Effective Date: July 7, 2021
This Privacy Policy describes The Holding Co. (“The Holding Co.”, “we,” “our” or “us”) practices with respect to the collection, use, and disclosure of information we collect from you through our websites, web and mobile applications, products and services, and any other products or services we provide to our users (collectively, the "Services").
By accessing or using the Services, you agree to this Privacy Policy and our Terms of Service. Capitalized terms not defined in this Privacy Policy will have the meanings ascribed to them in the Terms of Service Any processing of information or content uploaded by way of the Services (collectively, “Account Data”) will be subject to the Terms of Service and this Privacy Policy. This Privacy Policy does not apply to any third party products or services, applications or software, including those that are offered within, or used in connection or integrate with the Services (“Third Party Services”).
WHAT INFORMATION WE COLLECT
Account Data and Other Information. We may collect and receive Account Data and other information (collectively, “Information”) in a variety of ways. Users granted access to the Services may upload Account Data to the Services. We may also collect and receive other Information in the following ways, including when you:
We use email to exchange information efficiently for the benefit of users. We recognize that email messaging may not be a completely secure means of communication. Your use of the Services means that you agree and consent to the use of email as an acceptable form of communication.
Account Information.
To create or update an account with us, you may be asked to provide us with Information related to the creation of accounts or that otherwise identifies you as a registered user. Information may include Personal information (as defined below), such as your name, email address, mailing address, age, gender or phone number. If you create an account using any third-party service (such as Facebook or Google), we may collect Information about you from the third-party service provider (such as your username or user ID associated with the third-party service). By choosing to create an account using the third-party service, you authorize us to collect Information necessary to authenticate your account with that third-party service provider. In addition, if you purchase any Services, you may provide us (or our payment processors) with billing details such as credit card information, banking information and a billing address.
Use of the Services.
We collect information about how you use the Services and some of your actions on the Services, including IP addresses, what software and hardware you use (such as browser types, operating systems, ISP, platform type, device type, mobile device identifiers (i.e., make and model and mobile carrier)), metadata, pages or features of the Services used and associated dates and time-stamps, search terms, links you click, whether you open messages sent to your account, and other statistics related to your usage of the Services. We may also use tools, including third party tools, to collect analytics data. Some of this information is collected through the use of "cookies" and other tracking technologies, such as web beacons and similar technologies. We may also work with third party partners to support our use of these tracking technologies. These are used by us to allow you access to our Services, identify irregular site behavior, prevent fraudulent activity and improve security, assess the performance of our Services, help us understand how our users use the Services, allow us to offer you enhanced functionality when accessing or using our Services, for instance, to identify you when you sign into our Services or to keep track of your specified preferences, interests, or past items viewed, or to use first party or third party data to deliver content, on our Services or on third party sites.
Location Information.
We receive Information from you and other third parties that helps us approximate your location. We may, for example, use an IP address received from your browser or device to determine approximate location. We may also collect location information from devices in accordance with the consent process provided by your device.
Third Party Services.
Certain aspects of the Services allow you to link or integrate third party products and services to enable certain features and functionalities with the Services. If you choose to use these features or functionalities, you may be asked to create an account with a third-party service provider or link your existing account with that service provider (and, by doing so, agree to the privacy policy and/or terms and conditions of that third-party). You may also be asked to authorize us to collect information from the third-party service provider on your behalf. We will then collect information (such as your username or user ID associated with that third-party service) from you and/or that third party service provider as necessary to enable the Services to access your data and content stored with that third-party service provider. Once the authentication is complete, we have the ability to access information you provided to us or was otherwise collected by the third-party service in accordance with the privacy practices of that third-party service. We will store the information and data we collect and associate it with your account, and we will only use that information and data to enable the integration of the Services with the third-party service provider and to perform actions requested or initiated by you, or that are reasonably necessary to carry out instructions provided by you.
Third Party Data.
We may receive data about organizations, industries, lists of companies that are customers, site visitors, marketing campaigns and other matters related to our business from affiliates, our partners, or others that we use to make our own information more useful. This data may be combined with Information we collect and might include aggregate-level data or specific data.
You are under no obligation to provide Information to us, however, certain Information is collected automatically and, if some Information, such as account Information, is not provided to us, we may not be able to provide the Services.
HOW WE USE INFORMATION
Account Data will be used by us in accordance with your instructions, including in the Terms of Service, and as required by applicable law. Information may be used in furtherance of our legitimate business interests that does not conflict with this Privacy Policy, including as described below.
To Provide the Services. We may use Information to provide the Services to you including:
To Improve, Update and Protect the Services. We may use Information to improve, update and protect the Services including:
If Information is aggregated or de-identified so that it is no longer reasonably associated with an identified or identifiable natural person, we may use it for any business purpose.
To the extent Information is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection law, it is referred to in this Privacy Policy as “Personal Information.” We may use Personal Information for the above purposes, in accordance with your instructions and applicable law, including to respond to law enforcement or other governmental or legal requests or to act under exigent circumstances to protect the personal safety of users or the public. We may also use Personal Information for other purposes that are clearly disclosed to you at the time you provide Personal Information, or with your consent. We will not use or disclose sensitive personal information, such as race, religion, or political affiliations, without your explicit consent.
DATA RETENTION
We will retain Account Data to fulfill the purposes for which it was collected in accordance with your instructions and as required by applicable law. We will retain other Information for as long as necessary for the purposes described in this Privacy Policy. We may keep such Information after you have deactivated your account for the period of time needed for us to comply with applicable law, pursue legitimate business interests, conduct audits, comply with legal obligations, resolve disputes, and enforce our agreements.
MANAGING INFORMATION
You may access, correct, amend, or delete Information by accessing it within your account or by contacting us at privacy@theholding.co. Information you delete may be retained in archived or backup copies in order to enable you to use certain features of the Services. For any questions regarding managing your Information, please contact us at privacy@theholding.co. Please note that permanent deletion of Information through this process may impair or disable those features with respect to that Information.
If you would prefer not to accept cookies or otherwise wish to disable our use of tracking technologies, most browsers and mobile devices allow you to change your settings so as to notify you when you receive cookies or other tracking technologies are being used, and to choose whether or not to accept/allow it. Most browsers also allow you to disable or delete existing cookies or to automatically reject future cookies. Disabling cookies, however, may limit your ability to use the Services. Certain tracking technologies we use are related to advertising networks, and through those technologies we may share certain information such as IP addresses. Please note that the information we share with those advertising networks might be combined with other information about you that those networks may have collected from other sources. To learn more about advertising networks and how to opt out of sharing information with them, please visit the following sites: https://optout.aboutads.info/?c=2&lang=EN and https://optout.networkadvertising.org/?c=1. For any questions regarding our use of cookies or tracking technologies, please contact us at privacy@theholding.co.
We may use Information we collect for marketing purposes, including to send you promotional email or other communications about new features, products, events, or other opportunities. If you wish to stop receiving these communications or to opt out of use of your Information for these purposes, please follow the opt-out instructions by clicking "Unsubscribe" (or similar opt-out language) in those communications. You can also contact us at privacy@theholding.co to opt out.
HOW WE SHARE AND DISCLOSE INFORMATION
Except as specifically provided in this Privacy Policy, we do not share or disclose your Information including your Personal Information. We may share or disclose Information we collect for the following purposes:
Users of the Services may enable or permit Third Party Services. We require the Third Party Services to disclose all permissions for Information access in the Services, but we do not guarantee that they do so. When enabled, we may share Information with such Third Party Services. Third Party Services are not owned or controlled by us and third parties that have been granted access to Information may have their own policies and practices for its collection, use, and sharing.
We may disclose or use aggregated or de-identified Information for any legitimate business purpose. For example, we may share aggregated and/or de-identified Information with partners for business or research purposes or for statistical and analytical purposes.
SECURITY
We implement appropriate technical and organizational measures to protect the information we collect and store. Unfortunately, given the nature of communications and information processing technology, we cannot guarantee that Information during transmission over the Internet or while stored on our systems or otherwise in our possession will be absolutely safe from destruction, loss, alteration, unauthorized disclosure of, or access by others. When you click a link to a third-party site, you will be leaving our site and we don’t control or endorse any third-party sites. If you believe your Information may not be secure for any reason, please contact us immediately at privacy@theholding.co.
AGE RESTRICTIONS
The Services are not directed to anyone under the age of 18 (or other age as required by applicable law) and we do not knowingly collect Personal Information from children. If we learn that we have collected Personal Information from a child, we will take reasonable steps to delete such information from our files as soon as is practicable.
CHANGES TO THIS PRIVACY POLICY
Any Information that we collect is subject to the Privacy Policy in effect at the time such Information is collected. We may, however, revise the Privacy Policy from time to time. The current version of the Privacy Policy will always be posted to our Privacy Policy page. If you have any questions about this Privacy Policy, please contact us at privacy@theholding.co.
INTERNATIONAL USERS
We process and store information on servers located in the United States, and are subject to the applicable state and federal laws of the United States. If you choose to access or use the Services, you consent to the use and disclosure of information in accordance with this Privacy Policy and subject to such laws.
CALIFORNIA CONSUMER PRIVACY ACT
California consumers have certain rights regarding the Personal Information we collect about them under the California Consumer Privacy Act (“CCPA”). We collect and share the Personal Information for the business and commercial purposes described in this Privacy Policy. We do not sell (as ‘sell’ is defined in the CCPA) the Personal Information we collect. Subject to certain limitations, the CCPA also provides California consumers the right to request to know more details about the categories or specific pieces of Personal Information we collect (including how we use and disclose this information), to delete their Personal Information, to opt out of any ‘sales’ that may be occurring, and to not be discriminated against for exercising these rights. California consumers may make a request pursuant to their rights under the CCPA by contacting us at privacy@theholding.co. We will verify your request using the information associated with your account, including email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.
CONTACTING US
Please feel free to contact us if you have any questions about this Privacy Policy, or if you are seeking to exercise any of your legal rights. We will respond within a reasonable time period. You may contact us at privacy@theholding.co.
