HOLAA! PRIVACY STATEMENT

Holaa is committed to respecting your privacy and the confidentiality of your personal information, data and content and this Privacy Statement sets out what data Holaa collects and how we use and protect it.
IF YOU ARE UNDER 16 YEARS OLD YOU SHOULD DISCUSS THIS PRIVACY STATEMENT WITH A PARENT OR LEGAL GUARDIAN, AND ENSURE THAT THEY AGREE WITH HOLAA’S USE OF YOUR INFORMATION.
This Statement also forms a part of the Agreement between you and us for the use of the Holaa Services and Holaa Website, as explained in the Terms of Use (http://www.holaa.me/terms).Capitalised terms used in this Privacy Statement are defined in the Terms of Use. By using the Holaa Services or the Website you consent to our using the data you provide as explained in this Statement.
We may amend this Privacy Statement by posting a new version on the Website and/or notifying you in some other way as set out below.
1. WHAT TYPES OF PERSONAL INFORMATION DOES HOLAA COLLECT?

In connection with the provision of the Holaa Services, Holaa may gather and process information from you, including the following types of information:

  • Your personal data including contact and registration details (name, User ID, address, telephone, mobile, email address etc.) and profile data (age, sex, pastimes, photo, status updates etc.);
  • your phonebook, names and addresses, lists of contacts. Note: although you allow Holaa to upload this data, it will be used only to enhance your experience on the Holaa Services (e.g. to show you the ID of callers in your phonebook) and will not be disclosed to other Holaa users, except where any of your contacts expressly permit us to do so;
  • identifier data for Third Party Services (such as Facebook, Google+, LinkedIn, Twitter) that you ask to connect to;
  • network and technical data (IP addresses, network operator, Device ID data, Device operating system, cookies, etc.);
  • data in relation to your use of Holaa Services;
  • anonymous data on the approximate location of your device (e.g., from the cell ID data of your mobile network or GPS services);
  • questionnaires or survey results and information regarding use of the Holaa Services.
  • Please refer to section 10 below for what to do if you decide to stop sharing any personal information.
2. HOW AND WHY DOES HOLAA USE YOUR PERSONAL INFORMATION?

Our reasons for collecting information relating to you or your Device are to enable Holaa (or sometimes other data processors selected by Holaa) to provide the Holaa Services through the Holaa application or other applications provided by Holaa to you in an effective and satisfactory way, as follows:

  • processing your log-ins, contacts and preferences and enabling the other features of the Holaa Services, such as automatic caller name display, number look-up, number blocking, enabling you to make and receive contact requests, and functions such as showing you who has viewed your profile or who you already know on Holaa;
  • showing your profile information on the Holaa Services: please note that your profile information is provided by you voluntarily and under your sole responsibility;
  • extending and improving your user experience with names, places, photos etc. from the relevant Third Party Service if you choose to connect your Third Party Service profile to Holaa;
  • building a community spam database with information provided by users against reported numbers;
  • providing you with customer support, responding to questions and helping to resolve problems;
  • informing you about service updates or problems;
  • resolving disputes;
  • verifying your identity;
  • for legal reasons, e.g., checking that you comply with the Terms of Use and Holaa policies, and preventing crime and fraud;
  • customizing, understanding users’ use of, and improving the Holaa Services and Holaa Website (this includes customization of advertising based on your location, or features such as indicating when you were last online, or permitting you to invite contacts); and
  • informing you of additional products, services and offers provided by Holaa.

Holaa stores the personal information in different data files kept on servers based in the Netherlands. Holaa will take all reasonable measures to ensure security of the data, including where such servers may be operated by third party data processors under Holaa’s responsibility.

If we provide a method for you to invite friends to join Holaa, then their contact information will be used for the purposes of automatically generating a message to these potential Holaa users. Holaa Services also have a function that can check the names and phone numbers in your address book against the list of Holaa users and informs you of existing contacts that are already registered for Holaa Services and with whom you may want to connect. If you are already in the address book of other Holaa Services users they be informed that you are a Holaa user you so that they can decide whether to connect with you.

If we process data regarding the location of your Device then (i) in case of services such as allowing location requests from your Holaa contacts, you will be able to switch this functionality on or off at any time within the Holaa Services, and (ii) where this is used in order to provide advertising appropriate to your locality then we may provide this to our third party advertising partners but never in a form that you will be able to be identified from this data; and your acceptance of this privacy statement constitutes consent for this processing.

3. DOES HOLAA TRANSFER YOUR PERSONAL INFORMATION TO ANYONE ELSE?

Holaa does not sell, rent, trade or otherwise transfer any personal information you provide to Holaa to any third party without your express permission (unless it is obliged to do so under applicable laws or by order of the competent authorities) except as set out in this Statement.

Holaa needs to provide certain information to third parties who assist Holaa in providing elements of the Holaa Services. So, for example, Holaa may need to provide your mobile number to an SMS provider in order to contact you or verify your phone number. Under their contracts with Holaa they are required to store and process your information in accordance with similar standards of protection of your data as applied by Holaa.

If any authority lawfully requests Holaa or one of Holaa’s partners to retain and provide personal information, communications content and/or communications or technical data, or permit monitoring or interception, Holaa and/or its partner may comply with that request without being obliged to inform you.

Holaa operates internationally and may transfer the data for processing in different countries, including by Holaa group companies, outside of your home country.

4. WHAT ITEMS ARE PLACED ON YOUR DEVICE WHEN USING THE HOLAA SERVICES OR WEBSITE?

In order to use most of the Holaa Services, you will need to install the relevant software on your Device. This software enables you to make and receive communications using your mobile network or the internet and sends the necessary communications data, and other data that you define (e.g., profile or status updates, community log-in data) between your Device and the network.

In addition, for web-based Holaa Services, “cookies” may be used. Cookies are pieces of information stored on your Device in order to enable web-based applications to recognize who you are or your preferences (e.g., what language version of the Website you usually use) and provide Holaa with information about the use of its Websites).

Most internet browsers allow you to prevent your Device from accepting or using cookies or require your permission each time a cookie is received. Please note that some personalized Holaa Services may not be available if you choose to disable cookies.

Advertisements appearing on Holaa Services or Websites may be provided by Holaa’s advertising partners who may use cookies, web beacons, and/or other monitoring technologies to compile anonymous statistics. The information obtained in this way (e.g., how many times the Website is visited, how many times you see a particular advert) is used to deliver adverts to you. In addition, we may use profile information about you (e.g., your gender, age or pastimes) to provide advertisements that are more likely to be of interest to you, including by combining with other available information about you. We may share your information with advertisers or other third parties that assist us with these types of services, when we have either removed from it anything that personally identifies you, or encoded or combined it with other information so that it no longer personally identifies you.

5. YOUR USER PROFILE

Your user profile is the information you decide to provide when you create or manage your Holaa Services account (e.g., your Holaa user ID, full name, address, telephone numbers, gender, date of birth, language, status, photo, and any other information that you decide to make available). Holaa stores your user profile centrally on a secure server. This information is also visible to other Holaa users. You control your user profile and decide what (if anything) to make public. You can access your user profile within the Holaa Services in order to access, change, correct, complete or remove information. Holaa may remove unsuitable or illegal material at any time from your profile or other postings in accordance with the Terms of Use.

6. THIRD PARTY WEBSITES, PLATFORMS AND APPLICATIONS

Holaa Websites and Holaa Services may contain links that will let you access Third Party Services such as another website, platform or application. Third Party Services are outside Holaa’s control and not covered by this Privacy Statement. Holaa accepts no responsibility or liability for Third Party Services. You should take care before providing any personal information to anyone and in these cases especially to review the applicable privacy statements or policies.

Certain Holaa Services use the Google Places service provided by Google, Inc. When you use these services then you also agree to the Google Privacy Policy as set out at http://www.google.com/policies/privacy. If you choose to connect one or more of your Third Party Services profiles to Holaa we will be able to access the profiles of your connections and improve your user experience on the Holaa Services. This is entirely optional for you and if you have enabled such a connection you can choose to disconnect it at any time. Your connections' information will not be disclosed to other Holaa users unless your connections permit us to do so.

Remember that use of Third Party Services may in addition be subject to your signing up for an account with and accepting the terms and conditions of the relevant third party, including provisions relating to processing of personal data, which may differ from Holaa’s policies and for which Holaa is not responsible. You can view, manage and block the third party services that use your Holaa ID by logging into your Holaa profile at any time.

7. HOW DOES HOLAA PROTECT YOUR PERSONAL INFORMATION?

Holaa takes appropriate organizational and technical measures to protect the personal information and communications data provided to them or collected by them. For example, your personal and communications data can only be accessed by authorized Holaa staff that need to have access to this data in order for their work.

Holaa takes technical measures to protect the confidentiality of the content of communications sent over the Holaa Services, subject to all applicable obligations and exceptions under applicable law.

8. CONTACTING YOU

Holaa may contact you to notify you of issues and faults with the Holaa Services, and if you are considered to have breached any of the terms of your Agreement with Holaa or if another person makes a complaint about your use of the Holaa Services (e.g., a claim that you have infringed their rights in some way).

Holaa may also use email, SMS or the Holaa Services to keep you up to date with news about the Holaa Services that you use and/or other Holaa Services unless you have opted out of receiving this information. If you do not want to be kept informed in this way, please contact Holaa at support@holaa.me.

Holaa may occasionally ask you to provide information on your experiences with the Holaa Services. Any such feedback will always be voluntary and will be used only for the purposes of measuring and improving the quality of the Holaa Services and Website and not stored as personal information or combined with any of your other personal information.

9. CAN THIS PRIVACY STATEMENT BE CHANGED?

Holaa reserves the right to modify this Privacy Statement at any time by notifying you by any reasonable means or by publishing the modified Privacy Statement at http://www.holaa.me/privacy. The modified Privacy Statement will become effective thirty days from such publication or notification, unless you expressly accept the modified Privacy Statement earlier. Such express acceptance by you, or your continued use of any Holaa Service after expiry of the notice period of thirty days, shall constitute your consent to the modified Privacy Statement.

10. WHAT ARE YOUR RIGHTS AND HOW CAN YOU CONTACT HOLAA?

You have the right to access correct, complete or remove your personal information. To do so, please contact Holaa at support@holaa.me. After verifying your identity and provided your request is legal, within a reasonable period of time Holaa will fulfil your request.

You may also ask Holaa to stop processing your personal information. If you have shared information and changed your mind, then you can delist your number or your entire contact information so that it will not be searchable. However, please note that this may prevent you from using some or all of the Holaa Services.

Also if you are not a Holaa user and find that another person has provided us with your details then you always have the right to access, rectify or ask us to stop processing your data by contacting Holaa at support@holaa.me.

11. HOW LONG IS PERSONAL INFORMATION KEPT BY HOLAA?

Holaa will retain your information for as long as is necessary to carry out any of the purposes set out in this Privacy Statement and comply with applicable legislation, and any applicable orders of regulatory bodies or courts.