HEDY & HOPP’S COMMITMENT TO PRIVACY

This policy defines the commitment of Hedy & Hopp to protect the privacy of personal information that is collected or used by Hedy & Hopp in the course of conducting Hedy & Hopp business. The scope of this policy includes the collection and use of employee, customer, supplier and other third-party personal information. On a global basis, Hedy & Hopp will, and will cause its affiliates to, establish and maintain business procedures that are consistent with this policy.

We respect the privacy rights of individuals.

Hedy & Hopp takes privacy seriously and is committed to complying with legal requirements regarding the privacy of personal information. Hedy & Hopp will, from time to time, review its personal information collection, use, and disclosure practices in order to assure compliance with laws and regulations.

We give notice of Personal Information collection.

Hedy & Hopp will give notice when personal information is collected consistent with applicable law. All notices will explain the need for the information and describe how the information will be used.

We get explicit consent for sensitive information/opt-in.

To the extent required by applicable law, Hedy & Hopp will maintain procedures to assure that sensitive information is collected with explicit consent.

We process and distribute information consistent with notice.

Hedy & Hopp will collect and use personal information consistent with the notices that have been provided. However, Hedy & Hopp may decide to remove identifiable features from collected personal information and the resulting information may then be used for statistical, historic, scientific or other purposes, consistent with applicable law.

We provide individuals a way to access and correct their information.

Hedy & Hopp will maintain commercially reasonable procedures consistent with applicable law for individuals to gain access to their collected personal information and, when appropriate, correct any information that is inaccurate or incomplete, or have their personal information deleted.

We provide information security.

Hedy & Hopp will use commercially reasonable efforts to maintain the security of personal information and protect the integrity of such information.

We require others who process Hedy & Hopp data to comply with applicable law.

Hedy & Hopp will require others who acquire or provide personal information from or to Hedy & Hopp, including those engaged to provide support services, to appropriately protect personal information.

We will disclose Personal Information when required by law or court order.

Hedy & Hopp will, as permitted or required by law or court order, collect, use, transfer and/or disclose personal information pursuant to procedures that do not require giving notice (for example, in connection with law enforcement investigations).

We provide a way to process complaints.

Hedy & Hopp will publish the procedures for responding to complaints regarding potential deviations from its established procedures for protecting personal information.

We align our Human Resources processes with the Hedy & Hopp policy.

Hedy & Hopp will align its Human Resources processes, policies, practices, and guidelines to comply with this policy.

We maintain the flexibility to change this policy.

Hedy & Hopp reserves the right to modify and update this policy or its related business practices at any time.

If you are concerned about our use of your Personal Information, please contact us.