Lovense Terms & Conditions for the Gift Purchaser

THIS PRIVACY POLICY CONTAINS IMPORTANT INFORMATION ABOUT YOUR PRIVACY RIGHTS AND HOW WE PROCESS YOUR PERSONAL DATA. PLEASE READ IT CAREFULLY.

Warning. The Lovense websites, the App, and the Services may contain or be used to transmit sexually explicit material intended for individuals 18 years of age or older. If you are under 18, if such material offends you, or if its viewing is unlawful in your jurisdiction, please do not access or use the Services.

As your Service provider, HYTTO PTE. LTD., its related corporations and affiliates ("the Company," "Lovense," "we," "our," or "us"), respect your privacy when we collect, store, use, share, transfer, and otherwise process Personal Data. Unless otherwise stated, HYTTO PTE. LTD. is the data controller of your Personal Data. This Privacy Policy explains our practices.

This Privacy Policy applies to all visitors, registered users, and customers of the Lovense website (www.lovense.com), the App, our software, and any other Lovense products or services (collectively, the "Services"), as well as personal data collected through other online or offline channels described below.

The terms "you," "your," and "yours" refer to any user of the Services. "Personal Data" means any information that identifies, relates to, or could reasonably be linked, directly or indirectly, to an identified or identifiable individual. The Lovense Privacy Policy is referred to as the "Privacy Policy."

By accessing or using the Services, you acknowledge that you have read and understood this Privacy Policyyou acknowledge that you have read and understood this Privacy Policy. Where applicable law requires, we will obtain your separate consent for specific processing activities, including the processing of special categories of personal data (such as data concerning health life), direct marketing communications, and certain cookies. If you do not agree with this Privacy Policy, please do not use the Services.

1. INFORMATION THAT WE MAY COLLECT

We may collect different categories of Personal Data when you create an account, visit our websites, purchase our products, use the App, or otherwise interact with the Services. Wherever the Company collects Personal Data, we make a reasonable effort to provide a link to this Privacy Policy.

The categories of Personal Data we may collect include:

a. Identifiers and Contact Information

Such as your real name, alias, postal address, email address, telephone number, account name, login credentials, and other similar identifiers. We collect telephone numbers and email addresses when you sign up for our Messaging Service, contests, sweepstakes, surveys, customer support, or other communications. The processing of this data is generally necessary for the performance of our contract with you or for taking steps prior to entering into a contract.

b. Commercial and Transactional Information

Records of products or services purchased, obtained, returned, or considered, payment information, billing and shipping addresses, and other purchasing or consumption histories or tendencies.

c. Messaging and Communication History

When you communicate with us through the Services - including via customer support, contests, sweepstakes, research studies, or surveys - we may collect the contents of your messages, your communication history, and any other information you choose to provide.

User-to-User Communications. Lovense is committed to respecting the privacy of communications between users:

Private chats and messages between users are not collected, monitored, accessed, or stored by the Company in the ordinary course of business, except as strictly required by law (such as in response to a valid legal request) or to investigate suspected violations of our Terms (such as harassment, illegal content, or abuse) reported through our reporting channels.

The Company does not use the contents of user-to-user communications for marketing, profiling, or training of artificial intelligence systems.

d. Internet and Electronic Network Activity

Including User Content, browsing history, search history, click-stream data, advertising interactions, and information regarding your interaction with our websites, the App, or advertisements.

e. Audio, Electronic, Visual, and Similar Information

f. Device and Product-Use Data

Information collected by Lovense-related software and connected products, including activation dates and times, device details (such as model, operating system, and firmware version), connection logs, feature-usage statistics, error logs, and crash reports. This data helps us ensure the proper operation, security, and improvement of our Services.

g. User-Generated Content and Public Activities

Comments, product reviews, forum posts, and other content you choose to make publicly available through the Services. Please note that any information you post publicly may be read, collected, and used by other users or third parties. We are not obligated to publish or retain any User Content, and we may remove, modify, or decline to publish content as set forth in our Terms and Conditions.

h. General Fitness Data

If you choose to use general fitness features within the App (such as targeted exercises), we collect related usage data solely to provide feedback, track progress, and enhance your experience. Lovense products and their fitness features are not medical devices, and the data we collect is not intended for the diagnosis, treatment, prevention, or cure of any disease or health condition. Any insights are provided for personal fitness, and entertainment purposes only.

i.IP Addresses and Approximate Location

When you visit our websites or use the App, we collect IP addresses and derive approximate geographic location (such as country or region) for purposes including security, fraud prevention, regional content delivery, and aggregated analytics.

j. Automatically Collected and Aggregated Information

Non-Identifiable Information. When you interact with the Services, we may passively collect certain non-identifiable information using various technologies. Such information cannot presently be used, on its own, to identify you. We may use this information - alone or pooled with other information - for purposes such as measuring the number of visitors, identifying the most-viewed pages, or analyzing the domains of visitors' Internet service providers.

Aggregated Information. We may aggregate Personal Data to study user demographics, interests, and behavior in order to better understand and serve our users. Aggregated information does not identify you personally and may be shared with our affiliates, agents, business partners, or third parties for lawful business purposes.

k. Cookies and Similar Technologies

Our websites and the App use cookies and similar tracking technologies to recognize you, remember your preferences, analyze usage, and improve your experience. Cookies are small text files placed on your device; they cannot run programs or deliver viruses. Cookies are categorized as:

Session cookies, which exist only during your browsing session and are deleted when you close your browser; and Persistent cookies, which remain on your device for a defined period or until you delete them.

You may accept or reject cookies through our cookie banner, your browser settings, or your account preferences. Declining cookies may affect the functionality of the Services.

For further details, please refer to our Cookie Policy.

2. HOW WE USE YOUR PERSONAL DATA AND OTHER INFORMATION

The Company processes your Personal Data in a manner consistent with this Privacy Policy and the legal bases described below. Where you use multiple Lovense products, applications, or services, we may combine and use data collected across them - including activity data - to deliver, operate, and improve the Services.

We process your Personal Data for the following purposes:

a. Account Creation, Authentication, and Service Delivery

To register your account, authenticate you, deliver the Services you have requested, and provide unified access across the Lovense ecosystem. When you create an account on the Lovense website (www.lovense.com), your account credentials (such as email address) may be shared with the App and other Lovense applications to enable seamless single-sign-on login.

b. Orders, Payments, and Fulfillment

To process and fulfill your orders, manage payments, arrange shipping, handle returns and refunds, and provide warranty support.

c. Customer Support and Communications

To respond to your inquiries, provide technical and customer support, troubleshoot issues, and communicate with you about your account, transactions, security alerts, and other service-related matters.

d. Remote-Control, Pairing, and Interactive Use of Products

To enable the remote-control, pairing, and interactive features of Lovense connected products — including device-to-device synchronization, partner pairing, and real-time control sessions between users. For these features, we process device identifiers, connection logs, session metadata, and, where applicable, the contents of associated communications.

e. AI-Powered Features and Outputs

To provide and operate AI-powered features, including content generation, personalization, recommendations, and conversational tools (whether developed by the Company or provided by third-party AI providers). We may process your Inputs, Outputs, and related interaction data to deliver the AI Service, ensure its safety and reliability, and prevent misuse. We do not use your Inputs or Outputs to train third-party AI providers' general-purpose foundation models without your separate consent where such consent is required by applicable law.

f. Personalization and Recommendations

To personalize your experience, recommend relevant products, content, communities, and features, and improve the relevance of the Services to your interests. Where personalization relies on special categories of personal data, we process such data only with your explicit consent, which you may withdraw at any time.

g. Service Improvement, Analytics, and Research

To analyze usage patterns, measure performance, conduct research and statistical analysis, develop new features and products, and improve the content, functionality, and user experience of the Services. Wherever practicable, we use aggregated or anonymized data for these purposes.

h. Marketing and Promotional Communications

To send you, where permitted, information about our products, applications, services, new features, updates, promotions, and announcements. For users in the EU, UK, and other jurisdictions where opt-in consent is required, marketing communications will be sent only with your prior consent. For users in the US, we comply with the CAN-SPAM Act and provide an easy opt-out mechanism. You may withdraw consent or opt out at any time by following the unsubscribe instructions in any marketing message, by adjusting your account preferences, or by contacting us at [[email protected]].

i. Messaging Service

To deliver, operate, analyze, maintain, support, customize, and personalize the Lovense Messaging Service, and to enhance its features.

j. Safety, Security, and Fraud Prevention

To protect the security and integrity of the Services, our users, and our products; detect and prevent fraud, abuse, unauthorized access, harmful content, and other illegal or prohibited activity; investigate violations of this Privacy Policy or our Terms; verify user identity and age; and enforce our agreements.

k. Legal Compliance and Protection of Rights

To comply with applicable laws, regulations, court orders, subpoenas, governmental requests, and law-enforcement inquiries; to respond to mandatory reporting obligations (including those concerning child sexual abuse material); to establish, exercise, or defend legal claims; and to protect the rights, property, and safety of the Company, our users, or any third party.

l. Other Purposes Disclosed at Collection

If you provide Personal Data for a specific purpose, we will use it for that purpose. If we intend to use your Personal Data for any purpose that is materially different from those described above, we will inform you and, where required by law, obtain your consent before doing so.

m. Consent

By voluntarily providing Personal Data to the Company, you acknowledge that we may process it in accordance with this Privacy Policy. Where applicable law requires explicit consent - such as for special categories of personal data, direct marketing, or non-essential cookies - we will obtain such consent separately, and you may withdraw it at any time without affecting the lawfulness of prior processing.

3. THIRD-PARTY RECIPIENTS OF YOUR PERSONAL DATA

The Company does not sell your Personal Data. Maintaining your privacy is a vital part of our relationship with you and an important aspect of the Services we provide. There are, however, certain limited circumstances in which we may share your Personal Data with third parties, as described below:

a. Affiliates and Group Companies. We may share your Personal Data within HYTTO PTE. LTD., its related corporations, and affiliates for the purposes described in this Privacy Policy and subject to appropriate safeguards.

b. Service Providers and Processors. We engage trusted third parties to perform business-related functions on our behalf — such as hosting, payment processing, order fulfillment, shipping, customer support, communications, analytics, fraud prevention, and IT services. Such service providers process Personal Data only on our documented instructions, under written contracts that impose confidentiality and security obligations, and only the data necessary to perform their specific function.

c. Third-Party Partners and Integrations. We partner with third parties — including, where applicable, AI service providers, advertising partners, and platform integrators — to deliver certain features of the Services. We make reasonable efforts to limit how these partners may use information they collect from you or that we provide. Their processing of your Personal Data is governed by their own privacy policies, which we encourage you to review and, where required, accept separately.

d. Business Transfers. In the event of a corporate sale, merger, acquisition, reorganization, financing, dissolution, bankruptcy, or similar transaction, Personal Data may be transferred as part of the assets involved. We will notify affected users where required by law and ensure that any successor honors the commitments of this Privacy Policy.

e. Legal and Safety Requirements. We may disclose Personal Data where we believe in good faith that doing so is necessary to: (i) comply with applicable law, regulation, court order, subpoena, or legal process; (ii) respond to lawful requests from public authorities, including for national security or law-enforcement purposes; (iii) comply with mandatory reporting obligations, including those concerning child sexual abuse material; (iv) enforce our Terms or other agreements, or investigate suspected violations; (v) protect the rights, property, safety, or interests of the Company, our users, or any third party; or (vi) protect against legal liability.

f. With Your Consent or at Your Direction. We may share your Personal Data for any other purpose disclosed to you with your consent or at your direction.

We do not "sell" or "share" your Personal Data within the meaning of the CCPA/CPRA or analogous laws, except as expressly described in this Privacy Policy.

4. HOW LONG WE KEEP YOUR INFORMATION

We retain your Personal Data only for as long as is necessary to fulfill the purposes for which it was collected, as described in this Privacy Policy, and in each case in accordance with applicable legal and regulatory requirements (including permitted or required retention periods and limitation periods relevant to legal action).

Retention Criteria. The retention period for any given category of Personal Data is determined on a case-by-case basis, taking into account factors such as: (a) the nature, sensitivity, and volume of the Personal Data; (b) the purposes for which it was collected and processed; (c) the potential risk of harm from unauthorized use or disclosure; (d) whether the purposes can be achieved through other means; (e) applicable legal, regulatory, tax, accounting, or operational retention requirements; and (f) the time period during which legal claims may be brought.

General Retention Periods. By way of general guidance, and unless a longer retention period is required or permitted by applicable law:

• Account Data is retained for the duration of your active account and for a reasonable period thereafter to handle account closure, disputes, and legal claims.
• Transaction and Order Records are retained as required by applicable tax, accounting, consumer-protection, and warranty laws.
• Customer Support Communications are retained for a reasonable period after the matter is resolved, to enable follow-up and quality assurance.
• Community Message Caches are routinely and automatically purged on a regular basis to manage our storage capacity.
• Marketing Records (including consents and unsubscribe records) are retained for as long as required to demonstrate compliance with applicable laws.
• Logs, Security, and Fraud-Prevention Data are retained for the period necessary to detect, investigate, and respond to security incidents and fraudulent activity.

When Personal Data is no longer required, we will either delete it, anonymize it, or securely archive it in a manner that prevents further processing, except where retention is required by applicable law.

Account Closure and Deletion Requests. If you wish to close your registered account or delete the Personal Data you have provided to us, please follow the relevant instructions in your account settings or contact us by email at [[email protected]]. We will action your request in accordance with applicable law, subject to our right to retain certain information where necessary to comply with legal obligations, resolve disputes, prevent fraud or abuse, enforce our agreements, or protect the rights, property, or safety of the Company, our users, or any third party. Residual copies of Personal Data may remain in our backup systems for a limited period before being securely overwritten.

Content Sent to Third Parties. Any content that you send, transmit, share, or otherwise make available to a recipient (including another user or any third party) through the Services does not fall within the scope of the Personal Data we control once it has been delivered. The Company disclaims any obligation or liability for the acquisition, retention, use, further disclosure, or onward transfer of such content by any recipient or third party.

5. CHILDREN SHOULD NOT SUBMIT PERSONAL DATA

The Services are intended exclusively for adults. The Company does not knowingly collect, solicit, or process Personal Data from individuals under the age of 18 (or the age of legal majority in your jurisdiction, whichever is greater). If you are under such age, please do not access or use the Services and do not submit any Personal Data through the Services.

We encourage parents and legal guardians to monitor their children's internet activity and to help enforce this Privacy Policy by instructing minors under their care never to provide Personal Data through the Services. If you are a parent or legal guardian and become aware that a minor under your care has provided Personal Data to the Company, or if you otherwise have reason to believe that we may have inadvertently collected Personal Data from a person under the age of 18, please contact us promptly at [[email protected]]. Upon verification, we will take reasonable steps to delete such information from our records, in accordance with applicable laws (including, where applicable, the U.S. Children's Online Privacy Protection Act ("COPPA"), Article 8 of the GDPR, and analogous laws in other jurisdictions).

6. HOW WE SECURE YOUR INFORMATION AND CONTENT

The Company takes commercially reasonable technical and organizational measures to protect the Personal Data we process against loss, misuse, and unauthorized access, disclosure, alteration, or destruction, taking into account the nature, scope, and purposes of processing and the risks to your rights and freedoms.

Account-identifiable and user-identifiable data we collect — including emails, phone numbers, and account credentials — are protected by encryption in transit and at rest, access controls, authentication mechanisms, and other safeguards appropriate to the sensitivity of the data. Personal Data is stored on our secured internal databases, and accessible data associated with your account or profile can be retrieved only upon presentation of valid account credentials.

Please be aware, however, that no method of internet transmission, email, or electronic storage is ever fully secure or error-free, and information transmitted via the Services may be intercepted, accessed, disclosed, or altered. In particular, email sent to or from the Services may not be secure. You should therefore exercise care in deciding what information you transmit to us, and promptly notify us at [[email protected]] if you suspect any unauthorized access to or use of your account.

All payments for products and services are processed by third-party payment providers. The Company makes good-faith efforts to engage providers that employ appropriate protections for personal and payment data. However, the Company does not control such providers and disclaims any obligation or liability for their processing activities, security measures, or compliance, except to the extent required by applicable law.

7. YOUR RIGHTS

Under the GDPR, the CCPA, the UK GDPR, and analogous laws, you have the following rights in relation to the Company's processing of your Personal Data. Where your jurisdiction grants additional or stronger rights, those rights shall apply.

a. Right to withdraw consent. Where processing is based on your consent, you may withdraw such consent at any time by notifying the Company. Withdrawal does not affect the lawfulness of any processing carried out before the withdrawal, nor processing based on other lawful grounds.

b. Right to data portability. You have the right to receive a copy of the Personal Data you have provided to the Company, in a structured, commonly used, and machine-readable format, and to transmit such data to another controller, where technically feasible and where processing is based on consent or contract.

c. Right to erasure ("right to be forgotten"). You have the right to request the deletion of Personal Data we hold about you. While we can erase data from our active records, copies may persist temporarily in inactive, archived, or backup systems and will be deleted in accordance with our retention and document-management policies. In certain cases, we may be required or permitted by law to retain Personal Data — for example, to comply with legal obligations, resolve disputes, or enforce our agreements.

d. Right to restriction of processing. You may request that we restrict the processing of your Personal Data in certain circumstances permitted by law (for example, where you contest the data's accuracy or object to processing). Restriction may affect your ability to access or use parts of the Services.

e. Right of access. You have the right to obtain confirmation as to whether we process Personal Data concerning you and, where we do, access to such data and to supplementary information about the processing, as required by applicable law.

f. Right to rectification. You have the right to request the rectification of inaccurate Personal Data and the completion of incomplete Personal Data we hold about you.

g. Right to object. Where processing is based on our legitimate interests or the performance of a task in the public interest, you have the right to object on grounds relating to your particular situation. You also have an unconditional right to object to processing of your Personal Data for direct-marketing purposes, including any related profiling.

h. Rights related to automated decision-making. You have the right not to be subject to a decision based solely on automated processing — including profiling — that produces legal effects concerning you or similarly significantly affects you, except as permitted by law.

To exercise any of these rights, please contact us at [[email protected]]. We will respond without undue delay and, in any event, within the time limits required by applicable law (generally one month). We may need to verify your identity before processing your request, and exercising certain rights may affect your ability to use the Services where the relevant Personal Data is necessary for their operation.

8. SUPPLEMENTAL NOTICE FOR USERS OF AI-POWERED SERVICES

This Section explains how we process your Personal Data when you use the AI-powered features of our Services (the "AI Service") and supplements the AI Service provisions of our Terms and Conditions.

(a) What we process. Personal Data contained in your Inputs (content you submit) and Outputs (content generated in response).

(b) Purposes and recipients. To deliver, operate, and improve the AI Service, including by transmitting Inputs and Outputs to third-party service providers ("AI Providers").

(c) Use by AI Providers. Subject to applicable law and AI Providers' own terms, AI Providers may use Inputs and Outputs to operate and improve their services, including, where lawful, to train or fine-tune their AI models. Where separate consent is required by law, we will obtain it before transmission.

(d) Sensitive information. Please refrain from including sensitive Personal Data or special categories of personal data (such as health data) in your Inputs. Where you nonetheless do so, you are deemed to consent to such processing.

(e) AI Providers' policies. Our Privacy Policy governs the Company's processing. AI Providers' processing is governed by their own privacy policies, which we encourage you to review. We are not responsible for AI Providers' processing, except as required by law.

(f) Lovense AI CS. We process Personal Data in your interactions with Lovense AI CS solely to provide customer support. You may request a human agent at any time by contacting [[email protected]].

9. CHANGES TO THIS PRIVACY POLICY

The Company may modify, amend, or otherwise update this Privacy Policy from time to time as necessary to reflect legal requirements, changes in our business practices, or other factors. Where changes are material, we will communicated through the App, the Lovense website, by email, or by other reasonable means, and will take effect on the date specified in the notice or, where no date is specified, upon publication.

Your continued use of the Services following the effective date of any revised Privacy Policy constitutes your acknowledgment of the changes. If you do not agree with the updated Privacy Policy, please discontinue use of the Services.

To contact us regarding this Privacy Policy, your rights, or any other privacy-related matter, please email [[email protected]].

10. DISPUTE RESOLUTION

Any dispute, claim, or controversy arising out of or relating to this Privacy Policy, the processing of your Personal Data, or your privacy rights in connection with the Services (each, a "Dispute") shall be resolved in accordance with the dispute-resolution provisions set forth in our Terms and Conditions, including the provisions on governing law, informal resolution, binding arbitration administered by the Hong Kong International Arbitration Centre (HKIAC), class-action and jury-trial waivers, and applicable carve-outs. By using the Services, you acknowledge and agree to those provisions, which are incorporated into this Privacy Policy by reference.

For further details regarding the arbitration process and applicable laws, please refer to the "GOVERNING LAW AND DISPUTE RESOLUTION" section of our Terms and Conditions.

11. ENTIRE AGREEMENT AND CONTACT US

This Privacy Policy forms an integral part of, and should be read together with, the Lovense Terms and Conditions. By accessing or using the Services, you acknowledge that you have read, understood, and agreed to both this Privacy Policy and the Terms and Conditions, and that the two documents - together with any other policies expressly incorporated therein - constitute the complete agreement governing your use of the Services and the Company's processing of your Personal Data.

If you have any questions or concerns regarding this Privacy Policy, please contact us by email at [[email protected]].