Privacy Policy
Holo Sail Technologies, Inc. Privacy Policy
Last updated: April 9, 2022
This Privacy Policy describes the personal data we collect
and/or process (which may include collecting, organizing, structuring, storing,
using, or disclosing) to provide products and services offered directly by Holo
Sail Technologies, Inc. (“Holo Sail Technologies, Inc.”), including Holo Sail
Technologies, Inc.’s Progressive Web Application “Haven’s Den” and its
meetings, webinars, and messaging platform, and Holo Sail Technologies, Inc.
Product Suite (“Holo Sail Technologies, Inc. Products” or “Products”).
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 support@holosailhaven.com
You can also contact us by writing to the following address:
Holo Sail Technologies, Inc.
1234
Golden Gate Drive
Papillion, Nebraska 68046
Retention
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.
To exercise your rights or to opt out of the use of cookies on
our sites, please submit a request to support@holosailhaven.com. We do not use
your cookies for interest-based advertising purposes.
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
We may update this Privacy Statement periodically to account for
changes in our collection and/or processing of personal data, and will post the
updated Privacy Policy on our website, with a “Last Updated” date at the top.
If we make material changes to this Privacy Statement, we will notify you and
provide you an opportunity to review before you choose to continue using our
Products.