Hola Spark Privacy Policy

Hola Networks Limited ("Hola", "we," or "us") is the owner of the website HolaSpark.com, HolaCDN.com ("the Site"), the Hola software ("the Software") and any accompanying services, features, content, and applications offered by us (collectively referred herein as "the Services"). We are concerned about your privacy and have designed this Privacy Policy in order to help you decide whether to use the Services. This Privacy Policy is a legally binding agreement between you ("you" or "user") and us. By accessing and using the Services, or providing information to us in other formats, you agree and accept the terms of this Privacy Policy as amended from time to time and consent to the collection and use of information in the manner set out in this Privacy Policy. We encourage you to review this Privacy Policy carefully and to periodically refer to it so that you understand it and any subsequent changes made to it.

The definitions in the Hola End User License Agreement (https://holaspark.com/license) apply to this Privacy Policy unless stated otherwise.

What types of information do we collect?

We collect the following types of data from you when you use the Services:

  • Anonymous Information. We collect Anonymous Information about your use of the Services for three reasons: first, to allow us to provide the Services and constantly improve them; second, for security reasons; and third, so that we can audit and track usage statistically, audit our affiliates, and calculate payments to 3rd parties. Such Anonymous Information does not enable identification of individual persons; it includes your approximate geolocation, hardware specifications, browser type and version, the date of the Software installation, the date of your last use of the Services, your operating system type, version and language, registry entries, your URL requests, and respective timestamps. We do not make any efforts to reveal your identity through this information.
  • Personal Information. Personal information is information that may be of a private or sensitive nature, and which identifies or may identify you. The Personal Information we collect and retain include your IP address, your name and email address in the case that you provide us with this information (for instance when you open an account or if you approach us through the "contact us" option), screen name, payment and billing information (if you purchase premium services) or other information we may ask from time to time as will be required for the Services provisioning. When you create an account on the Services you are able to do so by using your credentials with a designated third party website or service ("Third Party Account") such as Facebook®. Doing so will enable you to link your account and your Third Party Account. If you choose this option, a Third Party Account pop-up box will appear that you will need to approve in order to proceed, and which will describe the types of information that we will obtain. This information includes your Personal Information stored on your Third Party Account, such as user-name, email address, profile picture, birthday, gender and preferences. Any Anonymous Information that is specifically connected or linked to any Personal Information, is treated by us as Personal Information, as long as such connection or linkage exists.
  • Other Information. HolaCDN collects information regarding video performance, such as start/seek times, buffering events, video bitrates etc.
  • For a more detailed list see our reference guide.

Why are we collecting your information?

We collect the information detailed above in order to provide you with better services. Anonymous Information is collected for research and statistical purposes, for enabling us to further develop, customize and improve the Services, based on your preferences, uses, and interactions with the Services, and to provide you with the most relevant additional services and offers.

Your Personal Information is collected for several purposes: First, it enables us to provide you with a better user experience and more relevant features, capabilities, offers, and marketing materials. Second, it allows us to provide you with support, technical assistance, and replies to your questions and concerns.

How do we collect your information?

In addition to using the information you have provided us (when registering or contacting us), we use various technologies to collect and store information such as cookies, pixel tags, web beacons, and log files.

  • Cookies: A cookie is a small data file that is sent to your browser for record-keeping purposes; it allows the same website to recognize you when you return. We use cookies to save your registration information and to recognize you when you are using the Services. We may also use cookies to help us and our partners customize the content, experience, and advertisements provided to you on websites across the Internet. For example, when you access a web page, a cookie is automatically set by us, our service providers, or our partners to recognize your browser as you navigate on the Internet and to present you with information and advertising based on your apparent interests. We also use session ID cookies to enable certain features of the Services, which allows us to better understand how you interact with the Services and to monitor aggregate usage and web traffic routing on the Services. Session cookies are deleted from your computer when you log off from the Services and close your browser. Third-party service providers or advertisers may also place cookies on your browser for their own purposes. You can choose anytime whether or not to accept such cookies or whether to delete existing cookies from your browser. However, if you delete such cookies, some of the Services may not be available to you.
  • Pixel Tags: A pixel tag is a type of technology placed on a website in combination with cookies to enable tracking activity on websites.
  • Web Beacon: A web beacon is a technique used to track who is reading a web page or email, when they are reading, and from which computer.
  • Log Data: Log Data is data that our servers automatically recorded when you use the Services. Log Data may include information about your device such as: your IP address, browser type, webpages you visit, time spent on those pages, access times and dates, and the unique identifier generated for your device (if you use the Services from your mobile device then such an identifier may be you mobile number). We use such data in its aggregated form and is not combined with any Personal Information.

Information we share

We do not share your Personal Information with third parties except with your specific consent pursuant to this Privacy Policy or if required by applicable laws or court order.

We share Anonymous Information with third parties when required to provide, maintain, or improve the Services. Such third parties may have access to your information only to the extent needed to provide such services. We may also share Anonymous Information with third parties for additional purposes, including marketing, research, and analytics purposes.

We may also share your Personal Information and other information in special cases if we have good reason to believe that it is necessary to: (1) comply with law, regulation, subpoena or court order; (2) detect, prevent or otherwise address fraud, security, violation of our policies or technical issues; (3) enforce the provisions of this Privacy Policy or any other agreements between you and us, including investigation of potential violations thereof; (4) protect against harm to the rights, property or safety of us, its partners, its affiliates, users, or the public.

Do we engage in direct marketing?

We may share your email address (if we have collected it) with our marketing partners and we may use it ourselves for the purpose of providing you news and marketing offers. Out of respect for your right to privacy we provide you with an easy means to decline receiving email offers from us or from our affiliates and partners.

At any time, you may choose to no longer receive commercial or promotional emails by clicking on the "unsubscribe" link at the bottom of each email communication that we send you. It may take up to 10 days for us to process such a request. Even if you have unsubscribed from receiving promotional emails from us, we may send you other types of important email communications without offering you the opportunity to opt out of receiving them. These may include customer service announcements, administrative notices, and surveys.

Please note that changing information in your registration account or opting out of receiving promotional email communications will affect only future communications from us. If we already provided your information to a third party (such as a sponsor or affiliate) before you changed your preferences or updated your information, you may have to change your preferences directly with that third party as well.

Protecting children's information

The Services are not directed or intended for children below the age of thirteen. We do not knowingly collect or solicit Personal Information from individuals under the age of thirteen. If you are below the age of thirteen, you should not register or provide Personal Information through the Services. If we later obtain knowledge that a user is below the age of thirteen, we will take steps to remove that user's Personal Information from our systems. If you are the parent or guardian of a child who you believe has disclosed Personal Information to us, please contact us at info@holaspark.com so that we may delete and remove this child's information from our systems.

If you believe that we might have any information from a child below the age of thirteen, please contact us via email at info@holaspark.com.

Security and Confidentiality

The collection and processing of Personal Information and Anonymous Information is aimed at providing you with the Services and sending you commercial information regarding products or services we think you may be interested in. We will store this information as long as it is reasonably necessary for these purposes and in accordance with any applicable legal or ethical requirement.

We use industry-standard information, security tools, and measures, as well as internal procedures and strict guidelines to prevent information misuse and data leakage. Our employees and contractors access the information on a need-to-know basis and subject to confidentiality obligations.

We use measures and procedures that substantially reduce the risks of data misuse, but we cannot guarantee that our systems will be absolutely safe. If you become aware of any potential data breach or security vulnerability, you are requested to contact us immediately. We will use all measures to investigate the incident, including preventive measures, as required.

Your Choices

We value your privacy and your control of personal information. You may therefore notify us that you wish to review your Personal Information or delete it. You can notify us by sending an email to privacy@holaspark.com. You may choose at any time not to allow us or any third party to collect data about you. You may request to view or edit Personal Information that is stored about you. You may also choose not to accept cookies, including cookies associated with our Services or third-party services. To opt out of Google's use of cookies you can visit Google's Ads Settings (https://adssettings.google.com). However, you should take into account that many of the Services or portions of them may not function properly if your cookies are disabled.

If you are a resident of California, United States, or of the European Union, you have the right to send us a written request regarding a list of Personal Information categories that we may have disclosed to third parties or to which we may have given to third parties, and the details of such third parties. To exercise such right, you may contact us at: privacy@holaspark.com.

Information Warranty Disclaimer

Notwithstanding anything else in this Policy, we are not responsible for the accuracy, correctness, and security of any of the information we gather, store, and disclose to you or to anyone else.

Change of Ownership

In the event of a change of ownership or control of all or a part of Hola, including without limitation through acquisition, merger, or sale, we reserve the right to transfer all or part of the Personal Information and Anonymous Information we store in our systems. You acknowledge that in the event of bankruptcy, insolvency, or receivership, we may have no control over the use and transfer of your personal information.

Changes to this Privacy Policy

This Policy may be revised from time to time at our sole discretion, so please check it regularly. The last revision will be reflected in the "Last Updated" heading. Any change of this policy will be posted on the Site. Your continued use of the Services following any such changes will be considered as you consent to the amended Privacy Policy.

Contact Us

If you feel that your privacy was not treated in accordance with our Privacy Policy, or if you believe that your privacy has been compromised by any person in the course of using the Services, please contact Hola at: privacy@holaspark.com and our privacy officer shall promptly investigate.

© 2015 Hola Networks Limited. All Rights Reserved.