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Privacy Policy
Effective date: July 30, 2024
Holini OÜ (“us”, “we”, or “our”) operates the https://holini.com website (hereinafter referred to as the “Service”).
This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Service and the choices you have associated with that data.
We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms of Service, accessible from https://holini.com
Definitions
Service
Service in the Privacy Policy context includes both the services described on the website and activities in connection with our website like automated marketing activities, email subscriptions, etc. Website is the https://holini.com operated by Holini OÜ.
Personal Data
Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
Usage Data
Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Cookies
Cookies are small files stored on your device (computer or mobile device).
Data Controller
Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.
For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.
Data Processors (or Service Providers)
Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.
We may use the services of various Service Providers in order to process your data more effectively.
Data Subject (or User)
Data Subject is any living individual who is using our Service and is the subject of Personal Data.
Information Collection and Use
We collect several different types of information for various purposes to provide and improve our Service to you.
Types of Data Collected
Personal Data
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:
- Email address
- First name and last name
- Phone number
- Address, State, Province, ZIP/Postal code, City
- Cookies and Usage Data
We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or the instructions provided in any email we send.
Usage Data
We may also collect information on how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’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.
Location Data
We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Service, to improve and customise our Service.
You can enable or disable location services when you use our Service at any time by way of your device settings.
Tracking Cookies Data
We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information.
Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we use (the list is not limited by these):
- Session Cookies. We use Session Cookies to operate our Service.
- Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
- Security Cookies. We use Security Cookies for security purposes.
- Marketing Cookies. We use Marketing Cookies for marketing purposes.
Use of Data
Holini OÜ uses the collected data for various purposes:
- To provide and maintain our Service
- To notify you about changes to our Service
- To allow you to participate in interactive features of our Service when you choose to do so
- To provide customer support
- To gather analysis or valuable information so that we can improve our Service
- To monitor the usage of our Service
- To detect, prevent and address technical issues
- To provide you with news, special offers and general information about goods, services and events
- To serve you with interest and behavioral based advertising and content about our Service
Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)
If you are from the European Economic Area (EEA), Holini OÜ legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.
Holini OÜ may process your Personal Data because:
- We need to perform a contract with you
- You have given us permission to do so
- The processing is in our legitimate interests and it is not overridden by your rights
- To comply with the law
Retention of Data
Holini OÜ will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.
Holini OÜ will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.
Transfer of Data
Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
Holini OÜ will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.
Disclosure of Data
Business Transaction
If Holini OÜ is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.
Disclosure for Law Enforcement
Under certain circumstances, Holini OÜ may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Legal Requirements
Holini OÜ may disclose your Personal Data in the good faith belief that such action is necessary to:
- To comply with a legal obligation
- To protect and defend the rights or property of Holini OÜ
- To prevent or investigate possible wrongdoing in connection with the Service
- To protect the personal safety of users of the Service or the public
- To protect against legal liability
Security of Data
The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
Third Party Service Providers
Holini OÜ may share your personal data with third parties to provide and maintain our Service or when we have your consent to do so. Additionally, we may de-identify, anonymize, or aggregate data in a manner that no longer identifies you before sharing with third parties for legally permitted purposes.
Legal basis: Legitimate interests in leveraging data for broader business purposes or consent for specific data-sharing activities.
By agreeing to Holini’s Privacy Policy, you consent to us sharing your personal data with the following service providers:
| Service provider | Data we may share | Purpose | Service provider policy details |
|---|---|---|---|
| Google Workspace | Email addresses, documents, user-generated content, metadata | To facilitate business communications, document management, and collaboration. Google Workspace may also use data for security, compliance, and operational purposes. | Google Privacy Policy |
| Make | Email address, phone number, first name, last name, organization name, automation workflows | To automate and synchronize workflows across different platforms and tools, ensuring efficient data transfer and process integration. | Make Privacy Policy |
| ConvertKit | Email address, phone number, first name, last name, organization name, subscription preferences | To send marketing communications, newsletters, product updates, and promotional content. Also used for managing subscriber lists and tracking engagement. | ConvertKit Privacy Policy |
| Pipedrive | Email address, phone number, first name, last name, organization name, communication history, deal information | To manage customer relationships, track interactions, and manage sales pipelines. Data may be used for analyzing and optimizing sales processes. | Pipedrive Privacy Policy |
Marketing and promotional purposes
Holini OÜ may share your data (email, first name, last name, phone number, etc.) with our service providers, advertisers, partners, and sponsors for marketing, promotions, advertisements, and other commercial communications.
Legal basis: Legitimate interests in conducting marketing activities or consent where you have explicitly agreed to such sharing.
With your explicit consent for marketing and promotional purposes, we may share your personal data with the following service providers:
| Service provider | Data we may share | Purpose | Service provider policy details |
|---|---|---|---|
| Email address, phone number, first name, last name, unique identifiers (e.g., Google Analytics Client ID, session ID, Google Ads Click IDs) | To improve marketing and analytics data accuracy, including conversion measurement, Enhanced Conversions, and Customer Match. | Google Privacy Policy | |
| Meta (Facebook) | Email address, phone number, first name, last name, unique identifiers (e.g., Meta Browser ID, Meta Click ID, Meta Lead ID) | To improve marketing and analytics data accuracy, including conversion measurement, Conversions API, and Custom Audiences. | Facebook Privacy Policy |
| Email address, phone number, first name, last name, organization name, unique identifiers (e.g., LinkedIn Ads Click ID) | To improve marketing and analytics data accuracy, including conversion measurement, Conversions API, and Matched Audiences. | LinkedIn Privacy Policy | |
| Make | Email address, phone number, first name, last name, organization name | To integrate and synchronize multiple marketing and analytics platforms and tools with the latest data. | Make Privacy Policy |
| ConvertKit | Email address, phone number, first name, last name, organization name | To integrate and synchronize multiple marketing and analytics platforms and tools with the latest data. | ConvertKit Privacy Policy |
| Pipedrive | Email address, phone number, first name, last name, organization name | To manage customer relationship and sales pipeline, including tracking communication and improving customer interaction. | Pipedrive Privacy Policy |
Children’s Privacy
Our Service does not address anyone under the age of 18 (“Children”).
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
Your Data Protection Rights under the General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Holini OÜ aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.
If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.
In certain circumstances, you have the following data protection rights:
The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
The right to object. You have the right to object to our processing of your Personal Data.
The right of restriction. You have the right to request that we restrict the processing of your personal information.
The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
The right to withdraw consent. You also have the right to withdraw your consent at any time where Holini OÜ relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
Our Policy on “Do Not Track” Signals under the California Online Protection Act (CalOPPA)
We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
Changes to This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and update the “effective date” at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
Contact Us
If you have any questions about this Privacy Policy, please contact us:
- By email: privacy@holini.com