HOLATUNE ’s Privacy Commitment
We ask for only the least amount of information necessary, gathering only what we believe is essential for doing business, or for the specific transaction at hand.
The goal of this policy is to make explicit the information we gather, how we will use it, and how we will not. This policy is unfortunately longer than we would like, but we must unambiguously address all the relevant cases. We will try and keep the language simple and direct as much as possible.
Part I – Information HOLATUNE collects and controls
This part deals with how HOLATUNE collects and uses information about website visitors, potential customers, users of HOLATUNE's products and services, and others who contact HOLATUNE through forms or email addresses published on or linked to our websites.
Part II – Information that HOLATUNE processes on your behalf
This part deals with how HOLATUNE handles data that you entrust to HOLATUNE when you use our products and services, or when you share any personal or confidential information with us while requesting customer support.
Part III – General
Part I – Information HOLATUNE collects and controls
What information HOLATUNE collects
We collect information about you only if we need the information for some legitimate purpose. HOLATUNE will have information about you only if (a) you have provided the information yourself, (b) HOLATUNE has automatically collected the information, or (c) HOLATUNE has obtained the information from a third party. Below we describe the various scenarios that fall under each of those three categories and the information collected in each one.
Information that you provide us
i. Account signup : When you sign up for an account to access one or more of our services, you'll be required to use an email address and a password for creating the account. Once your account is created, you can also add information like your name, contact number, email address, company name, and country to complete your profile.
ii. Payment processing : When you start to actively use your account, we ask you to provide your name, contact information, tax ID and credit card information or other payment account information. In all cases, your credit card information is stored and processed by the Payment Gateway Service Provider you choose, not by us. During the payment they inform you about their privacy and security policies, make sure you read them carefully.
iii. Interactions with HOLATUNE : We may record, analyze and use your interactions with us, including email, telephone, and chat conversations with our sales and customer support professionals, for improving our interactions with you and other customers.
Information that we collect automatically
i. Information from browsers, devices and servers : When you visit our websites, we collect information that web browsers, mobile devices and servers make available, such as the internet protocol address, browser type, language preference, time zone, referring URL, date and time of access, operating system, mobile device manufacturer and mobile network information. We include these in our log files to understand more about visitors to our websites.
iii. Information from application logs and mobile analytics : We or our contractors may collect information about your use of our services from application logs and in-house usage analytics tools, and use it to understand how your business use and needs can improve our products. This information includes clicks, scrolls, features accessed, access time and frequency, errors generated, performance data, storage utilized, user settings and configurations, and devices used to access and their locations.
Information that we collect from third parties
i. Signups using OpenID authentication service providers : You can log in to HOLATUNE Services using supported OpenID authentication service providers such as Soundcloud, Facebook and Google. These services will authenticate your identity and give you the option to share certain personal information with us, such as your name and email address.
Purposes for using information
In addition to the purposes mentioned above, we may use your information for the following purposes:
To keep you posted on new products and services, upcoming events, offers, promotions and other information that we think will be of interest to you;
To ask you to participate in surveys, or to solicit feedback on our products and services;
To set up and maintain your account, and to do all other things required for providing our services, such as enabling collaboration, providing website and mail hosting, and backing up and restoring your data;
To understand how users use our products and services, to monitor and prevent problems, and to improve our products and services;
To provide customer support, and to analyze and improve our interactions with customers;
To detect and prevent fraudulent transactions and other illegal activities, to report spam, and to protect the rights and interests of HOLATUNE, HOLATUNE’s users, third parties and the public;
To update, expand and analyze our records, identify new customers, and provide products and services that may be of interest to you;
To analyze trends, administer our websites, and track visitor navigations on our websites to understand what visitors are looking for and to better help them;
To monitor and improve marketing campaigns and make suggestions relevant to the user.
Legal bases for collecting and using information
Legal processing bases applicable to HOLATUNE : If you are an individual from the European Economic Area (EEA), our legal basis for information collection and use depends on the personal information concerned and the context in which we collect it. Most of our information collection and processing activities are typically based on (i) contractual necessity, (ii) one or more legitimate interests of HOLATUNE or a third party that are not overridden by your data protection interests, or (iii) your consent. Sometimes, we may be legally required to collect your information, or may need your personal information to protect your vital interests or those of another person.
Withdrawal of consent : Where we rely on your consent as the legal basis, you have the right to withdraw your consent at any time, but this will not affect any processing that has already taken place.
Legitimate interests notice : Where we rely on legitimate interests as the legal basis and those legitimate interests are not specified above, we will clearly explain to you what those legitimate interests are at the time that we collect your information.
Your choice in information use
Opt out of non-essential electronic communications : You may opt out of receiving newsletters and other non-essential messages by using the ‘unsubscribe’ function included in all such messages. However, you will continue to receive notices and essential transactional emails.
Disable cookies : You can disable browser cookies before visiting our websites. However, if you do so, you may not be able to use certain features of the websites properly.
Optional information : You can choose not to provide optional profile information such as your photo. You can also delete or change your optional profile information.
Who we share your information with
Third-party service providers : We may need to share your personal information and aggregated or de-identified information with third-party service providers that we engage, such as marketing and advertising partners, event organizers, web analytics providers and payment processors. These service providers are authorized to use your personal information only as necessary to provide these services to us.
Other cases : Other scenarios in which we may share the same information covered under Parts I and II are described in Part III.
Your rights with respect to information we hold about you as a controller
If you are in the European Economic Area (EEA), you have the following rights with respect to information that HOLATUNE holds about you. HOLATUNE undertakes to provide you the same rights no matter where you choose to live.
Right to access : You have the right to access (and obtain a copy of, if required) the categories of personal information that we hold about you, including the information's source, purpose and period of processing, and the persons to whom the information is shared
Right to rectification : You have the right to update the information we hold about you or to rectify any inaccuracies. Based on the purpose for which we use your information, you can instruct us to add supplemental information about you in our database.
Right to erasure : You have the right to request that we delete your personal information in certain circumstances, such as when it is no longer necessary for the purpose for which it was originally collected.
Right to restriction of processing : You may also have the right to request to restrict the use of your information in certain circumstances, such as when you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Right to data portability : You have the right to transfer your information to a third party in a structured, commonly used and machine-readable format, in circumstances where the information is processed with your consent or by automated means.
Right to object : You have the right to object to the use of your information in certain circumstances, such as the use of your personal information for direct marketing.
Right to complain : You have the right to complain to the appropriate supervisory authority if you have any grievance against the way we collect, use or share your information. This right may not be available to you if there is no supervisory authority dealing with data protection in your country.
Retention of information
Part II – Information that independent contractors or providers process on our behalf
Information entrusted to independent contractors or providers and purpose
Information provided in connection with services : We may entrust your information to independent contractors or providers we use in connection with providing our services or for providing technical support for our services. The data may either be stored on our servers when you use our services, or transferred or shared to us as part of a the services provided.
Who we share service data with
Third party sub-processors : In order to provide services and technical support for our products, HOLATUNE engages other third parties .
Employees and independent contractors : We may provide access to your service data to our employees and individuals who are independent contractors HOLATUNE involved in providing the services (collectively our “employees”) so that they can (i) identify, analyze and resolve errors, (ii) manually verify emails reported as spam to improve spam detection, or (iii) manually verify scanned images that you submit to us to verify the identities of rightsholders of distributed content. We ensure that access by our employees to your service data is restricted to specific individuals, and is logged. Our employees will also have access to data that you knowingly share with us for technical support or to import data into our products or services. We communicate our privacy and security guidelines to our employees and strictly enforce privacy safeguards within HOLATUNE.
Third-party integrations you have enabled : Most of our products and services support integrations with third-party products and services. Through these third-party integrations, you may be allowing the third party to access your service information and personal information about you. We encourage you to review the privacy practices of the third-party services and products before you enable integrations with them.
Other cases : Other scenarios in which we may share information that are common to information covered under Parts I and II are described in Part III.
Retention of information
We hold the data in your account as long as you choose to use HOLATUNE Services. Once you terminate your HOLATUNE user account, your data will eventually get deleted from active database during the next clean-up that occurs once in 6 months. The data deleted from active database will be deleted from backups after 3 months.
Data subject requests
If you are from the European Economic Area and you believe that we store, use or process your information on behalf of one of our customers, please contact us if you would like to access, rectify, erase, restrict or object to processing, or export your personal data.
Part III – General
Children’s personal information
Our products and services are not directed to individuals under 16. HOLATUNE does not knowingly collect personal information from children who are under 16 years of age. If we become aware that a child under 16 has provided us with personal information, we will take steps to delete such information. If you believe that a child under 16 years has provided personal information to us, please write to us with the details, and we will take the necessary steps to delete the information we hold about that child
How secure is your information
At HOLATUNE, we take data security very seriously. We have taken steps to implement appropriate administrative, technical & physical safeguards to prevent unauthorized access, use, modification, disclosure or destruction of the information you entrust to us.
Disclosures in compliance with legal obligations
We may be required by law to preserve or disclose your personal information and service data to comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements.
Enforcement of our rights
We may disclose personal information and service data to a third party if we believe that such disclosure is necessary for preventing fraud, investigating any suspected illegal activity, enforcing our agreements or policies, or protecting the safety of our users.
In the event that we sell our business or get acquired or merged, we will ensure that the acquiring entity is legally bound to honor our commitments to you. We will notify you via email or through a prominent notice on our website of any change in ownership or in the uses of your personal information and service data. We will also notify you about any choices you may have regarding your personal information and service data.
Notification of changes
Our contact information:
0151 Tbilisi (Georgia)
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