DATA SECURITY NOTICE

Effective Date: 2026/01/05

1. Security Program

HGC maintains administrative, technical, and physical safeguards consistent with industry-standard practices. The program is designed to help protect personal information and other sensitive data against unauthorized access, use, disclosure, alteration, or destruction.

Our security practices are reviewed periodically and updated as appropriate to address changes in technology, business operations, and evolving cybersecurity risks.

2. Administrative Safeguards

HGC employs administrative safeguards designed to support responsible data governance and regulatory compliance, which may include:

Written policies and procedures addressing data security, privacy, and information handling.
Employee training and awareness programs related to confidentiality and cybersecurity.
Role-based access controls that limit information access to personnel with a legitimate business need.
Supervisory oversight and compliance monitoring consistent with applicable legal requirements.
Incident response and escalation procedures designed to support timely identification and response to security events.
Periodic risk assessments and internal reviews.

All personnel and service providers with access to sensitive information are subject to confidentiality and security obligations.

3. Technical Safeguards

HGC uses technical controls designed to help protect information systems and data, consistent with industry standards and regulatory expectations, which may include, where appropriate:

Use of encryption or other protective measures for sensitive information during storage or transmission.
Authentication and access-control mechanisms to help prevent unauthorized system access.
Network security tools such as firewalls, monitoring systems, and endpoint protection.
Logging, monitoring, and alerting capabilities intended to identify anomalous or unauthorized activity.
System maintenance practices, including updates and vulnerability management.

The specific safeguards applied may vary based on system design, risk assessments, and operational requirements.

4. Physical Safeguards

HGC maintains physical security measures designed to protect facilities, systems, and records, which may include:

Controlled access to office locations and restricted areas.
Secure storage of physical records and devices.
Procedures for the secure disposal of paper records and electronic media when no longer required.

5. Third-Party Service Providers

HGC may engage third-party service providers to support technology, communications, or operational functions. As part of our vendor management practices, we conduct due diligence appropriate to the nature of the services provided and require service providers, through contractual arrangements where applicable, to:

Maintain reasonable security controls.
Protect confidential and nonpublic personal information.
Notify HGC of known or suspected security incidents related to HGC data.

6. Incident Response

HGC maintains incident response procedures designed to support the identification, assessment, and management of information security incidents. In the event of unauthorized access to personal information, HGC will take steps consistent with applicable legal and regulatory requirements, which may include:

Assessing the nature and scope of the incident.
Implementing measures to contain and mitigate potential harm.
Providing notifications to affected individuals and regulators when required by law.

7. Client and Partner Responsibilities

While HGC implements safeguards designed to protect information, individuals also play an important role in maintaining security. Users and Partners are encouraged to:

Use secure communication methods when available.
Protect login credentials and personal information.
Notify HGC promptly of suspected unauthorized activity.

8. Governing Law, Modifications and Questions

Disputes and Updates to this Notice are governed by the Terms of Use. Any questions may be directed to the Company using our Contact Form.