Hola Privacy Policy

Last Updated: Nov 18, 2024

Hola VPN Ltd. ("Hola", "we," or "us") is the owner of the website Hola.org ("the Site"), the Hola software ("the Software") and any accompanying services, features, content, and applications offered by us (collectively referred herein as "the Services"). We are concerned about your privacy and have designed this Privacy Policy in order to help you decide whether to use the Services. By accessing and using the Services, or providing information to us in other formats, you agree and accept the terms of this Privacy Policy as amended from time to time and consent to the collection and use of information in the manner set out in this Privacy Policy. We encourage you to review this Privacy Policy carefully and to periodically refer to it so that you understand it and any subsequent changes made to it.
IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY, PLEASE STOP USING THE SERVICES IMMEDIATELY AND UNINSTALL WHERE RELEVANT.

What types of information do we collect?

We collect the following types of data from you when you use the Services:

• Personal Information: we may collect and retain your IP address, name and email address, screen name, payment and billing information or other information we may ask from time to time, but only information which will be required for the on-boarding process and services provisioning. When you create an account on the Services you are able to do so by using your credentials with a designated third party website or service ("Third Party Account") such as Gmail®. Doing so will enable you to link your account and your Third Party Account. If you choose this option, a Third Party Account pop-up box will appear that you will need to approve in order to proceed, and which will describe the types of information that we will obtain. This information includes your Personal Information stored on your Third Party Account, such as user-name, email address, and profile picture. Any Anonymous Information that is specifically connected or linked to any Personal Information, is treated by us as Personal Information, as long as such connection or linkage exists.
• Installed Applications: we may collect names of applications that are installed on the user’s device and selected by the user to be unblocked by the Software (applicable only to mobile platforms).
• Registering through social network account: When you register or sign-in to the Services via your social network account (e.g., Facebook, Google+), we will have limited access to basic information from your social network account, such as your full name, email address and profile picture. We collect this information in order to communicate with you and show you custom app UI. At all times, we will abide by the terms, conditions and restrictions of the social network platform.
• Log Data: Log data may include the following information - IP address, operating system, browser type, web pages you visit, time spent on those pages, access times and dates.

How do we use your information?

We use your information in order to provide you with the Service. This means that we will use the information to set up your account, provide you with support regarding the Service, communicate with you for updates, marketing offers or concerns you may have and conduct statistical and analytical research to improve the Service.

Information sharing in case of extraordinary circumstances

We do not sell any Personal Information. We may share Personal Information as described in this Privacy Policy. We disclose minimal Personal Information, not including Log Data, to other trusted third party service providers or partners for the purposes of providing you with the Services, storage and analytics. We may also transfer or disclose Personal Information to our subsidiaries, affiliated companies, only when it’s necessary to provide the Services.

In extraordinary circumstances, we also share your Personal Information, including Log Data, and other information if and only if it's necessary to: (1) comply with law, regulation, subpoena or court order; (2) detect, prevent or otherwise address fraud, security, violation of our policies or technical issues; (3) enforce the provisions of this Privacy Policy or any other agreements between you and us, including investigation of potential violations thereof; (4) protect against harm to the rights, property or safety of us, its partners, its affiliates, users, or the public.

Processing of data outside the EEA

Please note that some data recipients may be located outside the EEA. In such cases we will share your data only with recipients located in such countries as approved by the European Commission as providing adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection.

Security and Confidentiality

We use industry-standard information, security tools, and measures, as well as internal procedures and strict guidelines to prevent information misuse and data leakage. Our employees are subject to confidentiality obligations. We use measures and procedures that substantially reduce the risks of data misuse, but we cannot guarantee that our systems will be absolutely safe. If you become aware of any potential data breach or security vulnerability, you are requested to contact us immediately. We will use all measures to investigate the incident, including preventive measures, as required.

Your Choices and Rights

We strive to give you ways to update your information quickly or to delete it (including without limitation, when such information is shared with our third party service providers) – unless we have to keep that information for legitimate business or legal purposes. When updating your personal information, we may ask you to verify your identity before we can act on your request. If you are a resident of California, United States, you have the right to send us a written request regarding a list of Personal Information categories that we may have disclosed to third parties or to which we may have given to third parties, and the details of such third parties.

If you are a resident of the European Union, please note that the following rights specifically apply regarding your personal information: (1) Receive confirmation as to whether or not personal information concerning you is being processed, and access your stored personal information, together with supplementary information; (2) Receive a copy of personal information you directly volunteer to us in a structured, commonly used and machine-readable format; (3) Request rectification of your personal information that is in our control; (4) Request erasure of your personal information; (5) Object to the processing of personal information by us; (6) Request to restrict processing of your personal information by us; (7) Lodge a complaint with a supervisory authority.

However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements.

To exercise such right, you may contact us at: privacy@hola.org

Retention

We will retain your personal information for as long as necessary to provide the Service, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Under applicable regulations, we will keep records containing client personal data, account opening documents, communications and anything else as required by applicable laws and regulations.

We currently retain Log Data for a period of up to 12 months, unless otherwise required, as described above.

We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.

Cookies

When you use our Site, we may store cookies on your computer (as well as other tracking technologies like web beacons and pixels) in order to facilitate and customize your use of our Site. A cookie is a small data text file, which a website stores on your computer's hard drive (if your web browser permits) that can later be retrieved to identify you to us. Our cookies may store information regarding your account information. You are always free to decline our cookies if your browser permits, but such disabling may cause some of the features of our Site to not operate properly and your online experience may be limited.

We also use a tool called “Google Analytics” to collect information about your use of the Site. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Use.

We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our services through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement

Information Warranty Disclaimer

Notwithstanding anything else in this Policy, we are not responsible for the accuracy, correctness, and security of any of the information we gather, store, and disclose to you or to anyone else.

Our policy only addresses the use and disclosure of information we collect from you. To the extent you disclose your information to other parties or sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them. Accordingly, we encourage you to read the terms and conditions and privacy policy of each third party that you choose to disclose information to.

Change of Ownership

In the event of a change of ownership or control of all or a part of Hola, including without limitation through acquisition, merger, or sale, we reserve the right to transfer all or part of the Personal Information and Anonymous Information we store in our systems. You acknowledge that in the event of bankruptcy, insolvency, or receivership, we may have no control over the use and transfer of your personal information.

Changes to this Privacy Policy

This Policy may be revised from time to time at our sole discretion, so please check it regularly. The last revision will be reflected in the "Last Updated" heading. Any change of this policy will be posted on the Site. Your continued use of the Services following any such changes will be considered as you consent to the amended Privacy Policy.

Contact Us

If you feel that your privacy was not treated in accordance with our Privacy Policy, or if you believe that your privacy has been compromised by any person in the course of using the Services, please contact Hola at: privacy@hola.org and our privacy officer shall promptly investigate.

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