Privacy Policy
Privacy Policy
This Privacy and Cookie Policy (“Policy”) of Horys Technologies LTD, a company incorporated on March 9th, 2023, with the BVI Company No. 2119727, pursuant to the British Virgin Islands Business Companies Act of 2004 (as amended) of the British Virgin Islands, governs the access to and use of all parts of the website and services branded as Horys Mall ("Horys Mall") and referring to the domain https://horysmall.com/ (“Platform”) and all documents, data, materials or other information made available on the Platform.
This Policy applies to all visitors and/or users of the Platform (“User”, “Users”, “You”, “Your” or “Yourself”) who act in their own personal capacity. Please read this Policy along with our Terms and Conditions carefully, and note that by using our Platform, you are consenting to the collection, storage, processing, and transfer of your personal information as described in this Policy.
Last Updated: July 2024
1. DEFINITIONS
1.1. “Account” means the account created on Homnifi to use the services offered by the Platform.
1.2. “Homnifi” is an intermediary platform that operates as a unified sign-on system enabling Users to access Third-Party Partners services and products offered on their platforms.
1.3. “Third-Party Partner Website” refers to the website of the Partners we collaborate with and where you can utilize your Horys Mall Account credentials to access our services.
1.4. “Third-Party Partner” means the service providers and Third Parties with which we have service agreements to expand the range of services and products accessible across our Platform to its Users and community members. However, each one is governed by their own terms and policies. We do not exercise any control or management over these Third-Party Partners websites. Users should display their own due diligence to read and understand each one of the legal documents governing those products and services.
1.5. “Personal Data” refers to any information that relates directly or indirectly to a natural person whether living or deceased, who is identified or identifiable from that information, or from that and other information in the possession of a data User.
This Policy may be made available in several languages for educational purposes only. In case of any inconsistency between the English version and a translated version, the English version prevails.
2. PURPOSE OF THIS POLICY
2.1. Horys Mall understands how important it is for Users to understand how we collect, store, process, share, and use your Personal Data. We respect and protect the privacy of our users’ Personal Data on our Platform.
2.2. The purpose of this Policy is to describe how Horys Mall collects, processes, and manages Users’ Personal Data through the Platform, which is developed to offer our services.
3. ACCEPTANCE
By accessing and using our Platform or our services, you are consenting to and accepting the terms of this Policy and all supplementary agreements, including the Terms and Conditions and any other subsequent and supplementary agreement related to the present document and the operations of Horys Mall.
4. USER LOGIN CREDENTIAL INFORMATION
4.1. To properly use our Platform, Users are required to create an Account on our Third-Party Partner Website, Homnifi. This process involves sharing your Personal Data not only with us but also with Third-Party Partners. Users should acknowledge that their responsibility encompasses reading and understanding the privacy policies of each Third-Party Partner Website.
4.2. Each Third-Party Partner Website maintains its own distinct privacy policy that governs the collection, utilization, and processing of your Personal Data. It is your responsibility to familiarize yourself with the terms and practices outlined in the respective privacy policies on how your Personal Data is accessed, employed, and managed across the different platforms available within the ecosystem.
4.3. Users grant us permission to use their Personal Data as required to provide services on the Platform.
5. PERSONAL INFORMATION THAT WE COLLECT FROM USERS
5.1. Horys Mall collects and retains your Personal Data to facilitate, advance, and improve our array of products and services. This encompasses the development of technical infrastructure, reinforcement of security measures, adherence to compliance standards, prevention of fraud, and provision of robust customer support. Additionally, it is imperative to acknowledge that Users Personal Data will also be collected in line with the prerequisites of our Third-Party Partner Websites.
5.2. The Personal Data we collect from our Users is as follows:
5.2.1. Users:
Full name;
Date of Birth;
Email address;
Gender;
Residence address;
Nationality;
Country Code;
Telephone number;
Referral activities on our Third-Party Partner Websites;
Wallet address;
Transaction details;
Passport or National ID number;
Credit card details;
Source of wealth;
Occupation;
Bank account details, including institution name, branch, account name, bank identifier;
Bank account number or IBAN.
5.2.2. Browser Information:
IP address;
Login information;
Browser type and version;
Time zone setting;
Platform;
Operating system;
Transaction history;
Pages accessed and links clicked.
6. HOW USERS’ PERSONAL DATA IS USED
Users’ Personal Data is used by the Platform to:
(i) To communicate with the User;
(ii) To provide its Services;
(iii) To comply with legal and regulatory compliance;
(iv) To detect and prevent fraud and credit risks;
(v) To troubleshoot and improve its Services;
(vi) To enforce Horys Malls’ Terms and Conditions;
(vii) To provide customer services;
(viii) To ensure quality control;
(ix) To ensure network and information security;
(x) To enhance and personalize User experience;
(xi) To engage in marketing activities;
(xii) For transaction services; and
(xiii) Purposes for which Horys Mall seeks User’s consent.
7. DATA TRANSFER
7.1. Horys Mall may share your Personal Data with specific third parties, which include Third-Party Partner Websites, encompassing business suppliers, distributors, and subcontractors. Such sharing becomes essential for the effective delivery of our services or in instances where a legal basis mandates such sharing. Please note that the aforementioned Third-Party Partner Websites are authorized to collect, utilize, and disclose your information as directed by us. This ensures that the services provided are comprehensive and aligned with our standards.
7.2. Users’ Personal Data may be subject to transfers between integrated Third-Party Partner platforms based on the needs to provide efficiency and better user experience to our community members. Please be aware that these transfers may be conducted without prior notice to you. Your continued engagement with our services signifies your acknowledgment and acceptance of this data transfer mechanism.
7.3. We further ensure that we comply with the applicable data protection legal norms, and we shall only share information in the following circumstances:
7.3.1. With applicable regulatory and governmental bodies;
7.3.2. With Third-Party KYC/AML service providers of Horys Mall (if applicable) or any of the Third-Party Partner Websites to perform verification services in the User onboarding process;
7.3.3. With service providers under contracts to operate the business. For instance, and not limited to:
Cloud storage;
Network Infrastructure;
Security;
Customer Support;
Marketing;
Data Analytics;
Payment Process.
7.3.4. We transfer only the minimum amount of data necessary for a particular outsourced service provider(s) (if applicable) and we only cooperate with the outsourced service providers who can provide and ensure an adequate level of Personal Data protection.
7.4. Horys Malls ensures that the service providers and affiliates/business partners who process personal information acknowledge the confidentiality of this information and protect the User’s right to privacy by complying with all applicable privacy and data protection laws.
7.5. Each Third-Party Partner Website may have its own data transfer clauses, terms and conditions and privacy policies governing how your information is handled, processed, and shared. By using our Platform to access the services of Third-Party Partner Websites, you acknowledge and agree to adhere to the data transfer clauses and privacy policies of those Third-Party Partner Websites.
8. PROTECTION AND STORAGE OF PERSONAL DATA
Horys Mall maintains physical, technical, administrative, and procedural safeguards in connection with the collection, storage, and disclosure of the User’s Personal Data. We use firewall barriers, encryption techniques, and authentication procedures to maintain the security of User’s online sessions.
9. DATA RETENTION
9.1. Horys Mall is responsible for retaining either the original or a precise copy of all data and information acquired from its Users. This retention will be in a format that is readily accessible for a seven (7) year period following the conclusion of Users involvement with the Platform services, as well as those offered by our Third-Party Partner Websites on which our services are engaged. Any Personal Data provided by Users will be securely maintained by Horys Mall until the point at which they choose to request the termination of the association. Variation in this period of retention might change based on the type of interaction of each User with the Platform, products and services, and compliance with requirements from governmental authorities.
9.2. Horys Mall will take reasonable measures to ensure that all Personal Data is destroyed or permanently deleted if it is no longer required for the purpose of providing its services for which it was processed and in certain circumstances, if required by law, it may not destroy any relevant records or Personal Data even though the prescribed period for retention shall have elapsed.
9.3. Furthermore, information or data collected via technical means such as cookies, web page counters, and other analytics tools is kept for a period of up to twelve (12) months from the expiry of the Cookies Policy, as defined below under Section 12.
10. DATA PROTECTION LAW AND THE EUROPEAN DATA PROTECTION RIGHTS
10.1. This Policy is governed by and shall be construed in accordance with the data protection laws of the British Virgin Islands. Additionally, the highest standard of data protection, as set forth in the European General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 or "GDPR"), shall also apply to the processing of Personal Data covered by this Policy.
10.2. According to the GDPR, Horys Mall provides privacy notices:
(i) in a concise, transparent, intelligible, and easily accessible form;
(ii) written in clear and plain language;
(iii) delivered in a timely manner; and
(iv) provided free of charge.
10.3. If Users are located in the European Economic Area (EEA), they will have the rights as described below.
10.3.1. Users may request access to and receive information about the Personal Data Horys Mall maintains about them, update and correct inaccuracies in their Personal Data, restrict or object to the processing of their Personal Data, have the information anonymized or deleted, as appropriate, or exercise their right to data portability to easily transfer their Personal Data to another company.
10.3.2. Users may withdraw any consent previously provided to Horys Mall regarding the processing of their Personal Data, at any time and free of charge. Horys Mall will apply the preferences going forward and this will not affect the lawfulness of the processing before consent withdrawal.
10.3.3. If Users are located in the EEA, Horys Mall will comply with applicable GDPR law when transferring their Personal Data outside of the EEA.
11. USER RIGHTS PROTECTED UNDER THE GDPR
11.1. Under certain circumstances, Users have rights under data protection laws in relation to Personal Data which as indicated below.
11.1.1. Request Access - this enables Users to receive copies of their Personal Data that Horys Mall holds about them and to check that Horys Mall is lawfully processing it. This is also commonly known as a "data subject access request". This enables Users to have any incomplete or inaccurate data Horys Mall holds about them corrected, though Horys Mall may need to verify the accuracy of the new data provided to it.
11.1.2. Request Erasure - this enables Users to request Horys Mall to delete or remove Personal Data where there is no good reason for it to continue to process it. Please note that there may be circumstances where Horys Mall may be legally entitled to retain Personal Data.
11.1.3. Request to Restrict Processing - this enables Users to object to the processing of their Personal Data, which is processed based on Horys Mall’s legitimate interests. In the event of such an objection, Horys Mall will no longer process Personal Data, unless it demonstrates compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject or for the establishment, exercise, or defence of legal claims.
11.1.4. Request to Object Processing - Users have the right to object to the processing of their Personal Data where Horys Mall relies on a legitimate interest (or those of a Third-Party Partner) and there is something about their particular situation which makes them want to object to processing on this ground as they feel it impacts on their fundamental rights and freedoms. Users also have the right to object where Horys Mall is processing their Personal Data for direct marketing purposes.
11.1.5. Request to Transfer - under previous request in written form Horys Mall can transmit User’s Personal Data in a structured, commonly used, machine-readable format to another controller. Note that this right only applies to automated information that Users initially provided consent for Horys Mall to use or where Horys Mall used the information to perform a contract with Users.
11.1.6. Right to Data Rectification - this gives Users the authority to request the correction of Personal Data that Horys Mall processes or holds. This right ensures that personal data is accurate, up-to-date, and complete. If Users discover that their Personal Data is incorrect, incomplete, or outdated, they can exercise this right by submitting a formal request to Horys Mall. Horys Mall is then obliged to rectify the erroneous data without undue delay, considering the purposes of the processing. This right supports the accuracy and fairness of data processing and contributes to the overall integrity and reliability of the Personal Data collected and processed by Horys Mall.
12. COOKIES POLICY
12.1. Cookies are small text files that are placed on a device like a computer, mobile, or any other device by a website, containing details of browsing history (“Cookies”). In simple terms, it is explained as that it contains information about the browsing activity. Whenever the User visits our Platform, the website sends Cookies to the device used to access our Platform. The device automatically stores the Cookies in a file that’s located within the website browser.
12.2. Cookies allow the Platform to recognize the User's device. When Users revisit a site, the website will respond in a more personalized way, remembering preferences, and it will make the page load faster. Cookies set by our operators are called “First party cookies,” set by parties other than our Platform to enable Third-Party Partners features or functionality to be provided on or through the website for instance such as advertising, interactive content, and analytics.
12.3. We use the following Cookies to operate our Platform, such as:
12.3.1. Session Cookies: are temporary and expire once the User closes the browser. It stores information for the time or session when the User is on the Platform.
12.3.2. Persistent Cookies: encompass all cookies that remain on the User’s hard drive until they erase them, or their browser does it. It depends on the Cookie’s expiration date. All persistent cookies have an expiration date written into their code, but their duration can vary.
12.3.3. First-Party Cookies: are placed on the User’s device directly by the Platform.
12.3.4. Third-Party Cookies: are placed on the User device, not by the Platform, but by a third party like an advertiser or an analytic system. Generally, Third-Party Cookies consist of tracking cookies used to identify online behaviour, understand interests, and then customize advertising to Users on other websites. Any information obtained from Third-Party Cookies is processed by the respective Collaborative Partners.
12.3.5. Google Analytics Cookies: to measure our Users’ interactions with the content on the Platform. These cookies collect information about the Users’ interactions with the Platform, such as unique visits, repeat visits, session duration, and website activity.
12.3.6. Essential Cookies: are known as strictly necessary Cookies for the Users to browse the Platform and use its features, such as accessing secure areas of the Platform. These cookies are generally First-Party Session Cookies. These cookies do not require consent from the Users. Essential cookies help to make the Platform easy to use by providing basic functions such as page navigation, language selections, authorization, and filling in forms. The Platform will not function without these Cookies, and they cannot be disabled. These Cookies do not reveal the User’s identity or collect information. They are stored on the User’s device until the browser is closed.
12.3.7. Functionality Cookies: allow the Platform to remember choices Users have made in the past like what language they prefer, what region they would like, or what username and password are so they can automatically log in. Horys Mall uses Cookies for navigation and to facilitate access to and use of the Platform. These Cookies are necessary for the transmission of communications on the network or to supply services whatever requested by Users. Further, they help Horys Mall to know which pages are the most and least popular and see how visitors move around the website.
12.3.8. Performance Cookies: collect information about how Users use the Platform, like which page they visited, and which link they clicked on. None of this type of information can be used to identify Users. The sole purpose of performance Cookies is to improve Platform functions. Analytics may collect information through log data, such as:
IP address;
Type of browser and device;
Operating system;
Name of the Internet Service Provider;
Country information;
Date and time of visit; and
Web page origin and exit.
12.3.9. Marketing Cookies: track online activity to help advertisers deliver more relevant advertising or to limit how many times Users see an ad. These Cookies can share information with other organizations or advertisers. However, these are Persistent Cookies which are third-party proven. These Cookies may be set through the website by Horys Malls’ advertising partners. If Users do not allow these Cookies, they will experience less targeted advertising.
12.4. Users reserve the right to decide whether to accept or reject Cookies from the Platform. They can exercise their rights by setting their preferences in the Cookie Consent Manager. However, Users will not be able to reject the Essential Cookies, as they are strictly necessary to provide them with the products and services available on the Platform. In the event Users choose to reject Cookies, they may still use the Platform though their access to some functionality and areas of the Platform may be restricted. They may also set or amend their web browser controls to accept or refuse Cookies. The rejection or deactivation of cookies may affect the functionality of the Platform. Therefore, it is recommended that Users do not disable Cookies.
13. PRIVACY TERMS IN USING DIGITAL ASSETS AND BLOCKCHAIN
The digital assets and/or digital tokens are recorded on a public blockchain. It is a ledger which means a chain of blocks where each block contains the recording of any data transmission. Blockchains are decentralized or third-party networks that are not controlled or operated by any Third-Party Partner service provider affiliates or business partners of Horys Mall, and Horys Mall has no access or authority to erase, modify, or alter any personal data that could be available in such networks.
14. MODIFICATIONS
Horys Mall reserves the right, at its sole discretion, to modify, amend, supplement, or replace this Policy at any time and such update details shall be indicated at the top of this page. The Platform Policies and Terms may be revised or updated periodically to meet the necessary requirements and standards. We encourage Users to regularly visit the Platform to stay informed about any changes to these Policies and the Terms. Continued access to the Platform means that Users agree to the updated content and to abide by the updated Policy.
15. CONTACT INFORMATION
In the event of any comments, questions, inquiries, or complaints regarding this Policy, Users have the right to submit questions and/or concerns at
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