PRIVACY POLICY HOLLA

Holla takes your privacy very seriously and is committed to protect your personal data and respect your privacy. We comply with all relevant data protection laws, such as the General Data Protection Regulation.

In this policy we explain to you how we collect and process your personal data and for which purposes. Please read it carefully to understand our views and practices regarding your personal data. By visiting our site you are accepting and consenting to the practices described in this policy.

Any terms used in this policy that are defined in our Terms of Use, have the same meaning in this policy.

DATA CONTROLLER

Holla Services Ltd is your data controller. This means that we are responsible for, and control the collecting and processing of, your personal data. You can find all our details under How to contact us.

PERSONAL DATA WE COLLECT

You can browse parts of our site without having to supply us with any personal data at all. However, if you want to set up an account with us and make full use of all our services and features, you will need to provide us with some personal data.

Please note that you can always monitor and control the processing of your personal data by exercising Your rights.

What kind of personal data do we collect from you when you use our site, and what do we need that information for?

1. Personal information you give to us

This is information about yourself that you give us when we ask for. Such information includes:

• name
• e-mail address
• country of residence

In addition to the above, when you correspond with us and when you place an order for goods or services on our site, we may (depending on the type of goods or services) ask for your:

• address (street and number, postcode or zipcode, city)
• telephone number

Why do we need your personal information?

• This information is necessary to enable us to properly perform our contract with you (our Terms of Use). In other words: we need it in order to provide you with all the basic functionalities of our site and to enable us or third parties to provide you with goods or services.

• We also use your e-mail address to notify you about changes and updates to our terms, services and policies, such as this Privacy Policy.

• Your e-mail address is also used to send you our newsletter. Our newsletter contains information that we think may be of interest to our users. Not only about Holla, but also of third-parties featured on our site as well as other sponsored content. We do need your specific and separate consent for this. To obtain your consent, we have included a tick box on our sign-up page to give you a choice to receive our newsletter.

Remember that you can always withdraw your consent to receive our newsletter. If you have unsubscribed from receiving our newsletter but you continue to receive updates via email, please contact help@holla.com and a member of our team will rectify the matter.

2. Other personal information that you share with us

Certain features and services on our site will give you the opportunity to share additional information about yourself with us. If you choose to do so, your user experience may be enhanced, we will be able to personalize information we display for you or send you and you may benefit even more from all the different features and services offered on our site. By submitting such information to us voluntarily, you agree to the processing of such information.

It includes information you provide when you participate in discussion boards on our site or make use of other interactive or social media functions, enter into competitions, promotions and surveys, post content on our site or invite other people to use our site.

Such additional personal information may include:

• age
• gender
• date of birth
• interests
• profile picture
• personal description
• contacts (address book)

You should be aware that some of this information may become publicly visible. If you do not want the general public to see such information, you must not upload it.

3. Other information we collect about you

Each time you visit our site we will automatically collect the following information, which includes some personal information, such as your IP-address and your location. We need to collect and process such information to properly perform our services under our Terms of Use (e.g. to provide you with all the functionalities and to help you when you encounter problems using our site) and the processing of such information is also in our legitimate interest to provide, improve and safeguard the different functionalities we offer.

Such information can be categorized as follows:

• technical information: the Internet protocol (IP) address used to connect your device to the Internet, device information, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

• information about your visit: the full Uniform Resource Locators (URL), clickstream to, through and from our site including date and time, products and services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page;

• location data: when you access our site by or through a mobile device, we may access, collect, monitor and/or remotely store location data, which may include GPS coordinates or similar information regarding the location of your device. Some features of our site, particularly location-based services, may not function properly if use or availability of location data is impaired or disabled.

We use this information for the following purposes:

• to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve our site to ensure that content is presented in the most effective manner for you and for your device;
• to allow you to participate in interactive features of our site, when you choose to do so;
• as part of our efforts to keep our site safe and secure;
• to make suggestions and recommendations about services that may interest you.

4. Personal information we receive from other sources

Sometimes we receive personal information about you from other sources than yourself if you use any of the affiliated websites or the other services we provide. Such information we obtain from you may be used by us in combination with information we already have about you and is only used for the purposes abovementioned.

Information shared with or provided to us includes:

• information about you if you access our platform through a third-party connection or log-in, such as Google or Facebook. That third party may pass on certain information about your use of its service to us. This information could include the user ID associated with your account (for example, your Facebook UID), an access token necessary to access that service, any information that you have permitted the third party to share with us, and any information you have made public in connection with that service. We do not control how such third-parties process and share your personal information with us. You should therefore always review, and if necessary, adjust your privacy settings on such third-party sites and services before linking or connecting them to us. You may also unlink your third-party account from our platform by adjusting your settings on the third-party service.

• Information about you shared by other users of our platform.

OUR SITE IS NOT FOR CHILDREN UNDER THE AGE OF 18

Our site and our services are not intended for children under the age of 18 or the legal age of majority in your country of residence. We do not knowingly collect or distribute personal information from or about children under the age of 18 or the applicable legal age of majority. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us.

COOKIES

A cookie is a small text file that is placed onto the electronic device you use when you visit our site. Cookies can be used to help you navigate websites more efficiently and to perform certain functions, as well as to provide information to us. There are several types of cookies and other online tracking devices such as web beacons, action tags, local shared objects or flash cookies, and single-pixel gifs. Cookies can perform different functions and serve different purposes:

• Strictly necessary cookies: these cookies are required for a good operation of our site and include, for example, cookies enabling you to log into secure areas of our site. Because these cookies are necessary for the operation of our platform, you cannot turn them off.

• Analytical/performance cookies: these cookies allow us to recognize and keep count of the visitors of our platform and see how our visitors navigate our site. They enable us to estimate our audience size and usage patterns and help us to improve our platform so your online experience can be made more efficient and enjoyable.

• Functionality cookies: these cookies are used to recognize visitors returning to our platform. They enable us to personalize our content for you and remember your preferences. This speeds up your access to our platform.

• Targeting cookies: these cookies record your visits to our site, the pages you visited and the links you have followed. We use such information to make our platform – and advertising displayed on it – more relevant to your interests.

When you first visit our platform, you will see a notice displayed on our landing page about the use of cookies. This notice links to this policy and gives you the opportunity to accept the cookies we use.

Please note that you can always withdraw your consent to the use of cookies by adjusting the privacy preferences of your browser. Please be aware that restricting or deleting cookies may impact on the functionality of our site and your ability to use our site.

We work with third-party suppliers who may also set cookies on our site, for example Amazon, Facebook, Twitter and YouTube. We have no control or responsibility over cookies placed by third parties. These third-party suppliers are responsible for the cookies they set on our site. If you want further information please go to the website of the relevant third party.

We also use Google Analytics on our sites for anonymous reporting of site usage and for advertising on the site. You can opt-out of Google Analytics monitoring your behaviour on our site via Google’s opt-out tool.

SHARING YOUR PERSONAL INFORMATION

We would like to stress that we do not sell your personal information to any other party.
However, we do share your personal information with a few categories of third-parties. Please see an overview below.

1. The general public

Some of your personal information will be shared with and is accessible by the general public. This is partly necessary to perform our obligations under the contract we have with you (Terms of Use) so that we can offer all the functionalities in a proper manner. For the parts of your information this does not apply to, we rely on your consent.

Such information includes the following:

• When you have set up a profile page on our platform, that profile page is publicly accessible. In any case, your username and personal description will be visible. You may choose to disclose other information about yourself by giving us your consent to do so.

• Whenever you use a feature on our platform via which you can communicate with other users of our site, such as taking part in discussions, the information you upload will be publicly accessible.

Any information that is publicly accessible on our platform may also be indexed by third-party search engine providers. We do not have any control over such third-parties.

2. Selected third parties

We will share your information with selected third parties including:

• our business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you, such as a supplier of goods and a third-party payment provider;

• third-party marketing automation providers, for the purpose of sending you our newsletter. We currently use Mailchimp as a partner, but we may change this in the future. In the event we do so, we will ensure that your information is transferred to such new provider in a safe and secure manner;

• advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on an advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience;

• analytics and search engine providers that assist us in the improvement and optimisation of our site.

3. Other circumstances in which we share your personal information

We will also share your personal information in the following circumstances:

• in the event that we sell or buy any business or assets, we will disclose your personal information to the prospective seller or buyer of such business or assets;

• if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;

• if we are under a duty to disclose or share your personal data in order to comply with any laws, legal obligations or investigations;

• to enforce or apply our Terms of Use, policies or other agreements;

• to protect the rights, property, or safety of Holla, its employees, our users or third parties. This includes exchanging information with other companies and organisations for the purposes of fraud protection.

In the event we receive a legal request to disclose personal information, we may notify you of such request before we do so, unless this is expressly prohibited by the authority making the request or if notifying you would be detrimental to us, the party requesting your personal information, or any other person affected, or to the investigation itself. If we can’t notify you of such requests beforehand for the reasons set out before, we will try to notify you afterwards.

THE USE OF LINKS ON OUR SITE

Our site may contain links to and from websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check such policies before you submit any personal data to these websites.

Our site may contain links to third party sites where you may purchase products and/or services. We may make commissions from those sales, and we do some tracking so the third party knows what site you came from, but we do not provide your personal information to that third party.

SOCIAL MEDIA FEATURES

Our site may include social media features, such as the Facebook Like button. Our integration of these features may allow third party social media to collect certain information about you such as your IP address, which page you are visiting when using our site, and to set a cookie to enable the feature to function properly. Social media features are either hosted by a third party or hosted directly through the use of our site. Your interactions with these features are governed by the privacy policy of the company providing it.

THIRD-PARTY PLUGINS

Our site uses third-party plugins for certain functionalities. We do not control those third-parties, nor do we control their processing of personal information. In the event that personal information is collected via such third-party plugins for our benefit, we only use such information in accordance with the purposes set out in this Privacy Policy.

PAYMENT PROCESSORS

If you make a purchase through our site, you may be able to pay using a third-party payment service, such as Stripe, PayPal and Apple Pay. All information collected by these third-party payment services for purposes of processing your payments is not available to us, unless you have otherwise provided this information to us in connection with your use of our site. Personal information collected from you by these third-party payment services is governed by the applicable third-party payment service’s privacy policy. You should review the applicable policy prior to submitting any information to that third-party payment service.

HOW AND FOR HOW LONG WE KEEP YOUR PERSONAL DATA
We put appropriate security measures in place to prevent personal information from being accidentally lost, or used or otherwise accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
All information you provide to us is stored on our secure servers, located in the UK. Any payment transactions will be encrypted (using SSL technology).
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

We only retain your personal data for as long as your account on our site is active or for as long as we need it to fulfil the purposes for which we have initially collected it, unless otherwise required by law. We may retain certain information to comply with applicable laws, to prevent fraud, or for obligations we have in relation to tax regulations.

TRANSFER OF PERSONAL INFORMATION OUTSIDE THE EEA

Our services are directed to users located all over the world. The following applies to users located in the European Economic Area (EEA): the personal data that we receive and collect from you may be transferred to, and stored at, a destination outside the EEA. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers.

For example, if you order a product or a service via our site from a seller based outside the EEA, we will provide them with your personal details so that they can send you the goods you ordered.
Such countries may not have the same data protection laws as the United Kingdom and EEA. In the event your personal information is transferred to such countries, we have ensured that appropriate safeguards are put in place to protect your privacy rights and give you remedies in the unlikely event of a misuse of your personal information.
We will not otherwise transfer your personal data outside of the EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.

YOUR RIGHTS

Under data protection laws, you have the following rights, which you can enjoy free of charge:

1. Right of transparency and information about how we use your personal information.

2. Right to ask us to confirm whether or not we hold any personal information from you and if we do, the right to ask us what information we have stored about you and for a copy of that information.

3. Right to rectify any inaccurate personal data we hold about you or to complete any incomplete information.

4. Right to have all personal data we keep from you erased in the following situations:

• the personal data are no longer necessary in relation to the purpose for which it was collected;
• you have withdrawn your consent to process your data and we do not have any other legal ground to keep processing your data;
• you object to the processing of your data while we do not have any overriding legitimate grounds to do so;
• your data have been unlawfully processed.

5. Right of restriction of processing

You have the right to ask us to restrict the processing of your personal data if either one of the following applies:

• if you contest the accuracy of the personal data, for a period so long that we can verify the accuracy of your personal data;
• if the processing is unlawful and you oppose the erasure of your data and ask for a restriction instead;
• we do no longer need your personal data for the purpose for which it was collected, but you require your data for the purpose of establishment, exercise or defence of legal claims;
• you have objected to the processing pending verification of the legitimate grounds to override such objection.

6. Right to object to:

• processing of personal data concerning you based on legitimate interests or the performance of a task in the public interest. Such objection must be based on grounds relating to your particular situation. We are obliged to stop processing your data, unless either we can demonstrate that we have compelling legitimate grounds to override your interests, rights and freedoms or the processing is for the establishment, exercise or defence of legal claims;

• direct marketing.

7. Right to withdraw consent you have given us to process your personal data, where consent is being relied on as the lawful basis of such processing.

8. Right to receive the personal data concerning you in a structured, commonly used, machine-readable format and, if technically possible, have this transferred to another service provider.

You can exercise your rights by checking certain boxes on the forms we use to collect your data, by adjusting your settings in your account and by contacting us. We may request you for proof of identity and address when you exercise your rights.

CHANGES TO OUR PRIVACY POLICY

Any changes we make to our Privacy Policy will be posted on our site accompanied by a statement that changes have been made. In addition, if we have collected your e-mail address, we will e-mail you our revised policy. If we need your renewed consent for anything, we will ask you for it.

MAKE A COMPLAINT

If you encounter any problems in relation to the use of your personal information, please contact us so we can try to resolve your issue or concern. You also have the right to lodge a complaint with the supervisory authority in the EU member state where you work, normally live or where any alleged data infringement of data protection has occurred. In the UK, this authority is the Information Commissioner who you can contact via https://ico.org.uk.

HOW TO CONTACT US

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to the data controller, Holla Services Ltd, via e-mail or regular mail:

help@holla.com

71-75 Shelton Street
Covent Garden, London
WC2H 9JQ, United Kingdom

© 2018 Holla Services Ltd