This HOLOWITS Privacy Notice (hereinafter referred to as this "Privacy Notice") describes the types of information, including but not limited to personal data, that we may collect from you or that you may provide when you interact with us or use the App. By accessing, browsing, and/or using the App, you shall be deemed to have agreed to this Privacy Notice. If you do not agree to this Privacy Notice, you must stop using the App.
1. What Information We Collect
When you use the App, we may collect certain personal information about you as described in this Privacy Notice. If you use certain functions or services of the App, additional privacy policies/notices may apply.
The information in this Privacy Notice can be divided into information that you provide to us and information that HOLOWITS collects.
Personal information that you provide to us may include your email address and your language selection. An example is the information that you provide to us when you contact us for technical support.
Personal information that we collect includes Internet traffic data, such as number of user visits and the time period of visiting.
2. How We Use Your Information
HOLOWITS may use your personal information for the following purposes:
● to respond to your enquiries;
● to increase the safety of the App, such as security protection and fraud detection;
● for troubleshooting;
● to generate operations and maintenance reports;
● to perform the agreements we have concluded with you;
● to provide other services that you request with your express consent;
● to meet a legal obligation, a court order, or other binding decision(s);
● to accomplish a purpose unrelated to those described in this Privacy Notice, for which we shall first notify you and, where required, allow you to choose whether we may use your personal information for such a purpose.
3. How We Process Your Information
We do not and shall not sell any personal information to any third parties. We may provide personal information to network service providers and other service providers on the basis of non-disclosure agreements.
The following are the limited situations where we may share your personal information:
We may share your personal information with our affiliates that are required to use such information in accordance with the purposes described in this Privacy Notice, for example, to provide you with technical support that you request.
We may share your personal information to comply with applicable laws and orders or for the purpose of public interest. We may access, preserve, and share your information with regulators, law enforcement, or others:
● in response to a legal request (for example, a search warrant, court order, or subpoena) if we have reason to believe that the law requires us to do so;
● when we have reason to believe that it is necessary to detect, prevent, and address fraud, unauthorized use of HOLOWITS services and products, breaches of our terms or policies, or other harmful or illegal activities; to protect ourselves (including our rights, properties, and HOLOWITS services), you, or others, including doing so as part of investigations or regulatory enquiries; or to prevent death or imminent bodily harm. For example, if relevant, we provide information to and receive information from third-party partners about the reliability of your account in order to prevent fraud, abuse, and other harmful activities in connection with HOLOWITS' online and offline services.
We may share your personal information with our new owner. If HOLOWITS and/or all or part of our assets are ever sold or transferred, your personal information may be among the items sold or transferred. Under such a circumstance, we will notify you on the App of (i) the identity and contact information of the purchaser or transferee, (ii) your right to revoke your consent to the provision of personal information, and (iii) the means by which you may revoke such consent.
4. Information Security and Retention
We have implemented commercially reasonable administrative, technical, and physical security measures that are designed to safeguard personal information. We anonymize users' accounts and email addresses to protect their privacy. We have a team dedicated to keeping your information secure and testing for vulnerabilities. We also conduct periodic reviews and assessments of the effectiveness of our security measures.
Notwithstanding the above, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, HOLOWITS cannot guarantee the absolute security of your personal information with existing security technologies. If you have any questions about the security of the App, please contact us.
In terms of information retention, generally, we store your information on HOLOWITS' servers, which are established upon third-party servers, until you delete or edit it, or for as long as we need it to support your use of our App, unless a longer retention period is required or permitted by applicable laws.
5. Your Rights
Subject to limitations in applicable laws, you have certain rights in respect to your personal information, such as the right of access, rectification, restriction, opposition, and deletion. In order to exercise your rights, please contact us by sending us an email. You also have the right to withdraw your consent at any time, free of charge, by sending us an email.
6. Children's Privacy
HOLOWITS prohibits persons under the age of 18 or the age of majority in the relevant jurisdiction, from accessing any part of the App. The App is designed and intended for adults only. By using the App, you represent that you are at least 18 years old or have reached the age of majority in the relevant jurisdiction. We attach great importance to children's privacy. HOLOWITS does not knowingly contact or collect any information from persons under the age of 18 or the age of majority in the relevant jurisdiction, and the App does not knowingly collect information in any form from persons under the age of 18 or the age of majority in the relevant jurisdiction. If you are a parent or legal guardian of a person under the age of 18 or the age of majority in the relevant jurisdiction and believe that he or she has disclosed his or her personal information to us, please contact us. A parent or legal guardian of a person under the age of 18 or the age of majority in the relevant jurisdiction may review and request deletion of such person's personal information and prohibit the use of such information. If we become aware that a person under the age of 18 or the age of majority in the relevant jurisdiction has provided his or her personal information to us, we will adopt appropriate measures to delete such personal information.
7. Global Operations
We transfer and process your information globally both in our own facilities and with service providers or partners, regardless of where you use our App. As HOLOWITS operates globally, we may transfer your personal information to our data centers worldwide, when processing such information for the purposes described in this Privacy Notice. For example, if you request customer services from HOLOWITS, our colleagues may access some of your information, irrespective of where you are located, in order to provide the requested services to you. All such data transfers shall be performed in accordance with the applicable laws. In particular, we warrant that all data transfers will comply with your applicable local data protection laws by putting in place appropriate safeguards. You hereby agree to such data transfer and acknowledge that you have the right to be informed of the appropriate security measures taken by HOLOWITS to protect the transfer of your personal information.
Currently, we have data centers in Singapore, the United Arab Emirates (UAE), Brazil, and South Africa. You acknowledge and agree that we may transfer and store your personal information at our international data centers, and that the data protection laws of the country or region in which your information is stored or processed may be different from those of your own country or region, which may result in different levels of protection and risks for your personal information. However, this does not change any of our commitments to safeguard your personal information in accordance with this Privacy Notice.
If you are located in the Europe Economic Area (EEA), HOLOWITS will transfer your personal data to the corresponding data center for storage. Therefore, your personal data may be processed, used, and/or transferred to a country or region outside the EEA. If we process, use, and/or transfer your personal data to a country or region outside the EEA, we will adopt appropriate measures to protect your privacy. In order to ensure that such data transfer complies with applicable laws and is managed properly to protect your privacy, such data transfer is subject to the Binding Corporate Rules (BCR), which means that we are legally obligated to ensure that your personal data is sufficiently and consistently protected during transfer.
If you are a resident of Brazil, you can learn more about your rights, including how to exercise your rights under the Brazilian General Data Protection Law, by reading the Brazil Privacy Notice.
8. Amendments to This Privacy Notice
We may modify this Privacy Notice at any time. If we make material changes to this Privacy Notice, we will notify you prior to the effective date of such changes by posting notifications on the App.
9. Contact Us
If you have any questions or comments about our privacy practices or this Privacy Notice, you can contact us by giving feedback in the App. You can also contact us by sending an email to [feedback@holowits.com].
When sending an email to us, please provide: (i) your registered email address and your country or region of residence; and (ii) the details of your request or comment.