Privacy Policy
🏢 Data controller:HOCL Hub Ltd
🌐 Applies to:us.hoclhub.com
This Privacy Policy applies to us.hoclhub.com and explains how HOCL Hub Ltd collects, uses, and protects your personal data. California residents: your additional CCPA rights are set out in Section 8.
Who Controls Your Data
| Controller | HOCL Hub Ltd |
| Company number | 16406845 (England & Wales) |
| Registered office | 128 City Road, London, EC1V 2NX, England |
| ICO registration | [ICO REGISTRATION NUMBER — add before publishing] |
| Privacy contact | privacy@hoclhub.com |
| General contact | info@hoclhub.com |
For UAE customers whose data is processed in connection with an H O C L Trading transaction, H O C L Trading (Trade Licence No. 1440003, Dubai) acts as the data controller for that processing.
What Data We Collect
Data you give us directly:
- Name and contact details — when you create an account, place an order, or contact us
- Billing and delivery address — including US state and ZIP code
- Payment information — processed securely through our payment provider; we do not store card details
- Business details — if you are enquiring about wholesale, white label, or private label services
- Messages and correspondence — emails, contact forms
Data we collect automatically:
- IP address and approximate location — including US state
- Device type, browser, and operating system
- Pages visited, time on page, and navigation path
- Referring URL
- Cookie data — see our Cookie Policy at us.hoclhub.com/cookies
Data from third parties:
If you log in via a third-party account (such as Google), we receive the basic profile that account shares — typically name and email. We do not receive payment data via social login.
Why We Use Your Data
| Purpose | Data used | Lawful basis |
|---|---|---|
| Processing and fulfilling your order | Name, address, payment, order details | Contract performance |
| Managing your account | Account credentials, purchase history | Contract performance |
| Responding to enquiries and support requests | Name, email, message content | Legitimate interests |
| Sending marketing emails (where you have opted in) | Email address, purchase history | Consent |
| Improving the site — analytics and performance | Usage data, cookies | Legitimate interests / Consent |
| Complying with legal obligations | Order records, financial data | Legal obligation |
How Long We Keep Your Data
| Data type | Retention period |
|---|---|
| Order and financial records | 7 years (UK legal requirement for financial records) |
| Account data | Duration of account, plus 12 months after closure |
| Marketing consent records | Until consent is withdrawn |
| Support correspondence | 3 years from last contact |
| Analytics and usage data | 26 months (Google Analytics default) |
Who We Share Your Data With
We do not sell your personal data. We share it only where necessary to operate the platform, fulfil your order, or meet a legal obligation.
- Payment processors — to handle your transaction securely
- Shipping and logistics partners — to fulfil and deliver your order within the US
- Manufacturing and distribution partners — for order fulfilment where direct dispatch applies
- IT and platform providers — hosting, email, analytics, customer support tools
- Legal and regulatory authorities — where required by law or valid legal process
International Data Transfers
Your data is processed by HOCL Hub Ltd in the UK. This means your personal data is transferred from the US to the UK. The UK has been granted an adequacy decision by the European Commission for data protection purposes. We apply UK GDPR standards to all data we process.Where data is shared with processors in other countries, we ensure appropriate contractual safeguards are in place.
Your Rights
As a US customer whose data is processed under UK GDPR, you have the following rights. Contact privacy@hoclhub.com to exercise any of them.
| Right | What it means |
|---|---|
| Access | Request a copy of the personal data we hold about you. |
| Rectification | Ask us to correct inaccurate or incomplete data. |
| Erasure | Ask us to delete your data where we no longer have a lawful basis to hold it. |
| Restriction | Ask us to pause processing your data in certain circumstances. |
| Portability | Receive your data in a structured, machine-readable format and transfer it to another controller. |
| Objection | Object to processing based on legitimate interests, including for direct marketing. |
| Withdraw consent | Where processing is based on consent, withdraw it at any time. This does not affect processing carried out before withdrawal. |
| Complain | Lodge a complaint with the UK Information Commissioner's Office (ICO) at ico.org.uk if you believe we have mishandled your data. |
California Residents — CCPA Disclosures
If you are a California resident, the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA) gives you additional rights over your personal information.
Categories of personal information we collect
- Identifiers — name, email address, IP address, account credentials
- Commercial information — purchase history, products considered
- Internet or electronic network activity — browsing behaviour on our site
- Geolocation data — approximate location derived from IP address
We do not sell or share your personal information
HOCl Hub does not sell your personal information to third parties. We do not share your personal information with third parties for cross-context behavioural advertising.
Your California rights
- Right to know — request disclosure of the personal information we have collected about you and how we use and share it
- Right to delete — request deletion of your personal information, subject to certain exceptions
- Right to correct — request correction of inaccurate personal information
- Right to opt out of sale or sharing — we do not sell or share personal information, so this right is not applicable
- Right to limit use of sensitive personal information — we do not use sensitive personal information beyond what is necessary to fulfil your order
- Right to non-discrimination — we will not discriminate against you for exercising any of your CCPA rights
To exercise your California rights, contact privacy@hoclhub.com with the subject line 'California Privacy Request'. We will respond within 45 days. You may designate an authorised agent to submit a request on your behalf.
Security
We use HTTPS encryption across all pages of us.hoclhub.com. Access to personal data is restricted to authorised staff and processors only. If you believe your account has been compromised, contact us immediately at info@hoclhub.com.
Children
us.hoclhub.com is for users aged 18 and over. We do not knowingly collect personal data from anyone under 18. If you believe a minor has shared data with us, contact privacy@hoclhub.com and we will delete it promptly.
Cookies
We use cookies on us.hoclhub.com. Our Cookie Policy at us.hoclhub.com/cookies explains what we use, why, and how to manage your preferences. California residents can opt out of any cookies that constitute a sale or sharing of personal information — currently none do.
Changes to This Policy
We will update this policy when our practices change or the law requires it. The effective date at the top will always reflect the current version.
Contact
For any privacy-related query, data subject request, or complaint:
| privacy@hoclhub.com | |
| Post | HOCL Hub Ltd, 128 City Road, London, EC1V 2NX, England |
| ICO (UK regulator) | ico.org.uk | 0303 123 1113 |