Last updated: April 9, 2022
What Personal Data Do We Receive?
Personal data is any information from or about an identified or identifiable person, including information that Holo Sail Technologies, Inc. can associate with an individual person. We may collect, or process on behalf of our customers, the following categories of personal data when you use or interact with Holo Sail Technologies, Inc. Products:
· Account Information: Information associated with an account that licenses Holo Sail Technologies, Inc. Products, which may include Username, Email address.
· Profile and Participant Information: Information associated with the Holo Sail Technologies, Inc. profile of a user who uses Holo Sail Technologies, Inc. Products under a licensed account or that is provided by an unlicensed participant joining a meeting, which may include, email address, username, or other information provided by the user or their account owner.
· Contacts and Calendar Integrations: Contact information IS NOT COLLECTED by Holo Sail Technologies, Inc. Products. Users can add scheduled meetings created with their Holo Sail Technologies, Inc. profile or account to their calendars from other services.
· Device Information: Information about the computers, phones, and other devices people use when interacting with Holo Sail Technologies, Inc. Products, which may include information about the speakers, microphone, camera, OS version, hard disk ID, PC name, MAC address, IP address (which may be used to infer general location at a city or[LG1] country level), device attributes (like operating system version and battery level), WiFi information, and other device information (like Bluetooth signals).
· Product and Website Usage: Information about how people and their devices interact with Holo Sail Technologies, Inc. Products, such as: when participants join and leave a meeting; whether participants[LG2] sent messages and who they message with; performance data; mouse movements, clicks, keystrokes or actions (such as mute/unmute or video on/off), and other user inputs that help Holo Sail Technologies, Inc. to understand feature usage, improve product design, and suggest features; which third-party apps users add to a meeting or other Product and what information and actions the app is authorized to access and perform; use of third-party apps and the Holo Sail Technologies, Inc. App Marketplace; features used (such as screen sharing, emojis, or filters); and other usage information and metrics. This also includes information about when and how people visit and interact with Holo Sail Technologies, Inc.’s websites, including what pages they accessed, their interaction with the website features, and whether or not they signed up for a Holo Sail Technologies, Inc. Product.
· Communications with Holo Sail Technologies, Inc.: Information about your communications with Holo Sail Technologies, Inc., including relating to support questions, your account, and other inquiries.
How Do We Use Personal Data?
Holo Sail Technologies, Inc. employees do NOT access meeting, webinar, or messaging content (specifically, audio, video, files, and messages) unless directed by an account owner, or as required for legal, safety, or security reasons, as discussed below. Holo Sail Technologies, Inc. uses personal data to conduct the following activities:
· Provide Holo Sail Technologies, Inc. Products and Services: This may also include using personal data for customer support, which may include accessing audio, video, files, and messages, at the direction of the account owner or their users. We also use personal data to manage our relationship and contracts with account owners, including billing, compliance with contractual obligations, and related administration.[LG3]
· Authentication, Integrity, Security, and Safety: To authenticate accounts and activity, detect, investigate, and prevent malicious conduct or unsafe experiences, address security threats, protect public safety, and secure Holo Sail Technologies, Inc. Products.
· Communicate with You: We use personal data (including contact information) to communicate with you about Holo Sail Technologies, Inc. Products, features, and services, including product updates, your account, and changes to our policies and terms. We also use your information to respond to you when you contact us.
· Legal Reasons: To comply with applicable law or respond to valid legal process, including from law enforcement or government agencies, to investigate or participate in civil discovery, litigation, or other adversarial legal proceedings, and to enforce or investigate potential violations of our Terms of Service or policies.
How Do We Share Personal Data?
Holo Sail Technologies, Inc. Does NOT provide personal data to third parties without explicit consent or in one of the following circumstances (subject to your prior consent where required under applicable law):
· Vendors: Holo Sail Technologies, Inc. works with Stripe for payment processing. This vendor can access personal data subject to contractual and technical requirements for protecting personal data and prohibiting them from using personal data for any purpose other than to provide services to Holo Sail Technologies, Inc. or as required by law.[LG4]
· For Legal Reasons: Holo Sail Technologies, Inc. may share personal data as needed to: (1) comply with applicable law or respond to, investigate, or participate in valid legal process and proceedings, including from law enforcement or government agencies; (2) enforce or investigate potential violations of its Terms of Service or policies; (3) detect, prevent, or investigate potential fraud, abuse, or safety and security concerns, including threats to the public; (4) meet our corporate and social responsibility commitments; (5) protect our and our customers’ rights and property; and (6) resolve disputes and enforce agreements.
· Change of Control: We may share personal data with actual or prospective acquirers, their representatives and other relevant participants in, or during negotiations of, any sale, merger, acquisition, restructuring, or change in control involving all or a portion of Holo Sail Technologies, Inc.’s business or assets, including in connection with bankruptcy or similar proceedings.
Privacy Rights and Choices
If you are in the European Economic Area (EEA), Switzerland, or the UK, or a resident of California, please refer to the respective dedicated sections below. Otherwise, at your request, and as required by applicable law, we will:
· Inform you of what personal data we have about you that is under our control;
Amend or correct such personal data or any previous privacy
preferences you selected, or direct you to
applicable tools; and/or
· Delete such personal data or direct you to applicable tools.
In order to exercise any of your rights as to personal data
controlled by Holo Sail Technologies, Inc., please submit a request via https://www.holosailtechnologies.com/havens-den-support.
Where legally permitted, we may decline to process requests that are
unreasonably repetitive or systematic, require disproportionate
technical effort, or jeopardize the privacy of others. As an account owner or a user under a licensed account, you may also take steps to affect your personal data by visiting your account and modifying your personal data directly.
How to Contact Us
To exercise your rights, please submit a request via https://www.holosailtechnologies.com/havens-den-support. If you have any privacy-related questions or comments related to this Privacy Statement, please send an email to email@example.com
You can also contact us by writing to the following address:
Holo Sail Technologies, Inc.
1234 Golden Gate Drive
Papillion, Nebraska 68046
We retain personal data for as long as required to engage in the uses described in this Privacy Statement, unless a longer retention period is required by applicable law.
The criteria used to determine our retention periods include the following:
· The length of time we have an ongoing relationship with you and provide Holo Sail Technologies, Inc. Products to you (for example, for as long as you have an account with us or keep using our Products);
· Whether account owners modify or their users delete information through their accounts;
· Whether we have a legal obligation to keep the data (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
· Whether retention is advisable in light of our legal position (such as in regard to the enforcement of our agreements, the resolution of disputes, and applicable statutes of limitations, litigation, or regulatory investigation).
European Data Protection Specific Information
Data Subjects Rights
If you are in the EEA, Switzerland, or the UK, your rights in relation to your personal data processed by us as a controller specifically include:
· Right of access and/or portability: You have the right to access any personal data that we hold about you and, in some circumstances, have that data provided to you so that you can provide or “port” that data to another provider;
· Right of erasure: In certain circumstances, you have the right to the erasure of personal data that we hold about you (for example, if it is no longer necessary for the purposes for which it was originally collected);
· Right to object to processing: In certain circumstances, you have the right to request that we stop processing your personal data and/or stop sending you marketing communications;
· Right to rectification: You have the right to require us to correct any inaccurate or incomplete personal data;
· Right to restrict processing: You have the right to request that we restrict processing of your personal data in certain circumstances (for example, where you believe that the personal data we hold about you is not accurate or lawfully held).
To exercise your rights or have any other questions about our use of your personal data, please submit a request via https://www.holosailtechnologies.com/havens-den-support Please note that we may request you to provide us with additional information in order to confirm your identity and ensure that you are entitled to access the relevant personal data.
You also have the right to lodge a complaint to a data protection authority. For more information, please contact your local data protection authority.
Legal Basis for Processing Personal Data
We only use your information in a lawful, transparent, and fair manner. Depending on the specific personal data concerned and the factual context, when Holo Sail Technologies, Inc. processes personal data as a controller for individuals in regions such as the EEA, Switzerland, and the UK, we rely on the following legal bases as applicable in your jurisdiction:
· As necessary for our contract: When we enter into a contract directly with you, we process your personal data on the basis of our contract in order to prepare and enter into the contract, as well as to perform and manage our contract (i.e., providing Holo Sail Technologies, Inc. Products, features and services to account owners, their users, and those they invite to join meetings and webinars hosted on their accounts, and manage our relationship and contract, including billing, compliance with contractual obligations, and related administration). If we do not process your personal data for these purposes, we may not be able to provide you with all Products, features, and services;
· Consistent with specific revocable consents: We rely on your prior consent in order to utilize cookies. You have the right to withdraw your consent at any time by submitting a request via https://www.holosailtechnologies.com/havens-den-support
· As necessary to comply with our legal obligations: We process your personal data to comply with the legal obligations to which we are subject for the purposes of compliance with EEA laws, regulations, codes of practice, guidelines, or rules applicable to us, and for responses to requests from, and other communications with, competent EEA public, governmental, judicial, or other regulatory authorities. This includes detecting, investigating, preventing, and stopping fraudulent, harmful, unauthorized, or illegal activity (“fraud and abuse detection”) and compliance with privacy laws;
· To protect your vital interests or those of others: We process certain personal data in order to protect vital interests for the purpose of detecting and preventing illicit activities that impact vital interests and public safety, including child sexual abuse material; and
As necessary for our (or others’) legitimate interests,
unless those interests are overridden by your interests or fundamental rights
and freedoms, which require protection of personal data: We
process your personal data based on such legitimate interests to (i) enter and
perform the contract with the account
owner and/or reseller providing you with the Products (which includes billing, compliance with contractual obligations, and related administration and support); (ii) develop, test, and improve our Products and troubleshoot products and features; (iii) ensure authentication, integrity, security, and safety of accounts, activity, and Products, including detect and prevent malicious conduct and violations of our terms and policies, prevent or investigate bad or unsafe experiences, and address security threats; (iv) send marketing communications, advertising, and promotions related to the Products; and (v) comply with non-EEA laws, regulations, codes of practice, guidelines, or rules applicable to us and respond to requests from, and other communications with, competent non-EEA public, governmental, judicial, or other regulatory authorities, as well as meet our corporate and social responsibility commitments, protect our rights and property and the ones of our customers, resolve disputes, and enforce agreements.
International Data Transfers
Holo Sail Technologies, Inc. operates globally, which means personal data may be transferred, stored (for example, in a data center), and processed outside of the country or region where it was initially collected where Holo Sail Technologies, Inc. or its service providers have customers or facilities – including in countries where meeting participants or account owners hosting meetings or webinars that you participate in or receiving messages that you send are based.
Therefore, by using Holo Sail Technologies, Inc. Products or providing personal data for any of the purposes stated above, you acknowledge that your personal data may be transferred to or stored in the United States where we are established. Such countries may have data protection rules that are different and less protective than those of your country.
We protect your personal data in accordance with this Privacy Statement wherever it is processed and take appropriate contractual or other steps to protect it under applicable laws. Where personal data of users in the EEA, Switzerland, or the UK is being transferred to a recipient located in a country outside the EEA, Switzerland, or the UK which has not been recognized as having an adequate level of data protection, we ensure that the transfer is governed by the European Commission’s standard contractual clauses. Please contact us if you would like further information in that respect.
California Privacy Rights
California Consumer Privacy Act
Under the California Consumer Privacy Act of 2018 (CCPA), California residents may have a right to:
· Access the categories and specific pieces of personal data Holo Sail Technologies, Inc. has collected, the categories of sources from which the personal data is collected, the business purpose(s) for collecting the personal data, and the categories of third parties with whom Holo Sail Technologies, Inc. has shared personal data;
· Delete personal data under certain circumstances; and
· Opt out of the “sale” of personal data. We do not sell your personal data.
Holo Sail Technologies, Inc. will not discriminate against you for exercising any of these rights, which is further in line with your rights under the CCPA.
We will acknowledge receipt of your request within 10 business days, and provide a substantive response within 45 calendar days, or inform you of the reason and extension period (up to 90 days) in writing.
Under the CCPA, only you or an authorized agent may make a request related to your personal data. Note that to respond to your requests to access or delete personal data under the CCPA, we must verify your identity. We may do so by requiring you to log into your Holo Sail Technologies, Inc. account (if applicable), provide information relating to your account (which will be compared to information we have, such as profile information), give a declaration as to your identity under penalty of perjury, and/or provide additional information. You may designate an authorized agent to submit your verified consumer request by providing written permission and verifying your identity, or through proof of power of attorney.
California’s Shine the Light Law
California Civil Code Section 1798.83, also known as “Shine The Light” law, permits California residents to annually request information regarding the disclosure of your Personal Information (if any) to third parties for the third parties’ direct marketing purposes in the preceding calendar year. We do not share Personal Information with third parties for the third parties’ direct marketing purposes.
Changes to This Privacy Statement