This privacy notice together with our, and any additional documents referred to within, sets out how and the extent to which HollaEx shall process your personal data as user or visitor. Please read these documents carefully to fully understand our views and practices regarding your personal data and how we will treat it.
This Privacy notice describes our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.
The use of the services provided by HollaEx is conditioned by the acceptance of the Terms and Conditions of Use and the reading of this Policy. If you do not agree to these conditions, please do not use our services.
. DATA WE COLLECT
Personal information items collected:
HollaEx shall not collect any sensitive personal information which may lead to the infringement of human rights of users, including their race, ethnicity, ideas and creeds, place of birth and legal domicile, political orientations and criminal records, health status, and sexual life.
HollaEx shall collect and use the following essential personal information:
2.1) Identification and Confirming Opinion on Membership Registration. Name, Birthdate, Gender, Mobile phone number, Connecting Information (CI), Duplication Information (DI), email address Password, Security code, Residence (Address)
2.2) Self Identification for Payments and Withdrawals. Name, Birthdate, Account Number, Copy of ID card, Mobile phone number, Security code, Trading account balances, trading activity, your inquiries and our responses.
2.3) Self Identification for Level Up. Name, email address, Mobile phone number, Picture of the owner with the ID card, Written oath (Membership name, Mobile phone number, Bank name, Account number), Copy of ID card, Driver’s license, Passport, Wallet address, Withdrawal account number, Residence (Address).
2.4) Security Code Reset. Name, email address, Mobile phone number, Copy of ID card, Driver’s license, Passport, Picture (Facial).
Prevention of use by fraudulent members and prevention of unauthorized use
- users’ IP address and date and time of their visit to the Company’s website
Verification of users’ real name
- name, date of birth, gender
2.5) Collecting Items for Asset Transfer. Name, Birthdate, email address, Mobile phone number, Copy of ID card, Picture (Facial), Certified copy of residence registration, Family relation certificate, Certificate of subscription to communication service, Mobile phone bill, Certificate for Accommodation.
B. Collection method
HollaEx shall collect personal information through the following methods:
- homepage, cell phone applications, cell phone web page, subscription account, trading transactions, telephone, consumer bulletin board, e-mail, and event application
- Collection of personal information through a tool for collecting created information.
3) PURPOSE OF COLLECTING AND USING PERSONAL INFORMATION.
HollaEx shall collect and use customers’ personal information for the following purposes:
- Member management.
- Self-authentication for the use of membership-based services, verification of individuals’ identity.
- Prevention of use of services by fraudulent members and of unauthorized use.
- Verification of users’ willingness to obtain membership and limitation on membership and the number of obtaining membership.
- Identification of minors.
- Records retention for consulting with customers, acceptance and handling of customers’ complaints and disputes resolution.
- Delivery of notices.
- Performance of agreements on the provision of services and payment of charges.
- Provision of services and contents, as well as tailored-made services.
- Payment and settlement of fees.
- Notification of the result of winning prizes at events/giveaways and delivery of products.
C. Use for marketing and advertisements.
- Providing optimized services for customers
- Developing and specializing in new services (products)
- Providing services and posting advertisements according to demographic traits
- Identifying the frequency of access to the Company’s homepage
- Statistics on the use of services
- Mailing periodicals and offering guidance on new products or services
- Planning web services and events that meet customers’ interests
- Delivering advertising materials such as sweepstakes, events, company news, partnership/affiliate news, or operate member participation space
- Conducting customer questionnaire-based survey.
Provision of Personal Information
HollaEx shall neither use nor provide customers’ personal information for any third party beyond the scope of which customers are notified upon collection of their information or the scope that is specified at the terms and conditions of the use of services, unless the customers agree or except for the following cases:
HollaEx may provide customers’ personal information for its partners or share such information with its partners for the provision of better services. In case the Company does the foregoing acts, individual customers shall be notified in advance of who are our partners, what kinds of personal information items are provided or shared and why such personal information should be provided or shared and until when such information should be protected and managed, either in writing or e-mail, and give their consent to the provision and sharing of their personal information. If customers do not agree, the Company shall neither provide for its partners nor share their personal information with its partners. If there is any change in or termination of the Company’s partnership, the Company shall notify customers of such change or termination or seek their consent through the same procedure as described above.
Customers’ personal information is required for the performance of an agreement on the provision of services, but it is significantly difficult to obtain customers’ ordinary consent due to economic and technological reasons.
3.1 Privacy when using digital assets and blockchains
Your funding of Digital Assets may be recorded on a public blockchain. Public blockchains are distributed ledgers, intended to immutably record transactions across wide networks of computer systems. Many blockchains are open to forensic analysis which can lead to deanonymization and the unintentional revelation of private financial information, especially when blockchain data is combined with other data.
Because blockchains are decentralized or third-party networks which are not controlled or operated by HollaEx or its affiliates, we are not able to erase, modify, or alter personal data from such networks.
4) HOW DO WE PROTECT PERSONAL INFORMATION?
The Company respects the privacy of any users who access its website, and it is therefore committed to taking all reasonable steps to safeguard any existing or prospective clients, applicants and website visitors.
The Company keeps any personal data of its clients and its potential clients in accordance with the applicable privacy and data protection laws and regulations.
We have the necessary and appropriate technical and organizational measures and procedures in place to ensure that your information remains secure at all times. We regularly train and raise awareness for all our employees to the importance of maintaining, safeguarding, and respecting your personal information and privacy. We regard breaches of individuals’ privacy very seriously and will impose appropriate disciplinary measures, including dismissal from employment. We have also appointed a Group Data Protection Officer, to ensure that our Company manages and processes your personal information in compliance with the applicable privacy and data protection laws and regulations, and in accordance with this Privacy Notice.
The personal information that you provide us with when applying to open an account, applying for a role within the Company, or when using our website, is classified as registered information, which is protected in several ways. You can access your registered information after logging in to your account by entering your username and the password that you have selected. It is your responsibility to make sure that your password is only known to you and not disclosed to anyone else. Registered information is securely stored in a safe location, and only authorized personnel have access to it via a username and password. All personal information is transferred to the Company over a secure connection, and thus all reasonable measures are taken to prevent unauthorized parties from viewing any such information. Personal information provided to the Company that does not classify as registered information is also kept in a safe environment and accessible by authorized personnel only through username and password.
6) COLLECTION PURPOSES
Improve our services. We use your information to improve our sites. We use your information to customize your experience with us. We also use your information to serve you specific content that is most relevant to you.
Legal matters we may use your personal data to comply with court requests, and administrative inspections, among other government legal requirements. In the case of a court request, all personal data will be fully available to the administrative or judicial authorities if our legal team agrees with the legal basis of the particular case.
Compliance with a legal obligation. There are a number of legal obligations imposed by relevant laws to which we are subject, as well as specific statutory requirements e.g. anti-money laundering laws, financial services laws, corporation laws, privacy laws and tax laws. There are also various supervisory authorities whose laws and regulations apply to us. Such obligations and requirements imposed on us necessary personal data processing activities for identity verification, payment processing, compliance with court orders, tax laws or other reporting obligations and anti-money laundering controls.
These obligations apply at various times, including client on-boarding, payments and systemic checks for risk management.
Marketing we may use your data to send you emails, notifications, text messages and postal mail. We will never do it, however, without your express authorization and you can choose not to subscribe and continue enjoying the rest of our services. To provide you the best experience, the processing of such communications may be subject to automated individual decision-making, including profiling.
Security purposes. We use your information to protect our company and our customers. We also use your information to protect our sites. We use your information to prevent, discover and investigate violations of our Policy or Terms. Our data security measures include, but are not limited to: PCI Scanning, Secured Sockets Layered encryption technology, pseudonymization, internal data access restrictions, and strict physical access controls to buildings and files.
5) THIRD PARTY PROVIDERS
Analysis of the use of software: we resort to applications in order to analyze the use of our platform, such as Google Analytics.
Data storage and processing: storage, processing and backup of your personal data is carried out securely in hosting and computing companies located mainly in Amazon cloud servers.
Audits and maintenance: your data might be accessed within the scope of independent quality control and security audits of our services. All audits are subject to confidentiality and are closely monitored by this platform’s team.
‘’Cookies” are data files that are placed on your device or computer, with the users’ previous consent. Our cookies have different functions:
Cookies strictly necessary (essential)
These cookies allow navigation on the website and use of its applications as well as allowing access to secure areas of the website. Without these cookies, services you have requested cannot be provided. Some cookies are essential to access specific areas of our website.
We use Google Analytics, on our website. It may utilize several tracking technologies, including cookies, to analyze how you use our services. The analytic data does not include personal information. We also use third party servers to obtain web analytics and intelligence about our Site. These tools use programming code to collect information about your interaction with our Site, such as the pages you visit, the links you click on and how long you are on our Site. These tools do not store any personal identifiable information.
These cookies keep the user preferences regarding the use of the website, so it is not necessary to configure the website for each new visit.
These Cookies are necessary to enable you to move around our Site and use its features. These Cookies also allow our Site to remember your previous action within the same browsing session.
Advertising and retargeting cookies
These Cookies save information from your browsing history in order to record your interests and your browsing path on our Site. We may use advertising and targeting cookies for retargeting, which enables our advertising partners to target advertising to you on other websites, based on your visit to our Site. Without these Cookies, online advertisements you encounter will be less relevant to you and your interests.
Third party cookies
They measure the success of applications and the effectiveness of third-party advertising.
Cookies can be:
These remain stored, for a variable time, on the Internet browser of the devices the users use to access it (PC, mobile and tablet); these cookies also are used when the user accesses multiple times the website. They are typically used for direct navigation according to the user's interests, allowing us to provide a customized service.
These are temporary and remain stored on your web browser until you exit the website. The information obtained allows us to identify problems and provide a better browsing experience.
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.
If you do not accept our cookies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Site.
How can you manage cookies?
As previously explained, cookies help you to get the most out of our site. For more information about the cookie’s functionality, please click here.
Usage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.
We process a limited amount of sensitive data when we carry out verification of identity. In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter a contract.
7) CHILDREN’S DATA
Our products and services are directed at adults aged 18 years and over, and not intended for children. We do not knowingly collect data from this age group. Our verification process prevents this platform collecting this data. If any data is collected from a child without verification of parental consent, it will be deleted.
All data requested by this platform is mandatory and failure to provide this Data may make it impossible for this platform to provide its services. In cases where this platform specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service. If you become aware that your child has provided us with Personal Information, please contact us at firstname.lastname@example.org. If we become aware that a minor has provided us with Personal Information, we take steps to remove such information and terminate that person’s account.
8) HOW WE PROTECT YOUR PERSONAL INFORMATION
This platform takes reasonable care to protect its security as well as your Personal Information from loss, misuse, disclosure, alteration, and destruction. We take reasonable steps to maintain physical, technical, and employ procedural safeguard to ensure the confidentiality, integrity of your Personal Information. The safeguards include the use of firewalls, and data encryption, enforcing physical access controls to Our premise and files, and limiting access to Personal Information only to those employees, agents or third parties who need access to that information to process it for Us.
We also implement certain reasonable security measures to protect your Personal Information from unauthorized access, and such security measures are in compliance with the security practices and procedures as prescribed under the applicable laws.
However, you agree and acknowledge that it is impossible to fully guarantee the security of your Personal Information by implementing the above-mentioned safeguard and measures. It is not absolute protection to your Personal Information and by accessing the Services.
You agree that we will not hold any responsibility for the acts committed by those who gain unauthorized access or abuse your information and services. In addition, we will not hold any responsibility for any act committed by the third-party service providers who are contractually engaged with Us to maintain an appropriate security measure for protecting your Personal Information. Thus, you are recommended to understand this responsibility and to independently take safety precautions to protect your Personal Information, particularly your credential information such your wallet address. You hereby agree that we will not be liable for any information leakage and other damage, or loss not caused by Our intention or gross negligence, including, but not limited to, hacker attacks, power interruptions, or unavoidable technical failures.
9) WAYS WE USE YOUR INFORMATION
Your Personal Information will be made available to need-to-know basis to this platform, Our affiliates, and/or within Our group of companies. This will include, but not be limited to, the employees and/or any persons or third parties working for this platform who are responsible for using and protecting your Personal Information.
We use and process your Personal Information for the following purposes or in the following ways:
To provide Our Services
We respect data protection principles, and process personal data only for specified, explicit, and legitimate purpose for which such personal data were provided. We primarily use your Personal information, either collected or delivered, in order to enable your use of this platform Services (including, but not limited to, processing transactions), to improve the efficiency of the Services, and to verify your identity.
To protect users
We use the information collected to protect Our Platforms, Users' information, and archives. We also use IP addresses and cookies to detect suspicious activities and to protect against automated abuse such as spam, phishing, and Distributed Denial of Service (“DDoS”) attacks, and other security risks.
To comply with regulations and compliance
For Our legitimate interests, we will use the information in compliance with Our legal obligations, global and local industry standards, and Our AML/KYC/CTF procedures. In the case where it is strictly necessary (i.e. to protect the vital interests of the users or other natural persons, to prevent or mitigate fraud, to fulfil the purpose of public interest, or to pursue Our reasonable interests), We may use and process your Personal Information without obtaining your consent. You hereby expressly authorize this platform to disclose any and all information relating to you in this platform’s possession to any law enforcement or government officials upon the only request by a valid court order.
For measurement, research, and development purposes
We actively measure and analyze your information to understand the way you use and interact with Our Services, and Our Platform, and to provide you with the unique and personalized experience. For example, we allow you to use social media plugins on Our Services. We keep track of your preferences such as display name, time zone, and so on. This review is continuously conducted by Our operation teams to continuously improve Our Platforms' performance and to resolve issues with user experience.
For communication purposes
To enforce Our T&Cs, and other relevant agreements
Personal Information is also used to enforce Our T&Cs continuously and actively among, and other agreements relating to the Services of this platform. Activities in this regard include, but are not limited to, reviewing, investigating, mitigating, and preventing any potentially prohibited or illegal activities that may violate preceding provisions, or disclose relevant information to third parties in accordance therewith. Considering this, this platform shall be entitled to freeze/close/delete accounts or any user activity as necessary to any User found to be engaged in any activities that violate Our T&Cs, and other agreements.
For marketing and advertising
We will share your Personal Information with Our marketing partners for the purposes of targeting, modelling, and/or identifying analytics as well as marketing and advertising. We may send you marketing communications to alert you about new Services, yet you can opt-out of Our marketing activities at any time.
For other purposes
10) LEGAL BASIS FOR PROCESSING IN EUROPE
The lawful basis we use for collecting and processing your information in Europe (as required by current legislation) are as follows:
- Where it is necessary for entering into or performing a contract with you.
- Where we have a legitimate interest to do so, provided your rights do not override those interests.
- Where you have consented to its uses.
- Where our colleagues believe it is in your vital interests to share your personal details.
- Where required to comply with our legal obligations.
11) DISCLOSURE OF YOUR INFORMATION
a) We may share your information with selected third parties including:
- Affiliates, business partners, suppliers and subcontractors for the performance and execution of any contract we enter with them or you.
- Advertisers and advertising networks solely to select and serve relevant adverts to you and others with your consent.
- Analytics and search engine providers that assist us in the improvement and optimization of our platform, and our group entities or subsidiaries.
b) We may disclose your personal information to third parties:
- Such as affiliates, business partners, suppliers and subcontractors for the performance and execution of any contract we enter with them or you.
- If we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- If we are under a duty to disclose or share your personal data to comply with any legal obligation, or to enforce or apply our Customer Agreement and other applicable agreements; or to protect the rights, property, or safety of this platform, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
- To assist us in conducting or co-operating in investigations of fraud or other illegal activity where we believe it is reasonable and appropriate to do so.
- To prevent and detect fraud or crime.
- In response to a subpoena, warrant, court order, or as otherwise required by law.
- To recover debt or in relation to your insolvency; and
- To develop customer relationships, services, and systems.
c) We do not have a list of all third parties we share your data with, as this would be dependent on your specific use of our Services. However, if you would like further information about who we have shared your data with, or to be provided with a list specific to you, you can request this by writing to email@example.com.
12) SHARING AND STORING YOUR PERSONAL DATA
In order to provide our Services to you, it is sometimes necessary for us to transfer your data to the third parties that are based outside of the European Economic Area. In these cases, we ensure that both ourselves and our partners take adequate and appropriate technical, physical, and organizational security measures to protect your data. We also ensure we have appropriate contractual protections (e.g. BCR, Standard Contractual Clauses) in place with these parties receiving the data outside the EEA.
13) PROFILING AND AUTOMATED DECISION MAKING
We may use some elements of your data to customize our Services and the information we provide to you, and to address your needs — such as your country of residence and transaction history. For example, if you frequently send funds from one currency to another, we may use this information to inform you of new product updates or features that may be useful for you. When we do this, we take all necessary measures to ensure that your privacy and security are protected — and we only use pseudonymized data wherever possible. This activity has no legal effect on you.
We may use Automated Decision Making (ADM) to improve your experience, or to help fight financial crime. For example, so that we can provide you with a fast and efficient service, we may use ADM to confirm the accuracy of the information you have provided to us. None of our ADM processes have a legal effect on you.
14) DATA RETENTION
This platform is required by law to store some of your personal and transactional data beyond the closure of your account with us. We only access your data internally on a need-to-know basis, and we’ll only access or process it, if it is necessary.
We will always delete data that is no longer required by a relevant law or jurisdiction in which we operate.
15) RETENTION TIME
As a matter of principle, this platform stores personal data only as long as necessary to fulfill the contractual or legal obligations to which this platform has collected the data. Thereafter, this platform deletes the data immediately, unless this platform needs the data until the expiration of the statutory limitation period for evidence for civil claims or for statutory storage requirements. Even following this statutory limitation period, this platform sometimes must save the User’s data for accounting reasons. this platform is obliged to do so because of legal documentation obligations which may arise from legal obligations. The deadlines for storing documents are 5 years.
The Company may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, we may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted; therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
16) YOUR RIGHTS
Subject to applicable laws, you may have the right to access information we hold about you. Your right to access can be exercised in accordance with the relevant data protection legislation. If you have any questions in relation to our use of your personal information, contact us. Under certain conditions, you may have the right to require us to:
- Provide you with further details on the use we make of your information.
- Provide you with a copy of the information that you have provided to us.
- Update any inaccurate, incorrect, or out of date personal information we hold.
- Delete any personal information that is no longer necessary, or no longer subject to a legal obligation to which this platform is subject to. This platform has legal obligations so it may not be possible to delete your data at the time of request. Once the required time has passed then we will be able to comply with your request.
- Where processing is based on consent, to withdraw your consent so that we stop that processing.
- Cease direct marketing to you, by contacting us or adjusting your notification preferences in the settings section of your account.
Where we undertake wholly automated decision making which results in the creation of a legal obligation or a similar significant impact, you may request that we provide information about the decision-making methodology and ask us to verify that the automated decision has been made correctly.
We may reject the request, as permitted by applicable law, including when providing the information would result in a disclosure of a trade secret or would interfere with the prevention or detection of fraud or other crime. However, generally in these circumstances we will verify that the algorithm and source data are functioning as anticipated without error or bias or if required by law to adjust the processing.
We object to any processing based on the legitimate interests ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights restrict how we use your information whilst a complaint is being investigated.
Your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege). If you exercise any of these rights, we will check your entitlement and respond in most cases within a month.
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in this company or for the purposes of the legitimate interests pursued by the company, users may object to such processing by providing a ground related to their situation to justify the objection.
17) INTERNATIONAL TRANSFERS
18) GDPR /RGPD
If you are a resident of EU, under the General Data Protection Regulation (GDPR), the relevant Data Protection information may be contacted at firstname.lastname@example.org. Please be aware that where GDPR applies, you have the right to lodge a complaint with the competent data protection authority.
19) CCPA - California Consumer Privacy Act- California
Under the California Consumer Privacy Act (CCPA) Notice you have the right to know your Personal Information. You can request the last 12 months of personal information collected from your use of the Services. You will need to provide your identity so we can return the requested data to you. Please note that you must make the request from each browser or device where you access the Services. For more information, please contact us at: email@example.com
California do not track notice
We do not currently respond or take any action with respect to web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party websites or online services. We may allow third parties, such as companies that provide us with analytics tools, to collect personally identifiable information about an individual consumer’s online activities over time and across different websites when a consumer uses the Services.
Do Not Sell My Personal Information
We do not sell personal information. However, the Service Providers we partner with (for example, our advertising partners) may use technology on the Service that “sells” personal information as defined by the CCPA law.
If you wish to opt-out of the use of your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by contacting us.
20) CHANGING AND ACCESSING PERSONAL INFORMATION
To the extent required by applicable law, you may be able to request that we inform you about the personal information we maintain about you and, where appropriate, withdraw your consent for certain data processing activity and/or request that we update, correct, delete, and/or stop processing your personal information. We will make all required updates and changes within the time specified by applicable law and as required by law. When permitted by law, we may charge an appropriate fee to cover the costs of responding to the request. Such requests may be submitted by writing to our contact information.
To protect your confidentiality, we can only respond to such requests to the email address that you have registered or otherwise provided to us. Please remember that if you make such a request, we may not be able to provide you with the same quality and variety of services to which you are accustomed.
In addition, in some circumstances based on applicable law, you may request that we cease sharing personal information about you with our business partners or that we cease using personal information about you by contacting us using the email address above. We will seek to honor those requests consistently with applicable law.
If you feel that we have not addressed your questions or concerns adequately, or you believe that your data protection or privacy rights have been infringed, you can complain to any supervisory authority or other public body with responsibility for enforcing privacy laws. in the case you are in the United Kingdom this is the Information Commissioner’s Office; you can see their contact details via the ICO website.
The changes should affect processing activities performed based on the user’s consent, the Company shall collect new consent from the user, where required.