Terms & Conditions
Privacy Notice
Table of Contents
There’s a reason for everything – also this Privacy Notice
Applicability
The meaning behind it all
Identity of the Data Controller
You have RIGHTS
All the information we might collect
We need to process Personal Data to make it all possible Legal basis for processing Personal Data
This is how we use the information?
We will put it right here
Transfers outside of Europe
Sharing isn't always caring - but in some cases we need to share information
We are not married - you can leave freely
Changes of business ownership and control
Links to Non-Hololink Platform
Don't worry - we will take really good care of your information
We won't store your data indefinitely
Just ask us and we will tell you
Children's Privacy and the Children's Online Privacy Protection Act (COPPA)
Cookies and all that Mambo Jambo
Changes to our Pricacy Notice
Holla at us
Applicable law
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 under stood he entirety of this notice, as it applies to you.
Applicability
This Privacy Notice applies to your use of those Hololink Platform that display or providean authorised link to this notice.This Privacy Notice does not extend to any websites or services of third parties which canbe 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 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 you, the natural person accessing, browsing, downloading or using any Hololink Platform.****
Hololink
means an augmented, virtual or mixed reality content experience.****
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 reuse 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 featuresThere 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);
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.
We need to process Personal Data to make it all possible
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 behaviour 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: