Privacy Policy

The information collection, use, and dissemination practices of Hede Ventures Ltd. (the "Company") are discussed in this policy.

1. Collection of Information.
1.1 Survey Information. The Company collects information from individuals when an individual voluntarily completes a Company survey or order form or a registration page either online or offline, or by means of online or offline surveys or order forms or registration pages operated by third parties (collectively, a "Survey"). (As used herein, "online" means using the Internet and related technologies, and "offline" means by methods other than online, including in person, in the mail, using telephone and cell phones, and other methods of communication including future technologies.) In the Surveys, the Company or the third party (the "Third Party") may ask an individual to provide various information to the Company, which may include his or her name, email address, street address, zip code, telephone numbers (including cell phone numbers and carriers), birth date, gender, salary range, education and marital status, occupation, employment information, personal and online interests, and such other information as may requested from time to time (together, "Survey Information"). Completing the Surveys is completely voluntary, and individuals are under no obligation to provide Survey Information to the Company or Third Party, but an individual may receive incentives from the Company or a Third Party in exchange for providing Survey Information to the Company.

1.2 Third Party List Information. The Company does not purchase or otherwise acquire any customer information via lists from third parties.

1.3 Other Information. Other occasions when the Company requests personal information include (1) when an individual is making a claim for a prize or seeking to redeem an incentive offered by the Company, (2) when an individual requests assistance through Company's customer service department, and (3) when an individual voluntarily subscribes to a Company service or newsletter (together, "Other Information").

1.4 Cookie Information. The Company uses cookie and tracker technology to associate certain Internet-related information about an individual with information about the individual in our database ("Cookie and tracker Information"). A cookie is a small amount of data stored on the hard drive of the individual's computer which allows Company to identify the individual with his or her corresponding data that resides in Company's database. You may wish to read more about cookies at https://www.allaboutcookies.org/cookies/. Individuals who use certain of Company's web sites need to accept cookies in order to use of all of the features and functionality of the web sites. A "tracker" is an <img src="x"> link (for more information on trackers and how trackers are created, please see https://en.ryte.com/wiki/Tracking_Pixel or ) on an Internet page or in an email message that can be used to monitor who is reading the web page or email message. The following information can be sent to Company's computer when a tracker is viewed: the Internet protocol (or IP) address of an individual's computer, the URL of the page where the tracker is located, the time at which the tracker was viewed, the type of browser that received the tracker, and a previously set cookie. If information about the individual who receives the tracker is in Company's records, Company may associate the information received from the tracker with other information about the individual by using the cookie.

1.5 Outside Information. The Company may on rare occassion receive information about individuals from third parties ("Outside Information").

1.6 No Information Collected from Children. The Company does not intentionally collect personal information from children who are younger than age 13. Because it does not collect such information, the Company has no such information to use nor to disclose to third parties.

1.7 Individual Information. As used herein, Individual Information means Survey Information, Other Information, Cookie and Tracker Information, Outside Information, and any other information the Company gathers or receives about individuals.

2. Use of Individual Information.

2.1 Discretion to Use Information. The Company may use the Individual Information for any legally permissible purpose in Company's sole discretion. The following paragraphs in Section 2 describe how the Company currently uses the Individual Information, but the Company may change or broaden its use at any time. As noted below, the Company may update this policy from time to time. The Company may use Individual Information to provide promotional offers to individuals by means of email advertising, telephone marketing, direct mail marketing, online banner advertising, and package stuffers, among other possible uses.

2.2 Targeted Advertising. Based on the Individual Information, the Company attempts to customize and target advertising to an individual. When an individual is using Company web pages, the Company uses cookies and webbugs (see Section 2.5 below) to associate a person with the person's Individual Information, and the Company attempts to show advertising for products and services in which the person has expressed an interest in the Surveys and otherwise. The Company may, at its discretion, target advertising by using email, direct mail, telephones, cell phones, and other means of communication to provide promotional offers.

2.3 Email. The Company uses Individual Information to provide promotional offers by email to individuals. The Company may maintain separate email lists for different purposes. If email recipients wish to end their email subscription from a particular list, they need to follow the instructions at the end of each email message to unsubscribe from the particular list. To unsubscribe from all Company email lists, a person must email [email protected]

2.4 Direct Mail and Telemarketing. The Company uses Individual Information to advertise, directly or indirectly to individuals using direct mail marketing, on telemarketing using telephones and cell phones.

2.5 Use of Cookies and trackers. The Company uses the Cookie and tracker Information (1) to match a person's Cookie and Webbug Information to other categories of Individual Information to make and improve a profile of a person, (2) to track a person's web browsing habits on Company web sites and on the sites of its marketing partners, (3) to determine which areas of Company's web sites are most frequently visited. This information helps the Company to better understand the online habits of individuals so that the Company can attempt to customize and target advertising and promotions to them.

2.6 Profiles of Individuals. The Company uses Individual Information to make a profile of a person. A profile is created by associating the various sources of Individual Information.

2.7 Storage of Individual Information. The Company stores the Individual Information in a database on Company computers. Our computers have security measures (such as a firewall) in place to protect against the loss, misuse and alteration of the information under Company's control. Notwithstanding such measures, the Company cannot guarantee that its security measures will prevent the Company computers from being illegally accessed, and the Individual Information on them stolen or altered, and the Company assumes no responsibility for such actions.

3. Dissemination of Individual Information.

3.2 Order Fulfillment. The Company will transfer Individual Information to third parties when necessary to provide a product or service that a person orders from such third party while using Company web sites or when responding to offers provided by Company.

3.3 Legal Process. The Company may disclose Individual Information to respond to subpoenas, court orders, and other legal process.

3.4 Summary Data. The Company may sell or transfer non-individualized information, such as summary or aggregated anonymous information about all persons or sub-groups of persons.

4. Privacy Practices of Third Parties.

4.1 Advertiser cookies and trackers. Advertising agencies, advertising networks, and other companies (together, "Advertisers") who place advertisements on Company web sites may use their own cookies and webbugs on your computer and collect information from such cookies and webbugs. The Company does not control the Advertisers' use of their own cookies and webbugs and the Company has no responsibility for such cookies and webbugs and the use of information gathered from them.

4.2 Links. The Company's web sites and email messages sometimes contain hypertext links to the web sites of third parties. The Company is not responsible for the privacy practices or the content of such other web sites.

4.3 Disclosure of Information in Chat Rooms. Individuals should be aware that if they disclose personally identifiable information (for example, their name, address, telephone number, or email address) in chat rooms on Company sites, that information can be collected and used by third parties and may result in unsolicited messages from third parties, among other things. Such activities are beyond the control of the Company, and Company recommends that individuals use caution when disclosing personal information.

4.4 Affiliated Companies. The Company may disclose, transfer and sell Individual Information to entities affiliated with Company in Company's discretion.

5. Deleting Individual Information. Individuals have the ability to request deletion of their Individual Information by sending an email to [email protected]  in which they clearly request to have their Individual Information deleted from the Company database.

6. More Information. For more information about protecting your privacy, you may wish to visit www.privacyalliance.org. If you have questions about this policy, please contact us at [email protected]. The Company reserves the right to update this policy from time to time, so you should review this policy frequently.