Privacy Policy

Effective date: August 29, 2026 Company: Hands on Concepts 3 Inc., operating as Hands on Concepts ("HOC," "we," "us," or "our") Contact: info@teamhoc.com | +1 619-396-5925 Mailing and operating address: 1330 La Cresta Blvd., El Cajon, California 92021, USA

This policy describes the personal information HOC processes, why it is used, when it is disclosed, how long it is retained, and the choices and rights available to individuals.

1. Scope and Roles

This policy applies to HOC websites, accounts, portals, configurators, saved and submitted builds, fittings, messages, files, signatures, sales, shipping, support, warranty, safety, dealer administration, and related services. Depending on the transaction and law, HOC may act as a business, controller, covered entity under a consumer-health law, independent contractor, or service provider. Dealers, clinicians, payers, manufacturers, and payment processors may have their own privacy notices and independent responsibilities.

2. Information We Collect

HOC may collect:

• identity, account, contact, organization, dealer-role, and representative-authority information;
• billing, transaction, quote, invoice, purchase-order, tax, exemption, and commercial history;
• shipping, pickup, delivery, customs, and recipient information;
• wheelchair measurements, body-related fitting information, intended-use information, selected options, configuration data, special requests, photos, videos, CAD drawings, signatures, and sign-offs;
• messages, helpdesk content, call notes, uploads, support, warranty, maintenance, incident, safety, and recall records;
• browser, device, IP address, cookie, session, authentication, security, error, and website-interaction data; and
• marketing preferences, consent records, surveys, testimonials, and feedback.

HOC does not intend to collect Social Security numbers, passport numbers, government identification, full payment-card numbers, biometric templates, or precise geolocation through the configurator. Do not submit these unless HOC specifically requests them through an approved secure process.

3. Sources

Information may come from the individual, an authorized caregiver or representative, a Dealer or Dealer employee, a clinician or assistive-technology professional, an insurer or payer, an employer or organization, payment and shipping providers, component manufacturers, cookies and website technology, public records where lawful, and HOC personnel.

4. Purposes and Legal Bases

HOC uses information to provide accounts and portals; save and review builds; assess compatibility; perform fitting, engineering, CAD, manufacture, sign-off, delivery, service, and support; process payments and taxes; administer Dealer relationships; prevent fraud and secure systems; maintain records; respond to rights requests; investigate complaints and safety events; perform warranty and recall obligations; improve products and Services; communicate about a transaction; and comply with law.

Depending on jurisdiction, the legal basis may be contract, steps requested before contract, consent, substantial public interest or another special-category condition, compliance with law, protection of vital interests, or HOC's legitimate interests balanced against individual rights. HOC will obtain separate express consent when a consumer-health or other law requires it.

5. Health and Sensitive Information

Wheelchair measurements, disability-related details, fitting records, photos, configuration choices, and intended-use information may reveal health or disability information. HOC limits processing to product configuration, fitting, manufacturing, safety, service, support, legal compliance, and purposes the individual separately authorizes. HOC does not sell this information or use it for targeted advertising. See the separate Consumer Health Data Privacy Policy.

6. Disclosures

HOC may disclose information to Odoo and other website, hosting, portal, document, signature, and business-system providers; payment processors; carriers, customs brokers, and logistics providers; manufacturers and suppliers; authorized Dealers, clinicians, payers, and representatives; professional advisers, insurers, auditors, and financial institutions; safety, warranty, repair, and recall providers; and government or legal recipients when required or reasonably necessary.

Providers receive information limited to their role and are expected to protect it under contract or law. HOC does not sell personal information and does not share personal information for cross-context behavioral or targeted advertising. HOC does not disclose consumer health data for advertising.

7. International Transfers

HOC is based in California and may process information in the United States and other countries where service providers operate. Those countries may have different privacy laws. Where required, HOC will use an approved transfer mechanism, contractual safeguards, consent, or another lawful basis. HOC must complete a vendor and transfer inventory before publication.

8. Retention

HOC uses the following default schedule, subject to legal holds, safety needs, warranty obligations, disputes, and mandatory law:

• abandoned saved configurations: 18 months after last activity;
• active account profile: account duration plus 3 years;
• submitted Build, measurements, CAD, sign-off, product-safety, serial, and warranty records: the product's useful life plus 10 years;
• accounting, tax, invoice, and payment records: 7 years;
• support and Build messages: Order completion plus 7 years, or longer when tied to safety or warranty;
• authentication, security, and error logs: 24 months;
• analytics and cookie identifiers: up to 26 months or the provider's shorter period;
• marketing consent and objection records: consent duration plus 4 years; and
• rolling backups: ordinarily 90 days before overwrite.

HOC may retain deidentified information where it cannot reasonably be linked back to an individual. This schedule requires counsel and operations approval before publication.

9. Security

HOC uses reasonable administrative, technical, and physical safeguards appropriate to the nature of the information and risk. No system is perfectly secure. Users must protect passwords, private links, devices, and account access and promptly report suspected misuse. HOC maintains an internal incident-response and notification process.

10. Rights and Choices

Depending on location, an individual may have rights to know or access information, correct it, delete it, obtain a portable copy, restrict or object to processing, withdraw consent, opt out of sale or targeted-advertising sharing, limit certain sensitive-information use, appeal a decision, or complain to a regulator. HOC will not discriminate unlawfully for exercising a right.

Submit a request to info@teamhoc.com with the subject Privacy Request or mail it to HOC. HOC may verify identity and authority and may deny or limit a request when law permits, such as when records must be preserved for safety, warranty, tax, fraud prevention, legal claims, or another person's rights. An authorized agent may act where law permits and authority is verified.

11. Cookies, Analytics, and External Media

HOC uses necessary cookies and may use preferences, analytics, embedded video, maps, chat, or error-monitoring technology as described in the Cookie Policy. Nonessential technology will be consent-controlled where required. An embedded provider may receive device and interaction data under its own policy.

12. Marketing and Communications

Transactional messages about an account, Order, safety, warranty, sign-off, payment, or support are not marketing. Marketing messages are sent as permitted by law and include an unsubscribe method where required. Unsubscribing from marketing does not prevent necessary service or safety communications.

HOC may monitor, record, or transcribe a call or chat for quality, training, security, documentation, or support only where lawful and after providing any notice or obtaining any consent the applicable jurisdiction requires. A person may request an available nonrecorded communication method when reasonably practicable.

13. Children and Representatives

HOC services are not directed to children who independently create accounts. A parent, guardian, conservator, or other lawful representative may submit information for a minor or person who lacks legal capacity. The representative must have authority and should provide only information reasonably necessary for the Build.

14. Public Photos, Testimonials, and Feedback

HOC will not publish an identifiable customer image, name, likeness, story, testimonial, or wheelchair linked to that person for marketing without separate express media consent. Operational permission to process Build photos is not marketing consent. A person may withdraw future marketing use as provided in the consent, without affecting lawful prior use. Nonconfidential suggestions and feedback may be used without compensation.

15. Changes and Contact

HOC may update this policy prospectively. Material changes will receive legally required notice and consent. The version applicable to a transaction remains available in HOC records. Questions and requests: info@teamhoc.com, +1 619-396-5925, or the address above.