Privacy Policy

Codefine International (HULKEN) Privacy Policy

Last Updated: September 19th 2024

Introduction

This Privacy Policy describes the privacy practices of Hulken Inc. (“Hulken,” “we,” “our,” or “us”) in connection with the personal information we collect on our website https://hulken.eu (the “Site”) and that may be collected via marketing communications from Hulken.  

Please read this Privacy Policy carefully to understand our policies and practices regarding your information. If you do not agree with our policies and practices, your choice is not to use the Site. By accessing or using the Site, you acknowledge this Privacy Policy. 

Updates to This Policy

We may update this Privacy Policy based upon evolving laws, regulations, and industry standards, or as we may make changes to our Site. We will post changes to our Privacy Policy on this page and encourage you to review our Privacy Policy when you use our Site to stay informed. We will take appropriate measures to inform you, consistent with the significance of the changes we make.  If you disagree with the changes to this Privacy Policy, you should discontinue your use of the Site.

Children 

The Site is not directed to, and we do not knowingly collect Personal Information from, anyone under the age of 18. If a parent or guardian becomes aware that his or her child has provided us with information, they should contact us. We will delete such information from our files as soon as reasonably practicable.

Personal Information We Collect

Information You Provide Us

We may collect information that personally identifies you (“personal information”) when using our Site and our services. When you make a purchase on our Site you may provide us with your name, addresses, and credit card information. You may also provide us with your personal information when you choose to contact us or when you sign up to receive marketing messages from us. 

Information We Automatically Collect

When you visit the Site, we may automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device using cookies and similar technologies. Additionally, as you browse the Site, we may collect information about the individual web pages or services that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site.

Cookies & Similar Technologies

We use cookies (small, often encrypted, text files that are stored on your computer or mobile device) and similar technologies (“Cookies”) to provide you with certain functions on our Site and help collect data. This section explains how we use Cookies to collect information about the way you use our Site and how you can control them.

How We Use Cookies

We use Cookies to track how you use our Site by providing usage statistics. Cookies are also used to deliver our information (including updates) and allow account authentication to you based upon your browsing history and previous visits to the Site. Information supplied to us using Cookies helps us to provide a better online experience to our visitors and users and send marketing communications to them, as the case may be. We may combine the information we collect from Cookies with personal information that we have collected from you to learn more about how you use our Site to improve it.

Types of Cookies

We use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your device until you delete them). To make it easier for you to understand why we need them, the Cookies we use on our Site can be grouped into the following categories:

  • Strictly Necessary: These Cookies are necessary for the Site to work properly. They include any essential authentication and authorization Cookies for our Site.
  • Functional: These Cookies enable technical performance and allow us to remember the choices you make while browsing our Site, including any preferences you set. They also include sign-in and authentication Cookies and IDs that enable you to return without additional sign-in.
  • Performance/Analytics: These Cookies allow us to collect certain information about how you navigate the Site and services running on your device. They help us understand which areas you use and what we can do to improve them.
  • Targeting: These Cookies are used to deliver relevant information related to our Site to an identified machine or other device (not a named or otherwise identifiable person) which has previously been used to visit our Site. Some of these types of Cookies on our Site are operated by third parties with our permission and are used to identify advertising sources that are effectively driving customers to our Site.

How to Control and Delete Cookies

Cookies can be controlled, blocked, or restricted through your web browser settings. Information on how to do this can be found within the Help section of your browser. All Cookies are browser specific. Therefore, if you use multiple browsers or devices to access websites, you will need to manage your Cookie preferences across these environments.

Find out how to manage Cookies on popular browsers:

If you are using a mobile device to access the Site, you will need to refer to your instruction manual or other help/settings resource to find out how you can control Cookies on your device.  For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.

Please note that if you restrict, disable or block any or all Cookies from your web browser or mobile or other device, the Site may not operate properly, and you may not have access to our services available through the Site. We are not responsible for your inability to use our Site or any degraded function you may experience that may be caused by your settings and choices regarding Cookies. 

We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

How We Use Personal Information

We use your personal information for the following purposes and as otherwise described in this Privacy Policy or at the time of collection:

  • To provide, operate and improve the Site;
  • To fulfill any requests you place using our Site;
  • To establish and maintain your account on the Site;
  • To communicate with you about the Site, including by sending you announcements and administrative messages;
  • To personalize your experience with the Site and communicate with you;
  • To provide support and maintenance;
  • To respond to your request and feedback; 
  • To provide you with Hulken marketing communications;
  • To help us advertise the Site and display advertisements to you;
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations; 
  • To comply with legal obligations; and
  • With your consent.

How We Share Personal Information 

We may share limited partners’ personal information with our affiliates and to service providers such as brokers, custodians, lawyers, and accountants. We may also share personal information for compliance purposes and as required by law.

We may sell, transfer, or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.

Payment Processing

Our store is hosted by Shopify, Inc. They provide us with the online e-commerce platform that allows us to sell our products to you. Your data is stored through Shopify’s data storage, databases, and general Shopify application. You may review Shopify’s Terms of Service here: https://www.shopify.com/legal/terms. We use Shopify Payments to process your payments. All direct payment gateways adhere to the standards set by PCI-DSS. Shopify Payments will collect, use, and process your information, including payment information, in accordance with their privacy policy. You can access Shopify Payment’s privacy policy here: https://pay.shopify.com/tos-privacy-policy.

Use of AI Technologies

We utilize AI tools on our Site which may process your Personal Information. We utilize such tools for the purpose of improving our efficiency and quality of our services, business processes, and customer support. We have agreements in place with providers of such AI tools to protect your Personal Information. 

Privacy Technology Practices

Do Not Track

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Links to Third-Party Sites

The Site may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications, or online services, and we are not responsible for their actions. Other websites, mobile applications and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites, mobile applications, and online services you use.

Data Security

We employ a number of administrative, technical, and physical safeguards designed to protect the personal information we collect. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Site.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Site. Any transmission of personal information is at your own risk. 

Data Retention

Hulken strives to retain Personal Information for no longer than it is reasonably necessary for its processing purpose. The applicable retention period depends on the purpose for which Personal Information was obtained and on specific data retention obligations arising from applicable laws that may require the data to be held for a certain period of time. We may retain Personal Information for a longer period than is necessary if it is required by law.

California & Texas Consumers

This section outlines data privacy rights afforded to California and Texas residents who use our Site. 

Your Data Privacy Rights

Residents of California and Texas have the following rights:

Right to Know

You can request information about how we have collected, used, and shared your personal information during the past 12 months. We have made this this information available to California residents without having to request it by including it in this Privacy Policy

Right to Access

You can request a copy of the Personal Information that we maintain about you. 

Right to Delete

You may request that we delete any of your personal data that we collected from you and retained, subject to certain exceptions. Once we receive your request and confirm your identity, we will review your request. We may deny your deletion request if retaining the information is proper and necessary or if an exception allowing us to retain the information applies. 

Right to Correct

You may also request that we correct any of your personal data that has become outdated or needs correction for any reason. 

Exercising Your Rights

To access or delete specific pieces of personal information we will need to verify your identity to the degree of certainty required by law. As permitted by applicable law, any request you submit to us is subject to an identification and residency verification process (“Verifiable Consumer Request”). We will not fulfill your request unless you have provided sufficient information for us to reasonably verify you are the consumer about whom we collected personal information.

Individuals may exercise their rights described above by emailing us at hello@hulken.com with subject line “[California]/[Texas] Data Rights Request.” 

Only you, or someone legally authorized to act on your behalf (an “Authorized Agent”), may make a request to know or delete related to your personal data. We require Authorized Agents to provide written authorization confirming they may submit a request on your behalf. You may only submit a request to know twice within a 12-month period. We endeavor to substantively respond to a Verifiable Consumer Request within forty-five (45) days of its receipt unless we require an extension. If we reasonably require an extension, we will inform you of the reason and extension period.

Note to Texas Residents: In the event your data request is denied, Texas residents may also appeal that denial. In the event we deny your data rights request, you may appeal our decision by emailing us or calling us at the information provided above. You will receive confirmation of the action being taken regarding your appeal within 60 days of receipt of your appeal.

Non-Discrimination

We will not discriminate against you for exercising any of your data subject rights. We do not charge a fee to process or respond to your Verifiable Consumer Request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Summary of the Categories of Personal Information We Collect

The personal information you may provide us with includes:

  • Category A: Identifiers such as your real name, alias, postal address and similar identifiers;
  • Category B: Personal information categories listed in the California Customer Records Statute such as your real name, address, telephone number, and medical information;
  • Category C: Protected Classification Characteristics under California law such as your age, citizenship, marital status, and mental ability; 
  • Category D: Commercial information, including records of personal property or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
  • Category F: Internet or other similar network activity such as information on how you interact with our Site;
  • Category: I: Professional or employment related information such as your current or past job history; and
  • Category J: Non-public education information such as educational records directly related to you that are maintained by an educational institution.

We do not collect Category E (biometric information), Category G (geolocation data), Category H (sensory data), or Category K (inferences drawn from your personal information).  We do not collect sensitive personal information.

Contact Us

For questions or comments about this Privacy Policy and our privacy practices, contact us at: 

hello@hulken.com 

Notice to European Consumers

This section applies to residents of the European Economic Area (“EEA”). Residents of the EEA and the United Kingdom may be entitled to rights under the General Data Protection Regulation (“GDPR”) and UK GDPR respectively. Hulken is a subsidiary of Codefine International SA (“Codefine”). Codefine operates the European version of our website at https://hulken.eu and your data may be shared between Hulken and Codefine. For more information about Codefine’s data processing practices please review their website here.

Legal Bases for Processing

We Process your Personal Information such as name, email address, and physical address for the performance of a contract with you, to comply with legal obligations, and to study our customers use our Site and products. Where you have provided Personal Information voluntarily or otherwise consented to its use, you have the right to withdraw your consent. 

GDPR Rights

If you request to exercise your rights under the GDPR, we may require verification of your identity before we respond to any such request. If you are entitled to these rights, you may exercise the following rights with respect to your Personal Information that we process:

  • The right to withdraw consent to data processing at any time;
  • The right of access to your personal information;
  • The right to request a copy of your personal information;
  • The right to correct any inaccuracies in your personal information;
  • The right to erase your personal information;
  • The right to data portability, meaning to request a transfer of your personal information from us to any other person or entity as chosen by you;
  • The right to request restriction of the processing of your personal information; and
  • The right to object to processing of your personal information.

You may exercise these rights free of charge. These rights will be exercisable subject to limitations and as provided by the GDPR. Any requests to exercise the above-listed rights may be made to hello@hulken.com. If you are a resident of the EEA, you have the right to lodge a complaint with a Data Protection Authority about how we processed your personal information here. UK Residents may use this link

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