Table of Contents
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.
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.
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:
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.
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.
(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.
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.
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.
means an augmented, virtual or mixed reality content experience.
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.
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”.
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.
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:
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):
Carl Jacobsens Vej 35
Helpline number: +45 33 19 32 00
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:
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
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:
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.
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.
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.
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).
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.
We may use your Information for the following purposes:
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.
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.
Your Personal Data may be transferred to, and processed in, countries other than thecountry of which you are a resident. These countries may have data protection laws thatare 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 Cloudservers 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 willcontinue to be the data controller in respect of any Personal Data transferred to or sharedwith such third parties and shall remain responsible for the processing undertaken bythem.
The following is a list of the main businesses who currently process data on our behalf in relation to the Hololink Platform:
We may also share Information between our group countries, which are located in countries worldwide, including the United States.
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.
We may disclose your Information to or share it with the following types of recipients:
We will not sell, trade or rent your Personal Data to anyone.
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.
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 deidentiﬁed user data to the prospective buyer of such business or assets.
The Hololink Platform may contain links to websites, microsites and other online 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.
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 Personal Data from access by unauthorised persons and against unlawful processing, accidental loss, destruction and damage. Speciﬁcally, we use the following measures:
Even though we have taken the above security measures given the nature of online communications 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 unauthorised person who is determined to circumvent our security measures.
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.
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.
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.
Please see our separate page on cookies for information on how Hololink Ltd. uses cookes, analytics and similar technologies in connection with the Hololink Platform.
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 Ved Stadsgraven 9, 2300 Copenhagen¢, Denmark. The company is VAT registered in Denmark and our VAT registration number is the same as our company number.
Ved Stadsgraven 9, kld.
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.