Privacy Policy

Last Modified: July 1, 2026

The controller responsible for processing personal data within the meaning of the EU General Data Protection Regulation (GDPR), the Hessian Data Protection and Freedom of Information Act (HDSIG), and other national data protection laws of the Member States.

Lamma Global Europe DOO ("HOPO", "we", "our", or "us") respect your privacy and are committed to protecting it through our compliance with this policy. This policy describes how we collect, process, retain, and disclose personal data about you when providing services to you through our websites, and services that link to this policy (our "Services") and our practices for using, maintaining, protecting, and disclosing that information.

This policy applies only to information we collect:

• Through the Services.
• In communications, including email, text, chat, and other electronic messages, between you and the Services.

It does not apply to information collected by:

• Us through any other means, including on any other website operated by HOPO or any third party that does not link to this policy; or
• Any third party, including through any application or content (including advertising) that may link to or be accessible from or through the Services.

We may provide additional or different privacy policies that are specific to certain features, services, or activities.

Please read this policy carefully to understand our policies and practices regarding your information and how we treat it. By interacting with our Services or providing us with your information, you agree to the collection, use, and sharing of your information as described in this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of the Services after we make changes as described here is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children's and Minors' Data

Our Services are not intended for, and we do not knowingly collect any personal data from, children under the age of 18. If we learn we have collected or received personal data from a child under 18 years old without verification of parental consent, we will delete that information.

The Personal Data That We Collect or Process

"Personal data" is information that identifies, relates to, or describes, directly or indirectly, you as an individual, such as your name, email address, telephone number, your employment information and any other identifier we may use to contact you online or offline.

The types and categories of personal data we collect or process include:

• Contact information, including name, work address, your employment, email address, phone number, and other contact information you provide us.
• Device information, including your IP address, device identifiers, operating system and version, preferred language, hardware identifiers, browser type and settings, and other device information.

We also collect:

• Statistics or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal data. For example, we may aggregate personal data to calculate the percentage of users accessing a specific Services feature.
• Technical information. Technical information includes information about your internet connection and usage details about your interactions with the Services, such as clickstream information to, through, and from our Services (including date and time), products that you view or search for; page response times, download errors, length of your visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), or methods used to browse away from a page.

If we combine or connect non-personal statistical or technical data with personal data so that it directly or indirectly identifies an individual, we treat the combined information as personal information.

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).

How We Collect Your Personal and Other Data

You Provide Information to Us

We collect information about you when you interact with our Services, such as when you make an inquiry or contact us.

Automatically Through Our Services

As you navigate through and interact with our Services, we may use automatic data collection technologies to collect information that may include personal data. Information collected automatically may include usage details, IP addresses, operating system, and browser type, and information collected through cookies and other tracking technologies including details of your interactions with our Services, such as traffic data, location data, and other communication data, and which resources and Services features that you access and use.

We may use these automatic collection technologies to collect information about your online activities over time and across third-party sites or other online services (behavioral tracking).

Using automatic collection technologies helps us to improve our Services and to deliver a better and more personalized experience.

The technologies we use for this automatic data collection may include:

• Cookies. A cookie is a small file placed on your device when you interact with the Services. You may refuse to accept or disable cookies by activating the appropriate setting on your browser or device. However, if you select this setting, you may be unable to access certain features of the Services. Read more about cookies below.

When you interact with the Services, there are third parties that may use automatic collection technologies to collect information about your or your device. These third parties may include:

• Advertisers, ad networks, and ad servers.
• Analytics companies.
• Your device manufacturer.
• Your internet or mobile service provider.

These third parties may use tracking technologies to collect information about you when you use the Services. The information they collect may be associated with your personal data or they may collect information, including personal data, about your online activities over time and across different websites, apps, platforms, and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

We use the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our website. These essential cookies are always enabled because our website won’t work properly without them. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services. You can switch off these cookies in your browser settings but you may then not be able to access all or parts of our website.

Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose so that they can serve you with relevant advertising on their websites.

To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.

Choices about cookies

You can choose which analytical, functionality and targeting cookies we can set by clicking on the button(s):

Strictly necessary cookies ALWAYS ACTIVE

Analytical or performance cookies OFF

Functionality cookies OFF

Targeting cookies OFF

You can also choose to "Reject All" cookies in the cookie banner.

However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

Except for essential cookies, all cookies will expire after five years.

If you have any questions or concerns about our use of cookies, please send us an email at socials@hopoeu.com.

How We Use Your Information

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

We use information that we collect about you or that you provide to us, including any personal data, to:

• Provide you with the Services and any contents, features, information, products, or services that we make available through the Services.
• Fulfill any other purpose for which you provide it.
• Improve our Services, including by analyzing your information and creating aggregated data derived from your information) to develop, maintain, analyze, improve, optimize, measure, and report on our Services and their features and how users interact with them.
• Promote our Services, business, and offerings by publishing advertising on our own Services and by placing ads on third parties' services. We may use your information to model, segment, target, offer, market, and advertise our Services.
• Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• Notify you when Services updates are available and about changes to any products or services we offer or provide though them.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

The usage information we collect, whether connected to your personal data or not, helps us improve our Services and deliver a better and more personalized experience by enabling us to:

• Estimate our audience sizes and usage patterns.
• Store information about your preferences, allowing us to customize the Services according to your individual needs and interests.
• Speed up your searches.
• Recognize you when you return to our Services.

Large Language Model Training Disclosure

We do not collect, use, or sell personal data for the purpose of training large language models.

Direct marketing

You will receive marketing communications from us if you have requested information from us.

We may also analyse your identity, contact, technical, usage and profile data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

Third-party marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

Who We Disclose Your Information To

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may also disclose personal data that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our organization and who are bound by contractual obligations to keep personal data confidential and use it only for the purposes for which we disclose it to them.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of HOPO assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by HOPO is among the assets transferred.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal data:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our terms of use https://hopoeu.com/terms and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our organization, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

The categories of personal data we may disclose include:

• Device information.
• Content and information you elect to provide to us.

Your Rights and Choices About Your Information

This section describes mechanisms you can use to control certain uses and disclosures of your information and rights you may have under GDPR.

If your personal data are processed, you have the following rights under the GDPR:

Right of access (Art. 15 GDPR, § 52 HDSIG)

Right to rectification (Art. 16 GDPR, § 53 HDSIG)

Right to erasure (Art. 17 GDPR, § 53 HDSIG)

Right to restriction of processing (Art. 18 GDPR, § 53 HDSIG

Right to data portability (Art. 20 GDPR)

Right to lodge a complaint (Art. 77 GDPR) with a supervisory authority, in this case:

The Hessian Data Protection Commissioner, Gustav-Stresemann-Ring 1, 65189 Wiesbaden,

P.O. Box 3163, 65021 Wiesbaden,

Email: poststelle@datenschutz.hessen.de,

Tel.: +49 611 1408-0.

Right to object (Art. 21 GDPR): You may object at any time on grounds relating to your particular situation to processing based on Article 6(1)(f) GDPR.

If your data are processed for direct marketing, you may object to such processing at any time.

Right to withdraw consent: You may withdraw consent at any time without affecting the lawfulness of prior processing. Withdrawals can be sent at socials@hopoeu.com.

Tracking technologies choices:

• Cookies and Other Tracking Technologies. You can set your browser to refuse all or some browser cookies or other tracking technology files, or to alert you when these files are being sent. You can choose whether or not to allow the Services to collect information through other tracking technologies by disabling such technologies through the website. If you disable or refuse cookies or similar tracking files, some Services features may be inaccessible or not function properly. Some browsers include a "Do Not Track" (DNT) setting that can send a signal to the online services you visit indicating you do not wish to be tracked.

Location data choices:

• Location Data. You can choose whether or not to allow the Services to collect and use real-time information about your device's location through the device's privacy settings. If you block the use of location information, some Services features may become inaccessible or not function properly.
• International transfers
• We share your personal data within the HOPO Group. This will involve transferring your data outside Germany to our overseas offices in Poland, Netherlands, France and may involve transferring your data to offices in other countries. In all times such data transfer is performed in accordance with the General Data Protection Regulation (GDPR).
• Whenever we transfer your personal data out of EU to countries which have laws that do not provide the same level of data protection as the EU law, we always ensure that a similar degree of protection is afforded to it by ensuring that the following safeguards are implemented:
• We use specific standard contractual terms approved for use in EU which give the transferred personal data the same protection as it has in EU.

We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the EU to countries which have laws that do not provide the same level of data protection as the EU law.

Whenever we transfer your personal data out of the EU to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:

• We will only transfer your personal data to countries that have been deemed by the EU to provide an adequate level of protection for personal data,
• We may use specific standard contractual terms approved for use in the EU which give the transferred personal data the same protection as it has in the EU, namely the standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 (SCCs).

How We Protect Your Personal Data

We use commercially reasonable administrative, physical, and technical measures designed to protect your personal data from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. However, no website, mobile application, system, electronic storage, or online service is completely secure, and we cannot guarantee the security of your personal data transmitted to, through, using, or in connection with the Services. In particular, email, texts, and chats sent to or from the Services may not be secure, and you should carefully decide what information you send to us via such communications channels. Any transmission of personal data is at your own risk.

The safety and security of your information also depends on you. You are responsible for taking steps to protect your personal data against unauthorized use, disclosure, and access.

How We Retain Your Personal Data

We keep the categories of personal data described in this policy for as long as reasonably necessary to fulfill the purposes described or for as otherwise legally permitted or required, such as maintaining the Services, operating our organization, complying with our legal obligations, resolving disputes, and for safety, security, and fraud prevention. This means that we consider our legal and business obligations, potential risks of harm, and nature of the information when deciding how long to retain personal data. At the end of the retention period, personal data will be deleted, destroyed, or deidentified.

Changes to Our Privacy Policy

We may update this policy from time to time, and we will provide notice of any such changes to the policy as required by law. The date the privacy policy was last updated is identified at the top of the page. We will notify you of changes to this policy by updating the "last updated" date and posting the updated policy on the Services. We may email or otherwise communicate reminders about this policy, but you should check our Services periodically to see the current policy and any changes we have made to it.

Your legal rights

You have a number of rights under data protection laws in relation to your personal data.

You have the right to:

• Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
• If you want us to establish the data's accuracy;
• Where our use of the data is unlawful but you do not want us to erase it;
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• If you wish to exercise any of the rights set out above, [please contact us at Contact details.
• No fee usually required
• You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Complaints

You have the right to make a complaint to the Hessian Data Protection Commissioner (HDSB), the regulator for data protection issues. However, before doing so please make sure you have first made your complaint to us or asked us for clarification if there is something you do not understand. The HDSB will expect you to have done this before reviewing your complaint. You can file your complaints at socials@hopoeu.com.

Contact Information

To exercise your rights or ask questions or comment about this privacy policy or our privacy practices, contact us at:

Lyoner Stern 5th floor,Hahnstraße 70, Frankfurt am Main 60528

socials@hopoeu.com