the information is incorrect, including the right to have incomplete personal data completed.

If you have a Hockerty account you can edit your personal data under your account pages.

Right to erasure:

You have the right to erase any personal data processed by Hockerty at any time except for the following situations:

• you have an ongoing matter with Customer Service
• you have an open order which has not yet been shipped or partially shipped
• you have an unsettled debt with Hockerty, regardless of the payment method
• if you are suspected or have misused our services within the last four years
• if you have made any purchase, we will keep your personal data in connection to your transaction for book-keeping purposes

Your right to object to processing based on legitimate interest:

You have the right to object to processing of your personal data that is based on Hockerty's legitimate interest. Hockerty will not continue to process the personal data unless we can demonstrate legitimate grounds for the process which overrides your interest and rights or due to legal claims.

Your right to object to direct marketing:

You have the right to object to direct marketing, including profiling analysis made for direct marketing purposes.

You can opt out from direct marketing by the following means:

• following the instruction in each marketing emails
• by editing the settings of your Hockerty account

Right to restriction:

You have the right to request that Hockerty restricts the process of your personal data under the following circumstances:

• if you object to a processing based Hockerty’s legitimate interest, Hockerty shall restrict all processing of such data pending the verification of the legitimate interest.
• if you have claim that your personal data is incorrect, Hockerty must restrict all processing of such data pending the verification of the accuracy of the personal data.
• if the processing is unlawful you can oppose the erasure of personal data and instead request the restriction of the use of your personal data instead
• if Hockerty no longer needs the personal data but it is required by you to defend legal claims.

How can you exercise your rights?

We take data protection very seriously and therefore we have dedicated customer service personnel to handle your requests in relation to your rights stated above. You can always reach them at dataprotection@hockerty.com

Updates to our Privacy Notice

We may need to update our Privacy Notice. The latest version of the Privacy Notice is always available on our website. We will communicate any material changes to the Privacy Notice, for example the purpose of why we use your personal data, the identity of the Controller or your rights.