This Privacy Policy explains how Hoken Holdings Inc . (“Hoken”, “we”, “our”, or “us”) collects, uses, and discloses data when you use our website (“Site”) or mobile application (“App”) and your rights relating to the data and information that we collect or hold about you. We are committed to protecting the privacy and creating a safe and secure online environment of anyone who buys, sells, or trades hotel room reservations on our Site or App.

This privacy statement ("Privacy Policy") explains which personal information we collect from or about you on our Site and App, how such personal information is used, and your rights relating to such personal information.

Certain goods or services, which you may access or purchase via the Site or App, are provided by our third party partners, and protection of your information relating to such services will be governed by the privacy policy of such third parties.

By accessing, browsing and using the Site or the App, you represent that you have read, understood and agreed to this Privacy Policy.

Categories of Personal Information We Collect

When you use our Site or, once it is launched, App, we collect personal information that you provide at your own volition when and while (i) you create an account or change information in connection with such account, (ii) you access, browse, or use our Site or App, (iii) in an any shape or form correspond with is, (iv) you engage in trading activities with any of our customers. The personal information may include, without limitation and for example, the items listed below:

• Name, username, email, phone number, and home, business, and billing addressees (including street and postal code);

• Security questions and answers;

• Government issued identification required for booking or identity verification, such as passport, driver’s license, government redress numbers, and country of residence;

• Financial information such as credit card related information (number, expiration date, billing address, and financial account number);

• Birth date and gender;

• Geolocation

• Personal tastes and preferences as to shows, movies, sport teams, and other information for identification validation purposes when you log into your account or engage in transactions on our Site or App;

• Images (including facial photographs), videos, and other recordings

• Publicly available information such as in your Facebook, Instagram, or LinkedIn profiles;

• Communications with us in any form for quality assurance and training purposes;

• Searches you conduct, buy, sell, and trade transactions, and other interactions with you on the Site or the App;

• Personal information about others for whom you are making a hotel room reservation or that you otherwise provide personal information; or

• Information facilitated by third parties such as hotel properties which may include, but is not limited to, demographic information, interests, tastes and preferences, and purchase history, which we may add to your account or profile and use for market research and analysis.

The list above is not exhaustive of all of the personal information we may collect from you.

When you install our App or use our Site, we automatically collect the following types of information from your device:

• IP address;

• Device type;

• Unique device identification numbers;

• Operating System;

• Internet browser-type;

• Internet Service Provider;

• Mobile carrier; or

• Your interactions with the Site or the App, as the case may be, including hotels viewed, geographic, event, or any other preference we may discern, along with other use habits.

• General geographic location at the country, state, province, or city level, as the case may be, but no specific address information is collected.

App

When you download and use our App after it is launched, we collect certain technical information from your mobile phone or other device to enable the App to work properly and as otherwise described in this Privacy Policy including:

• Device and telephone connectivity information such as your carrier, network type, network operator, subscriber identity module ("SIM") operator, and SIM country;

• Operating system and version;

• Device model;

• Performance and data usage;

• Usage data and habits, such as when is the App used, , the searches, transactions, and the data and files downloaded to the App;

• Subject to your authorization, device settings selected or enabled, for location services;

• Other technical information as needed to provide you with the services you choose.

Permissions for Location-Based Services

We may collect location information by using GPS signals, cell phone towers, Wi-Fi signals, Bluetooth or other technologies subject to the settings and permissions in your device and the choices you make. We will collect this information, if you opt in through the App or other program (either during your initial login or later) to enable certain location-based services available within the App (for instance, locating the closest hotel properties to an event that you are planning to attend). You may disable location capabilities of the App at any time of your choosing by logging off or changing the settings relating to your mobile device.

Cookies and Other Tracking Technologies

This Privacy Policy refers to the seven (7) technologies listed and described below as “cookies.”

1. Cookies are small pieces of text sent as files to a device when it visits certain websites. We or third parties, as the case may be, may deliver cookies. Cookies are used as a tool that facilitate websites to remember particulars of website browser past behavior. Cookies help us monitor and improve the user experience and allow us to personalize the Site and the App, assess which areas and features of our Site and App are useful or popular and understand customers' usage and behavior of the Site and the App.

2. Web beacons, gifs, and clear gifs are embedded invisibly tiny graphics with a unique identifier on each. You may find them in websites and emails. Such provide incisive data in connection with visits to a certain page or the effectiveness of ad banners in the Site or other websites.

3. Proximity based beacons transmit one-way signals across short distances, to communicate with related mobile apps on your phone. They can notify you, for example, about related deals or promotions in connection with a hotel property. Beacons communicate with a device only when distances are short subject to your consent within the relevant mobile application.

4. Local Storage Objects are used to store content and preferences based upon your behavior, habits, and activity. Third parties that provide certain features on the Site to display advertising of specific hotel properties based upon your behavior use Local Storage Objects to collect and store information.

5. Pixels are small objects embedded into a web page that are not visible to the user. We use pixels to send cookies to your computer, enable the log-in process, monitor Site activity, and remit advertising.

6. Tags are small pieces of HTML code that compels a browser to request certain content generated by an ad server. Tags are used to display or offer, as the case may be, advertising and promotions that may be relevant to you.

7. Scripts are pieces of JavaScript code used to determine viewership of related advertisements by visitors of webpages when certain webpages load in the device.

Use of Cookies

Cookies are used for a number of reasons, including (i) to help improve your experience when visiting our Site; (ii) fulfill buy, sell, and trade hotel room reservations and ensure our Site performs as intended and to your satisfaction; (iii) tailor advertising so that it is relevant to you; (iv) to enable ad performance analysis; (v) facilitate your return to hotel property searches that you performed; (vi) detect and identify errors in the Site; (vii) data protection and related compliance; (viii) potentially detect bad actors and malicious or fraudulent activity; (ix) acquiring knowledge relating to Site traffic; and (x) analyzing the performance of the Site.

Types and Functions of Cookies

1. Essential Cookies (otherwise known as Strictly Necessary Cookies) are required for the efficient operation of the Site. Such are necessary to log-in into the Site, browse the Site, and to manage hotel room reservations whether you are buying, selling, or trading. Essential cookies are also utilized to recall security settings that gate the flow towards particular content. We also use essential cookies for information collection purposes to learn the web pages which visitors browse or interact the most to improve the Site and the App. Essential cookies are not optional (i.e., you may not opt out from essential cookies).

2. Functional Cookies are used to ameliorate the functional performance of the Site and to remember your preferences, settings, and previous searches.

3. Analytics Cookies are used to count the number of visitors and monitor their activities to understand the performance of the Site which information is utilized to improve and enhance the Site’s performance. We can see how users move around the Site among other details that we use to improve the ease of use of the Site. Further, the information allows us to experiment new features, measure the success of our marketing efforts, and enhance the effectiveness of the Site in catering to the wants, desires, and needs of our customers.
   Please note that our third party service providers may use cookies to provide services to you. During that process, such third parties may use the information collected about you on our Site with other information such third parties may have gathered elsewhere. This Privacy Policy does not cover such third parties’ use of your information.

4. Advertising Cookies are used by us and third parties to show advertisements based on our perception of your interests. Third parties may gather information about your online habits to service you and may combine the information that they gather about you on the Site with other information collected through other sites. Perceptions and assumptions relating to your interests, characteristics, taste, or preferences may be used to tailor advertisements. We do not control nor have access to the third party cookies which gather information, and this Privacy Policy does not relate to the policies or practices of such third parties.

Cookies Management

You can set or change your settings relating to cookies at your discretion, but this may entail restricting access or not being able to use, as the case may be, some of the functionality or areas of the Site or the App.

One of the choices available to you is to not receive tailored online advertising from us and other sites. This choice may mean that the online advertisements that you may receive are less in tune with your interests or preferences. Information is available at http://www.aboutads.info/choices/ and http://optout.networkadvertising.org/. If you are a resident of Canada, you may find useful information at http://youradchoices.ca/choices/. If you are a resident of the European Union, Switzerland or the UK, you may find useful information at http://www.youronlinechoices.eu/.

Information We Collect From Other Sources

We may obtain personal information from other sources and combine that with other personal information we collect. For instance, we may collect personal information about you from third parties, including but not limited to identity verification services, fraud detection service providers, credit bureaus, mailing list providers, and publicly available sources. If you create or log into your account through Facebook, Instagram, or another social media platform, we will have access to certain personal information from that site, such as your contact or friends list, in accordance with such social media platform policies.

Use of Personal Information

We use your personal information to fulfill our mission of providing the services you desire relating to the buy, sell, and trade of hotel room reservations in the Site or the App. This entails analyzing the information to improve, manage, nurture, keep up, organize, and strengthen the Site or the App. We also use your personal information for the purposes set forth below.

1. Your Use of the Site and the App:

   • Facilitate the purchase, sell, or trade transactions that you choose to engage in;

   • Upkeep your account;

   • Identify and verify you;

   • Keep records on your preferences, reservations, viewing patterns, and similar information, and as otherwise described in this Privacy Statement; and

   • Facilitate currency flow that fuels the buy, sell, and trading transactions.

2. Advertising and Communications:

   • Communicate with you relating to questions, information requirements, and process information choices;

   • Facilitate the communication between hotel properties and you;

   • Communicate with you to supply information such as buy, sell, or trade notifications or for other purposes; and

   • Promote the Site, the App, our hotel room reservation marketplace, tailor marketing, and use metrics to evaluate our advertisements and marketing strategy.

3. Other Compliance and Business Grounds or Objectives:

   • Conduct data analytics, metric evaluation, and businesses related research;

   • Monitor your activities and interactions with the Site, the App, and our team and other representatives for the purposes of improving our services and interactions pertaining to you and to reach resolution of conflicts with you;

   • Compile aggregated data that is not attributable to you, which has no use or disclosure restrictions where allowed;

   • Risk management including, without limitation, promoting security, avoiding and fighting against fraud and unlawful activities, set forth records to fight potential claims and other liabilities;

   • Applicable law compliance, protect us including, without limitation, our rights and interests, and respond to governmental entities, related investigations, and court or administrative processes; and

   • Comply with applicable anti-money laundering, anti-fraud, anti-terrorism, anti-bribery, and other laws and regulations.

Sharing of Personal Information

We share your personal information as described below and in this Privacy Statement, and as permitted by applicable law.

• Third party service providers. We share personal information with third parties, many of whom we are required to hire in connection with our business operations and the performance of services to our customers such as you. For instance, we are not a credit card processing company. Thus, we hire third parties that provide credit card processing and other third parties that assist us in the prevention of fraud, money laundering, and other compliance services as well as others that provide business analytics or tailored advertising based on perceptions of your tastes and preferences. Our third party service providers cannot use or divulge personal information other than to provide services we contracted them for. They are not allowed to use the personal information we share for purposes of their own direct marketing (unless you have separately consented with the third party under the terms provided by the third party).

• Hotel room suppliers. We share personal information with hotel room suppliers and similar parties. Please note that hotel room suppliers may take the initiative in contacting you if and as required to enable your hotel to provide services.

• Other Third Parties. When you trade in our marketplace, you may share limited information with your counterparty. There may be other instances in which you share personal information with other third parties. The personal information shared will be governed by the privacy policy of the relevant party (including any personal information we obtain via the third party provider), if any. The third party providers should inform you about how you can modify your privacy settings on their site.

• Legal rights and obligations. Your personal information is subject to disclosure to enforce our policies including, without limitation, in the protection or defense of the rights and interest of Hoken and its stakeholders, or where it required to do so by regulatory or legal process or as otherwise required by law, such as in response to a request by a law enforcement or governmental authority (including tax authorities).

• Corporate transactions. Disclosure of personal information may be required in connection with a corporate transaction to effectuate the corporate transaction. As part of any change of control, the buyers of Hoken may have access to personal information as owners of the business or the assets of Hoken, whether directly or indirectly.

Rights and Choices

You have rights and choices with respect to your personal information, such as:

• Change your communication preferences in your Hoken account by either manually making the changes in your account or contacting us.

• Restrict the usage of cookies (except those that are Essential Cookies) as described in the Cookie and Other Tracking Technologies segment in this Privacy Policy.

• Enter into your account or contact us to alter, update, or delete your information at any time.

• Unsubscribe by using the ‘unsubscribe’ link in any email from us if you do not want to receive advertisement messages. Unsubscribing or opting out of advertisement messages will not stop other types of messages such as the execution of orders in the Hoken trade marketplace which you may not be able to unsubscribe from.

• In relation to the App, the settings menus of the App and of your operating system should allow you to manage notifications and preferences.

• You may terminate consent by contacting us assuming that Hoken is processing your personal information on the basis of consent. Any consent termination does not affect events before the consent termination nor will affect any personal information processing conducted in reliance on a legal basis other than consent.

Additional personal information rights are provided by certain countries and regions to its residents. These additional rights vary by country and region and may include, without limitation, the ability to request (1) a copy of your personal information; (2) information about the purpose of the processing activities; (3) deletion of personal information; (4) the restriction of our processing, use, disclosure, or sale of your personal information.

In addition, a data protection authority may be available to hear any complaints relating to the collection and use of personal information. Despite the availability of a data protection authority, we invite you to raise your concern first with us to hopefully solve it. You may submit your request by sending an email to support@gohoken.com.

International Data Transfer

Personal information we collect may be transmitted or transferred to countries other than the country in which you reside in the ordinary course of business. The data protection regime in such countries may vary from the laws of your country.

We have placed safeguards to protect your personal information and require that third party service providers have appropriate safeguards in place to protect your personal information, in compliance with applicable data protection law, but such law depends on the country or region of the service provider among other factors.

Record Retention

Your personal information is retained in accordance with applicable law, but no longer than necessary to fulfill the purposes set forth in this Privacy Statement. If your information may be used for analytical purposes, Hoken deidentifies, aggregates, or otherwise anonymizes your personal information. Different retention policies are applied according to the personal information in question, legal requirements, the data’s purpose, industry guidelines, our legitimate interests, or protection of ourselves. Retention periods are assessed continuously to ensure compliance and that your personal information is not preserved more than is absolutely necessary for processing purposes.

Your California Privacy Rights

The law of California allows California residents to request certain details about how their information is used, stored, and shared. Further, the residents of California under the California Consumer Privacy Act (CCPA) have the right to obtain access and request certain personal information collected the past 12 months or to request that personal information be erased or deleted with certain exceptions among other rights.

Additional Information Relating to Users Located in the UK and/or European Union

If you are located within the UK/EU, please note that we are acting as a data controller in collecting your personal information. You have the right to ask us which personal information we hold and ask for corrections if inaccurate. In addition, you can request the deletion of your personal information and ask for a copy of such information. You may have a right depending on the circumstances to object to personal information collection or processing or otherwise restrict its processing. If you wish to exercise your rights, please contact Hoken at support@gohoken.com.

We may share your personal information with third parties, which become our processors, in which case such processors assume the applicable data protection obligations in particular if any processing is carried out outside the UK or EU.

If you have a complaint about our personal information use, you may have a right to issue a complaint with an applicable data protection authority.

Contact Us

If you have any questions or concerns about personal information use, or desire to ask relating to our personal information practices, please contact us at support@gohoken.com.

Updates to Privacy Policy

We reserve the right and absolute discretion to amend or change this Privacy Statement in response to an evolving landscape relating to legal, technical, or business developments. The top of the first page specifies when this Privacy Policy was last updated.