Privacy Notice

There’s a reason for everything – also this Privacy Notice

We have put together this Privacy Notice which you are currently reading to help you understand what information we collect about users of our technology platform and the Hololink Website (Hololink.io) and how we use and share this information. It also contains important information about your rights. The Privacy Notice is an essential part of your engagement with Hololink Ltd. and it is important that you read it carefully. By engaging with us in the ways set out in this notice, you confirm that you have read and understood the entirety of this notice, as it applies to you.


Applicability

This Privacy Notice applies to your use of those Hololink Platform that display or provide an authorised link to this notice.

This Privacy Notice does not extend to any websites or services of third parties which can be accessed from the Hololink Platform, including any links we may provide to social media sites.


The meaning behind it all

In this Privacy Notice some of the words we use have capital letters. This is because we have given these words a particular meaning. These words are listed below:

Anonymous Information
means information that does not identify and cannot reasonably be used to identify a specific individual. When Anonymous Information is linked with Personal Data, this Anonymous Information is normally treated by Hololink as Personal Data.

Content
means content made available on or via the Hololink Platform. This might include hololinks, animation, mini-games, documents, images, links, sound files, videos, text, and other content.

Information
(depending on the context) means any or all information that you or your device send, submit or transmit to Hololink via the Hololink Platform. Information also includes information automatically collected by us and information about you, which we obtain from other sources.

IP Address
means an Internet Protocol address, a number that is automatically assigned to your device when you use the internet and which may vary from session to session.

Personal Data
means any information we hold about you which could be used to identify who you are, e.g. your name, email, home address, IP Address and may include other information such as identification numbers and location data.

Third Party Content
means Content which is owned or controlled by a person other than Hololink, including (a) Content which is created by Hololink for a brand, entertainment franchise or other client and (b) Content which is published on our platform by users of our services.

You
means an augmented, virtual or mixed reality content experience.

Hololink
means content made available on or via the Hololink Platform. This might Hololinks, animation, mini-games, documents, images, links, sound files, videos, text, and other content.

Hololink Platform
Means our augmented reality web based authoring tool and viewer combined with existing and future services made available through the Hololink Website and tools. called “Hololink”, including all versions of that application published by Hololink Ltd.

Hololink Ltd. or we
means Hololink Limited, a private limited company in Denmark and registered in Denmark with company number DK40261117.

Hololink Website
means the official Hololink Website available at https://www.Hololink.io/

Where we refer to a “person” this includes individuals, companies, corporations, partnerships, limited liability partnerships, co-operatives, associations and other natural and legal persons.

When we use the words “includes” or “including” in this Privacy Notice we are not limiting ourselves in any way and mean “includes or including without limitation”.


Identity of the Data Controller

The data controller is Hololink Ltd.
Our contact details are shown below in the section headed “Contacting Us”. Third parties controllers are the controllers with regard to the processing of your personal information in connection with your use of Third Party Content and, in that capacity, are solely responsible for compliance with applicable data protection and other legislation and regulation with regard to such processing.


You have RIGHTS!

As a data subject, you have the following rights under EU data protection legislation (including the European General Data Protection Regulation (GDPR)) and UK Data Protection Act, which we will always work to uphold:
• The right to be informed about our collection and use of Personal Data;
• The right of access to the Personal Data we hold about you (see “How can you access your Personal Data?”);
• The right to rectification if any Personal Data we hold about you is inaccurate or incomplete (please contact us using the details in “Contacting Us”);
• The right to be forgotten – i.e. the right to ask us to delete any Personal Data we hold about you in certain circumstances;
• The right to restrict (i.e. prevent) the processing of your Personal Data in certain circumstances;
• The right to data portability. This means that, if you have provided Personal Data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that Personal Data to re-use with another service or business in many cases;
• The right to object to us using your Personal Data for a particular purpose or purposes;
• and Rights with respect to automated decision making and profiling.

When making a request, please be aware that we may be unable to delete Information that resides in our archives, and the requested removal of certain Information may mean we are no longer able to provide you with all or certain parts of the Hololink Platform.

If you have any cause for complaint about our use of your Personal Data, please contact us using the details provided in “Contacting Us” and we will do our best to solve the problem for you. If we are unable to help, you also have the right to lodge a complaint with the Danish supervisory authority, The Danish Data Protection Agency (Datatilsynet):

Datatilsynet

Carl Jacobsens Vej 35
2500 Valby
Denmark
Helpline number: +45 33 19 32 00
E-mail: dt@datatilsynet.dk


All the information we might collect

As and when you visit, browse or use Hololink Platform we may collect certain Information from you. Some of this Information may be Personal Data and some of the Information may be Anonymous Information. We use your Information in accordance with the terms of this Privacy Notice.

Below is a list of some of the Information we may collect from you, depending on how you interact with Hololink:
• Information to enable the use of certain features
• Emails sent to Hololink and messages submitted via the Hololink Website
• Competition entries
• Responses to surveys and feedback requests
• User Generated Content
• Information given to us by other companies
• Device information
• Information relating to your use of the Hololink Platform
• Log Data - Hololink Websites

****Use of certain features
****

There are some features of the Hololink Platform that may require you either to confirm your country and age* and/or opt-in before you can access those features (e.g. photo share, newsletter, ‘upload feature’). You may be asked to provide certain Information about yourself when doing this. This could be one or more of the following items of Personal Data: your name, your email address, your postcode or zip code, your country of residence, username and password.

*Age information is not stored by us.

Emails and other Information submitted to Hololink

If you choose to email or write to Hololink Ltd. about the Hololink Platform, or you fill in an online contact or support request form, we may collect Information about you from the content of your letter, email or other message e.g. your name, your email address, and what you like or dislike about the Hololink Platform. If you participate in a competition or promotion, or respond to a survey or feedback request then in addition to your entry or response we may collect your name, email and/or other contact details.

User Generated Content

Some features of the Hololink Platform may allow you to create, submit, post, display, transmit or share content (e.g. photos, videos, comments, messages, and other materials) on or through the Hololink Platform (we call this “User Generated Content”). This includes any ‘upload feature’ which is attached to Hololink published by a third party (i.e. a person other than Hololink Ltd.). You may find Hololinks printed on third party products or see them within third party services and publications. These images enable you to unlock digital content on your mobile device by scanning the image.

When you use the Hololink App we will only collect and store your User Generated Content, if you choose to share an animated GIF from within an experience, or you upload content to a Hololink. We do not collect or store any photos or videos that you take within an experience, even if you choose to share that content with others.

Some of your User Generated Content may contain personal information about you or other natural persons, e.g. audio, photos or videos featuring you or your friends. We therefore advise you to be selective about what personal information you include in User Generated Content, and not to include any of the following types of personal information in any submission to any publicly available area of the Hololink Platform: telephone numbers, physical addresses, full name or any other information of a sensitive nature. If you upload personal information about or depicting other individuals (e.g. a photo of a friend), you must obtain their consent first.

Please be aware that even if you remove personal information that you post to the Hololink Platform, copies may still remain in cached and archived pages of the Hololink Platform or on another user’s device.

IT IS ALSO IMPORTANT TO NOTE THAT YOU AND NOT HOLOLINK ARE RESPONSIBLE FOR, AND CONTROL YOUR USER GENERATED CONTENT. IF YOUR USER GENERATED CONTENT CONTAINS ANY PERSONAL INFORMATION OF OTHERS THEN UNLESS YOU ARE DOING THIS AS PART OF A PURELY PERSONAL OR HOUSEHOLD ACTIVITY YOU MAY HAVE OBLIGATIONS AS A ‘DATA CONTROLLER’ UNDER APPLICABLE DATA PROTECTION LAW THAT YOU NEED TO COMPLY WITH.

Information collected from other sources

We may engage the services of other companies to handle certain tasks relating to the Hololink Platform. This may include payment processing, search engine facilities, storage and serving of content, advertising and marketing, and analytics. These companies may send us Personal Data relating to you. We may also collect information about you from publicly available sources, such as via the internet and social networks, including through public or licensed APIs. If we do collect such information from third parties, we will only use that information in accordance with this Privacy Notice. Equally, these companies may collect personal information directly from you. If they do, that company and not Hololink will be the data controller in respect of any information you provide to them (e.g. your credit card details) and you should check their privacy policy to find out how they will use your information.

Analytics and information about your device

When you use the Hololink Platform, our servers will automatically access or collect information from your device (e.g. smartphone), including the following:
• an Installation ID (see below);
• the IP Address linked to the device: we will process this to infer coarse user location (Country and City), and then discard the IP Address;
• the time;
the make and model of your device (including operating system version);
• the version of the application being used; and
• information about your use of the application.

We may use this Anonymous Information in the following ways: (i) to analyse and optimize your use of the Hololink Platform; (ii) to provide notifications within a Hololink based on your activities on the Platform; (iii) to develop new features and functionality; and (iv) to develop new products or services which we believe may be of use to you or other users of the Hololink Platform. This information will also be available to some creators of Hololinks through tools like Google Analytics and Facebook Pixels.

Installation ID

The Installation ID is a unique installation ID generated by the Hololink Platform when it is first run. The ID is a random number seeded from the system time and cannot be used to identify who you are. The ID is stored in the app’s storage directory (or locally) on your device and is used to anonymously track your use of the mobile application in various ways, e.g.
• when you open the mobile application
• when you tap “Scan”;
• the names and time of scan of Hololink’s accessed;
• how long you spend interacting with a Hololink;
• when you perform certain actions during a Hololink e.g. completing a game, high score achieved.

The Installation ID is not accessible to other apps or sites on your device and does not track you beyond the Hololink Platform. We do not share the Installation ID within any third party.

Log Data – Hololink Websites

Our systems will automatically record and store information created by your access to and use of our websites, including specific actions performed by you within these Hololink Platform (collectively, “Log Data”). This may include information about your device, your IP Address, browser type, the pages that you visit, time spent on pages and other statistics. We use this information to better tailor the Hololink Platform to our users’ needs and to provide you with targeted communications that you are happy to receive from us. We may also link this automatically collected information to Personal Data. We may also add Log Data to our customer relationship management system. We do not use any Log Data to track you outside of the Hololink Platform. This log data will also be available to some creators of Hololinks.

GPS Location Data

Hololink does not currently receive or process any GPS location data provided by you or which we receive from location service providers. We may however wish to do so in the future to tailor the Hololink Platform offered to users in a particular geographical location. If this becomes the case, we will only process GPS location data for which you have given us your consent, including your GPS location, which were provided by you or which we receive from GPS location service providers, but only for so long as this is necessary for delivering the Hololink Platform and/or to the extent required as permitted by applicable law.


All the information we might collect

Legal basis for processing Personal Data

Our legal basis for collecting and using your Personal Data will depend on the Personal Data concerned and the specific context in which we collect it. However, we will normally collect Personal Data from you only where (i) we need the Personal Data to perform a contract with you; (ii) the processing is in our legitimate interests and not superseded by your rights; (iii) we have a legal obligation to process your Personal Data; or (iv) we have your consent to do so (e.g. you have ticked a box, or signed up for a newsletter).

Under our terms of use for the Hololink Platform, we refer to when we make the Hololink Platform available to you, provide customer support, integrate the Hololink Platform with technology and distribution platforms such as Apple iOS and Google Android, and inform you of service-related changes. If there is no legal contract between you and Hololink (e.g. because you are a minor), then we will process Personal Data for these purposes on the basis of our legitimate interests.

We process your Personal Data on the basis of our “legitimate interests”, for example, when we provide you with the Hololink Platform, carry out marketing, keep the Hololink Platform secure, for engineering purposes, analysing users behavior across the Hololink Platform, providing customer support, and running, growing and developing our business.

We have a “legal obligation” to process your Personal Data when complying with a legal obligation, such as preventing a crime or fraud or maintaining tax records. This ground may also include our obligation under the European General Data Protection Regulation (GDPR)) and UK Data Protection Act, to protect your Personal Data. If you have questions about the legal basis for collecting and using your Personal Data, please contact us using the contact information provided in the “Contacting Us” section below.


This is how we use the information

We may use your Information for the following purposes:

add table later

Profiling and automated decision making

We do create and maintain user profiles relating to some visitors to our websites. These profiles are created when a visitor fills in a form on Hololink.io. No profiles are created for visitors who just browse the site(s). Our aim is to limit the Personal Data contained in these profiles to that required to achieve our legitimate interest of helping users get the best from our platform.

Marketing communications

We may use your Information to send you notifications and information about the Hololink Platform. If you have consented to receive marketing, you may opt out at a later date. If at any time you no longer wish to be contacted for this purpose, please let us know and we will remove you from our mailing list. Please note that you may not opt out of service related emails as these are necessary for the security and performance of the Hololink Platform.


We will put it right here

Your Personal Data may be transferred to, and processed in, countries other than the country of which you are a resident. These countries may have data protection laws that are different from the laws of your country.

We use Digital Ocean and Google Cloud to store and process data on our behalf in connection with the Hololink Platform. We primarily use Digital Ocean and Google Cloud servers around the world to store and process your Information.

We may engage other businesses to carry out data processing on our behalf. For example, we may engage someone to provide payment services, to host the Hololink Platform, to administer electronic mailings on our behalf, or to provide analytics services. We will continue to be the data controller in respect of any Personal Data transferred to or shared with such third parties and shall remain responsible for the processing undertaken by them.

The following is a list of the main businesses who currently process data on our behalf in relation to the Hololink Platform:

Add table later

We may also share Information between our group countries, which are located in countries worldwide, including the United States.


Transfers outside of Europe

If you use the Hololink Platform while you are outside the European Economic Area (EEA), your Personal Data may be transferred to countries outside the EEA to enable us to provide you with those services. The circumstances in which this may happen are:

If any of our servers are located outside the EEA or our service provider is located outside the EEA (see the table above).

The Hololink Platform is available for use internationally. This means it is possible that any Personal Data contained in your User Generated Content (e.g. your picture) that you publish on our platform (e.g. by connecting content to a Hololink, or sharing an animated GIF) may be automatically transferred by our servers to a device, server or other computer equipment being used in a country outside the EEA.

Countries outside of the EEA may not have similar data protection laws to the GDPR and UK Data Protection Act. If we do transfer any of your Personal Data outside the EEA (e.g. to a data processor located outside the EEA) we shall take all steps reasonably necessary to ensure that your Personal Data is adequately protected by: (i) only using processors who comply with EU data protection laws; (ii) the use of the European Commission's Standard Contractual Clauses; and (iii) (in the case of transfers to the US) the transfer of Personal Data to service providers and partners that are certified under the EU-US Privacy Shield.

BY USING THE HOLOLINK PLATFORM YOU SPECIFICALLY GIVE YOUR CONSENT TO THE INTERNATIONAL TRANSFERS REFERRED TO IN THIS SECTION.


Sharing isn’t always caring – but in some cases we need to share information

We may disclose your Information to or share it with the following types of recipients: other users where you allow Information to be made public; social media services you choose to share Information with;
• any third party to whom disclosure is required to enable us to provide you with the Hololink Platform, including our server provider(s);
• other companies that we have engaged to provide services on our behalf e.g. providers of analytics services and customer relationship management tools;
• any third party to whom we believe disclosure is necessary to protect the rights, property or safety of the Hololink Platform, its users and the public. This includes exchanging Information with other companies and organisations for fraud protection and spam prevention;
• the publisher of a Hololinks where you have chosen to upload content to their Hololink;
• any person to whom we believe disclosure is necessary to enable us to enforce our rights under this Privacy Notice or under our Terms of Use or to defend legal claims relating to the Hololink Platform;
• our business partners, which may include advertising, brand and retail partners for the purposes of providing certain services available within the Hololink Platform that are offered in conjunction with those partners. This Information would, for example, allow third-party advertising networks to, among other things, deliver targeted advertisements that they believe will be of interest to you;
• to inform business partners about use of the Hololink Platform and products and services made available through the Hololink Platform, in the form of aggregated statistics or otherwise in a format that does not identify you personally;
• any prospective purchaser of Hololink Limited, its parent company, or the Hololink Platform or any part thereof (see below);
• any subsidiary or holding company of Hololink Limited or any subsidiary of any such holding company for use by them in accordance with this Privacy Notice; and
• other outside parties (e.g. judicial, government or regulatory authorities) to comply with the law and legal obligations.

We will not sell, trade or rent your Personal Data to anyone.


We are not married – you can leave freely

You may withdraw your consent for Hololink to process your Personal Data for direct marketing purposes at any time by notifying us in writing (an email will suffice).

You can opt-out from the future collection of Information by Hololink in accordance with this Privacy Notice by uninstalling the Hololink App from all your devices and discontinuing use of the Hololink Platform.


Changes of business ownership and control

Hololink may choose to expand or reduce our business and this may involve the sale and/ or transfer of control of all or part of Hololink Ltd. or the Hololink Platform. Information provided by users will, where it is relevant to any part of our business so transferred, be transferred along with that part as one of the transferred assets. The new owner or newly controlling party will, under the terms of this Privacy Notice, be permitted to use the information for the purposes for which it was originally supplied to Hololink.

We also reserve the right to disclose de-identified user data to the prospective buyer of such business or assets.


Links to Non-Hololink Platform

The Hololink Platform may contain links to websites, microsites and other on-line services that are operated by third parties i.e. businesses other than Hololink (collectively, “Third Party Services”). Hololink Ltd. does not control these Third Party Services and is in no way responsible for their content, or information collection practices. This Privacy Notice DOES NOT apply to your use of any Third Party Services.

Please consult the terms and conditions and privacy policy of any Third Party Service you choose to access to find out how they will collect, use and share your personal information and to establish whether and for what purpose they use cookies and similar technologies. Some Third Party Content contained on or accessible via the Hololink Platform may operate as links to that third party’s website(s) and as such any information they collect by virtue of your clicking on that link will be collected and used in accordance with the privacy policy of that third party.


Don’t worry – we will take really good care of your information

Data security is of great importance to Hololink Ltd. We have put in place commercially reasonable physical, electronic and managerial security measures to protect your Perso- nal Data from access by unauthorised persons and against unlawful processing, acci- dental loss, destruction and damage. Specifically, we use the following measures:

The Information you send Hololink Ltd. is protected by SSL/TLS end-to-end en- cryption when transmitted from your device to our servers.
• Information stored on our servers is protected by encryption, key authentication and by firewalls. Your Information will only be accessed by authorised employees. These employees are obliged to preserve the confidentiality of all information that comes to their attention unless disclosure is compulsory by law or necessary for the fulfilment of their duties.

• Even though we have taken the above security measures given the nature of online com- munications we cannot 100% ensure the security of your Information or guarantee that your Personal Data will not be accessed, disclosed, altered or destroyed by an unautho- rised person who is determined to circumvent our security measures.


We won’t store your data indefinitely

We will retain your Personal Data for the duration of your use of the Hololink Platform and for a reasonable period thereafter for backup, archival and/or audit purposes or for as long as the law otherwise requires.

Where you have chosen to upload User Generated Content to a Hololink of a third party we will need to continue to store your content on our servers for so long as the third party wishes to have access to your content in accordance with any agreement you or Hololink Ltd. may have entered into with that party.


Just ask us and we will tell you

You have the right to ask for a copy of any of your Personal Data held by us (where such data is actually held by us and we can identify who you are). We will normally provide copies in response to your request free of charge. We do, however, reserve the right to charge a reasonable fee for requests which are manifestly unfounded or excessive, particularly if it is repetitive and for further copies of the same Information.

We will ask you to provide reasonable proof of your identity before we disclose any Information to you.


Children’s Privacy and the Children’s Online Privacy Protection Act (COPPA)

This section of the Privacy Notice applies if any Hololink Platform are accessed from within the USA or any other country which requires parental consent to be obtained before any collection of personal information from a child under the age of 13.

Hololink Ltd. does not knowingly collect or solicit personal information from children under the age of 13. The Hololink Platform and their Content are not intentionally directed at children under the age of 13 and we do not target children under 13 as our primary audience. In the event we learn that we have inadvertently collected personal information from a child under the age of 13, and that child lives in a country which does not permit such collection without prior parental consent, we will delete that information as quickly as possible.

If a parent or legal guardian becomes aware that their child under the age of 13 has provided us with personal information without prior parental consent, please contact us at the address below and we will delete such information from our files.

So we can comply with international privacy laws, we may use age screens for some Hololinks. We do not store any individual’s date of birth.


Cookies and all that Mambo Jambo

Please see our separate page on cookies for information on how Hololink Ltd. uses cook- ies, analytics and similar technologies in connection with the Hololink Platform.

If our use of cookies involves the processing of Personal Data, the legal basis for this will be our legitimate interests, i.e. to help us to provide you with a good experience when you use the Hololink Platform (including making them more secure) and to improve the Hololink Platform by understanding how you use them.


Changes to our Privacy Notice

The Hololink Platform, our collection and use of Personal Data and other information, and the laws and regulations which apply will change over time. We reserve the right to make changes to this Privacy Notice. When we update the Privacy Notice, we will post the new version to (link to privacy policy) and change the “Last Updated” date. We encourage you to visit this page from time to time for the latest on our information collection practices.


Holla at us

The Hololink Platform are owned and operated by Hololink Ltd., a company incorporated in and registered in Denmark with company number DK40261117. The Company’s registered office address is Raffinaderivej 20, 2300 Copenhagen S, Denmark. The company is VAT registered in Denmark and our VAT registration number is the same as our company number.

If you have any questions about the Hololink Platform or these Terms of Use, please contact us using the following addresses: contact@hololink.io

Postal Address
Hololink Aps
Raffinaderivej 20
2300 Copenhagen S
Denmark

Email
contact@hololink.io


Applicable law

Irrespective of which country you live in or submit Information from the law which applies to this Privacy Notice shall be the law of Denmark.
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