At HOLY your privacy is important to us, so we strive to be transparent about how we collect, use and share information about you. This policy is intended to help you understand:
- WHAT INFORMATION WE COLLECT
- HOW WE USE INFORMATION
- HOW WE SHARE INFORMATION
- HOW WE STORE INFORMATION
- HOW TO ACCESS AND CONTROL YOUR INFORMATION
- HOW WE TRANSFER INFORMATION INTERNATIONALLY
- ADDITIONAL IMPORTANT PRIVACY MATTERS
1. WHAT INFORMATION WE COLLECT
Information You Share with Us
We require certain information to provide our services to you. For example, you must have an account in order to upload or share content on United Young. When you choose to share the information below with us, we collect and use it to operate our Services.
Account Information: When you use the Services, you will provide information that could be Personal Information, such as your name, relationship status, employment status, telephone number, email address, birthday and gender, the user that you invited to HOLY, who you invited to HOLY, when you joined HOLY and your HOLY member number. You acknowledge that this information may be personal to you, and by creating an account on the Services and providing Personal Information to us, you allow others, including us, to identify you and therefore may not be anonymous. We may use your contact information to send you information about our Services.
User Content: Some features of the Services allow you to post information to the Services. This information is public. Also, Information posted about you by other people who use our services may also be public. You are responsible for the information you provide through our services, and you should think carefully about what you post, especially if it is sensitive information.
Contact Information and Address Books: We use your contact information, such as your email address or phone number, to authenticate your account and keep it - and our Services - secure, and to help prevent spam, fraud, and abuse. We also use contact information to personalize our services, enable certain account features, and to send you information about our services. You can choose to upload and sync your address book on the Services so that we can help you find and connect with people you know and help others find and connect with you. We also use this information to better recommend content to you and others. If you email us, we will keep the content of your message, your email address, and your contact information to respond to your request.
Information We Collect Automatically
We automatically receive and record information from your use of the Services, including app usage, your IP address and cookie information. This information is used to optimize your user experience. Generally, the Services automatically collect usage information, such as the number and frequency of use of the Services. This type of data enables us and third parties authorized by us to figure out how often individuals use parts of the Services so that we can analyze and improve them.
Log Information: Like most online service providers, we collect information that web browsers, mobile devices, and servers typically make available, such as the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. We collect log information when you use our Services.
Usage Information: We collect information about your usage of our Services. We also collect information about what happens when you use our Services (e.g., when you edit your profile, upload a profile picture, send someone a message, search for someone on the app, send an invite to a friend, or view someone’s profile) along with information about your device (e.g., screen size, name of cellular network, and mobile device manufacturer). We use this information to, for example, provide our Services to you, as well as get insights on how people use our Services, so we can make our Services better.
Location Information: We may determine the approximate location of your device from your IP address. We collect and use this information to, for example, calculate how many people use our Services from certain geographic regions. We may also collect information about your precise location via our mobile apps (when, for example, you update your profile with our “Find my location” feature) if you allow us to do so through your mobile device operating system’s permissions.
Stored Information: We may access information stored on your mobile device via our mobile app. We access this stored information through your device operating system’s permissions. For example, if you give us permission to access the photographs on your mobile device’s camera roll, our Services may access the photos stored on your device when you when you upload a wonderful photo of you smiling to your profile.
2. HOW WE USE THE INFORMATION
While we consider the collection and processing of your information to be in our legitimate business interests we take into consideration your privacy rights. We use information about you for a number of purposes. Below are the specific purposes for which we use the information we collect about you.
To provide the Services and personalize your experience: We use information about you to provide the Services to you, including to process payment transactions with you, authenticate you when you log in, provide customer support, and operate and maintain the Services.
For research and development: We are always looking for ways to make our Services smarter, faster, more secure, integrated and useful to you. It is in our legitimate business interests to continue to maintain and improve Services. To that end, we use collective learnings about how people use our Services and feedback provided directly to us to troubleshoot and to identify trends, usage, activity patterns and areas for integration and improvement of the Services.
To communicate with you about the Services: We use your contact information to send transactional communications via email and within the Services, including confirming your purchases, reminding you of subscription expirations, responding to your comments, questions and requests, providing customer support, and sending you technical notices, updates, security alerts, and administrative messages. We send you information about Services you use because it is in our legitimate interest to do so.
To market, promote, and drive engagement with the Services: We use your contact information and information about how you use the Services to send promotional communications that may be of specific interest to you, including by email and by displaying ads on other companies' websites and applications, as well as on platforms like Facebook and Google. These communications are aimed at driving engagement and maximizing what you get out of the Services, including information about new features, survey requests, events and other information we think may be of interest to you. We also communicate with you about new product offers, promotions and contests.
Conducting surveys and collecting feedback about our Services: We do this to pursue our legitimate interests to understand if the Services are helpful to you and to evaluate the effectiveness of any updates we provide.
Customer support: We use your information to resolve technical issues you encounter, to respond to your requests for assistance, to analyze crash information, and to repair and improve the Services.
For safety and security: We use information about you and your Service use to verify accounts and activity, to monitor suspicious or fraudulent activity and to identify violations of Service policies.
To protect our legitimate business interests and legal rights: Where required by law, where we believe it is in our legitimate business interest, or where it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger or sale of a business.
With your consent: We use information about you where you have given us consent to do so for a specific purpose not listed above. For example, we may publish testimonials or featured customer stories to promote the Services, with your permission.
Additional purposes: We may process your information for any other purpose disclosed to you in connection with our Services from time to time. If we intend to process your personal data for a purpose other than that set out above, we will provide you with information prior to such processing and will obtain your consent where necessary.
Legal bases for processing (for EEA users): If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable EU laws. The legal bases depend on the Services you use and how you use them. This means we collect and use your information only where:
- We need it to provide you the Services, including to operate the Services, provide customer support and personalized features and to protect the safety and security of the Services;
- It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services and to protect our legal rights and interests;
- You give us consent to do so for a specific purpose; or
- We need to process your data to comply with a legal obligation.
If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the Services.
3. HOW WE SHARE INFORMATION
The Services are designed to help you share information with others. As a result, some of the information generated through the Services is shared publicly or with third parties.
Usage Information: We share Usage Information with our partners, service providers and other persons with whom we conduct business. We share this type of data so that our partners can understand how and how often people use our Services and their services or websites, which facilitates improving both their services and how our Services interface with them. In addition, these third parties may share with us non-private, non Personal Information about you that they have independently developed or acquired.
Communications with Us: As part of the Services, you may occasionally receive text, email and other communications from us, such as communications relating to your Account. In the event that we communicate with you through text, standard messaging rates apply.
User Profile Information: User profile information including your name and other information you enter may be displayed to other users to facilitate user interaction within the Services. We will not directly reveal user email addresses to other users.
Third Party Vendors: We may share information about you with third party vendors who need to know information about you in order to provide their services to us, or to provide their services to you or your site. This group includes vendors that help us provide our Services to you (like payment providers that process your credit and debit card information, fraud prevention services that allow us to analyze fraudulent payment transactions, postal and email delivery services that help us stay in touch with you, customer chat and email support services that help us communicate with you, those that assist us with our marketing efforts (e.g. by providing tools for identifying a specific marketing target group or improving our marketing campaigns), those that help us understand and enhance our Services (like analytics providers), who may need information about you in order to, for example, provide technical or other support services to you. We require vendors to agree to privacy commitments in order to share information with them.
Information Disclosed Pursuant to Business Transfers: In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this policy.
Information We Share With Your Consent: Except as set forth above, you will be notified when your Personal Information may be shared with third parties, and will be able to prevent the sharing of this information.
4. HOW WE STORE AND SECURE INFORMATION
Keeping your information secure is a top priority for us. To that end we comply with industry-standard best practices to secure your information. We use data hosting service providers in the United States to host the information we collect, and we use technical measures to secure your data. While we implement safeguards designed to protect your information, no security system is impenetrable and due to the inherent nature of the Internet, we cannot guarantee that data, during transmission through the Internet or while stored on our systems or otherwise in our care, is absolutely safe from intrusion by others. How long we keep information we collect about you depends on the type of information, as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.
Account Information: We retain your account information. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations and to continue to develop and improve our Services. Where we retain information for Service improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyze personal characteristics about you.
Information You Share on the Services: If your account is deactivated or disabled, some of your information and the content you have provided will remain.
Marketing information: If you have elected to receive marketing emails from us, we retain information about your marketing preferences unless you specifically ask us to delete such information. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
5. HOW TO ACCESS AND CONTROL YOUR INFORMATION
You have the right to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion or restriction of your information, or to request your information in a structured, electronic format. Below, we describe the tools and processes for making these requests. You can exercise some of the choices by logging into the Services and using settings available within the Services or your account. For all other requests, you may contact us as provided in the Contact Us section below to request assistance.
Your request and choices may be limited in certain cases: for example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we are permitted by law or have compelling legitimate interests to keep. Where you have asked us to share data with third parties, you will need to contact those third-party service providers directly to have your information deleted or otherwise restricted. If you have unresolved concerns, you may have the right to complain to a data protection authority in the country where you live, where you work or where you feel your rights were infringed.
Access and Update Your Information: Our Services and related documentation give you the ability to access and update certain information about you from within the Service. You can update your profile information within your profile settings and modify content that contains information about you using the editing tools associated with that content.
Deactivate Membership: You can deactivate your access the Services at any time.
Delete Your Information: Our Services and related documentation give you the ability to delete certain information about you from within the Service. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations.
Request That We Stop Using Your Information: In some cases, you may ask us to stop accessing, storing, using and otherwise processing your information where you believe we don't have the appropriate rights to do so. For example, if you believe a Services account was created for you without your permission or you are no longer an active user, you can request that we delete your account as provided in this policy. Where you gave us consent to use your information for a limited purpose, you can contact us to withdraw that consent, but this will not affect any processing that has already taken place at the time. You can also opt-out of our use of your information for marketing purposes by contacting us, as provided below. When you make such requests, we may need time to investigate and facilitate your request. If there is a delay or dispute as to whether we have the right to continue using your information, we will restrict any further use of your information until the request is honored or the dispute is resolved. If you object to information about you being shared with a third-party app, please disable the app.
Opt Out of Communications: You may opt out of receiving promotional communications from us by using the unsubscribe link within each email, updating your email preferences within your Service account settings menu, or by contacting us as provided below to have your contact information removed from our promotional email list or registration database.
Send "Do Not Track" Signals: Some browsers have incorporated "Do Not Track" (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. We 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.
Data portability: Data portability is the ability to obtain some of your information in a format you can move from one service provider to another (for instance, when you transfer your mobile phone number to another carrier). Depending on the context, this applies to some of your information, but not to all of your information. Should you request it, we will provide you with an electronic file of your basic account information and the information you create on the spaces under your sole control.
6. HOW WE TRANSFER DATA INTERNATIONALLY
To bring you our services, we operate globally. Where the laws of your country allow you to do so, you authorize us to transfer, store, and use your data in the United States. In some of the countries to which we transfer personal data, the privacy and data protection laws and rules regarding when government authorities may access data may vary from those of your country.
When we transfer personal data outside of the European Union or EFTA States, we ensure an adequate level of protection for the rights of data subjects based on the adequacy of the receiving country’s data protection laws, contractual obligations placed on the recipient of the data (model clauses may be requested by inquiry as described below), or EU-US and Swiss-US Privacy Shield principles.
We comply with the EU-US and Swiss-US Privacy Shield principles (the “Principles”) regarding the collection, use, sharing, and retention of personal data from the European Union and Switzerland.
Privacy Shield participants are subject to the investigatory and enforcement powers of the US Federal Trade Commission and other authorized statutory bodies. Under certain circumstances, participants may be liable for the transfer of personal data from the EU or Switzerland to third parties outside the EU and Switzerland.
7. ADDITIONAL IMPORTANT PRIVACY MATTERS
Minimum Age: The Services are not directed to individuals under 18. We do not knowingly collect personal information from children under 18. If we become aware that a child under 18 has provided us with personal information, we will take steps to delete such information. If you become aware that a child has provided us with personal information, please contact our support services.
8. CONTACT US
Contacting us: If you have any questions, please don’t hesitate to contact us at:
Attn: Data Protection Officer
31 Hudson Yards Fl 11
New York, NY 10001
Please include your name, address, and/or email address when you contact us.
Effective Date: July 24, 2018