Last updated December 13, 2015
Hola Networks Limited ("Hola", "we" or "us") is the owner of the website
hola.org (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
This 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
from time to time and consent to the collection and use of information in the
Policy carefully and to periodically refer to it so that you understand it and
its subsequent changes if any. IF YOU DO NOT AGREE TO THE TERMS OF THIS
The definitions in the Hola End User License Agreement
apply to this Policy unless stated otherwise. IN ADDITION TO THIS POLICY,
PLEASE REVIEW OUR END USER LICENSE AGREEMENT, WHICH IS INCORPORATED HEREIN BY
REFERENCE, TOGETHER WITH SUCH OTHER POLICIES OF WHICH YOU MAY BE NOTIFIED OF BY
US FROM TIME TO TIME.
The Information We Collect
When you use the Services we collect the following types of data from you:
Anonymous Information; We collect Anonymous Information about your
use of the Services to allow us to provide the Services and constantly
improve them, for security reasons and 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, and it includes your approximate geo-location, 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 time stamps.We do not make any efforts to reveal your identity
through this information. We may also collect information that will help us
understand whether your device is used at a given moment so we will not
send it any requests.
Personal Information; is information that may be of a private or
sensitive nature, identifies or may identify you. The Personal Information
we collect and retain include your IP address, your name and email address
in case 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, then a Third Party Account pop-up box will appear which
you will need to approve in order to proceed, and which will describe the
types of information that we will obtain from. Such information includes
your Personal Information stored on this Third Party Account, such as user
name, email address, profile picture, birthday, gender and preferences. We
also treat any Anonymous Information which is specifically connected or
linked to any Personal Information, as long as such connection or linkage
exists, as Personal Information.
Other InformationAs part of the Services' nature and to enable
browsing acceleration, information which is publicly accessible by other
users that you have accessed may be accessed by those users from cached
copy of this data from your device; Please note that when you interact with
other websites and use Hola, such websites may collect information about
you. Hola has nothing to do with such website's data collection practices
and such practices will be governed by their own privacy policies.
What is the Purpose of 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.
In addition, our revenue model is designed so that the Services have 3rd party
services implemented inside them for providing analytical services. Your
Personal Information is collected for a few purposes. First, it enables us to
provide you with a better user experience and more relevant features,
capabilities, offers and marketing materials. In addition, it allows us to
provide you with technical assistance and support, and replying to questions
and concerns received from you.
How We Collect Your Information
In addition to the information provided by you (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, so the same website will be able to recognize
information and to recognize you when you are using the Services. We may also
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. Further, we use session ID cookies to enable certain
features of the Services, 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 any time whether to accept such cookies or not or to delete
existing cookies from 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 cookie to enable tracking activity on websites.
Web Beacon: A web beacon is technique used to track who is reading a
web page or email, when, and from which computer.
Log Data: Log Data is a data that is automatically recorded by our
servers when you use the Services. Log Data may include information about
your device such as your IP address, browser type, the webpages you visit,
the time spent on those pages, access times and dates, unique identifier that
was generated for your device (if you use the Services from your mobile
device then such identifier may be you mobile number). Such data is used by
us in its aggregated form and is not combined with any Personal Information.
With Whom Do We Share Information
We do not share your Personal Information with third parties except as
specifically consented by you pursuant to this Policy or if required by
applicable laws or court order.
We share Anonymous Information with third parties, when this is required in
order to provide, maintain or improve the Services. Such third parties may have
access to your information only to the extant needed to provide such services.
We may also share Anonymous Information with third parties for additional
purposes, including for marketing, research and analytics purposes.
We may also share your Personal Information and other information in special
cases if we have a 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)
you and us, including investigation of potential violations thereof; or (4)
protect against harm to the rights, property or safety of us, its partners, its
affiliates, users or the public.
We may share your email address, if we have collected it, with our marketing
partners and to 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
At any time, you can choose to no longer receive commercial or promotional
emails from us by clicking on the "unsubscribe" link at the bottom of each
email communication that we will send you. It may take up to 10 days for us to
process such 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 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.
The Services are not directed or intended for children under 13 years of age. We do not knowingly collect or solicit Personal Information from individuals under 13 years of age. If you
are under 13 years of age, you should not register or provide Personal Information through the Services. If we later obtain actual knowledge that a user is under 13 years of age, we will
take steps to remove that user's Personal Information from our systems. If you are the parent or guardian of a child whom you believe has disclosed Personal Information to us, please contact
us at email@example.com so that we may delete and remove such child's information from our systems.
If you believe that we might have any information from a child under age 13,
please contact us via email at firstname.lastname@example.org.
Security and Confidentiality
The collection and processing of Personal Information and Anonymous Information
is aimed at providing you with the Services offered by us and to send you
commercial information on products or services we think you may be interested
in. We will store this information as long as it is reasonably necessary to
attain the mentioned purposes and in accordance with any applicable legal or
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.
The measures and procedures that we employ 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, and we will take all measures to
investigate the incident and take preventive measures, as required.
We value your privacy and control over your personal information, and therefore
you may notify us that you wish to either review your Personal Information or
delete it. You can notify us by sending an email to email@example.com. At all
times you can choose not to allow us or any third party to collect data about
you, or ask to view or edit Personal Information that is stored about you. You
may also choose not to accept cookies, including cookies associated with our
visit Google's Ads
. However, you should take into account that many of the Services
or portion 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 written request and ask a list of Personal
Information categories that we may disclosed to third parties or to which we
may gave access to third parties, and the details of such third parties. To
exercise such right you may contact us at: firstname.lastname@example.org.
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 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.
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 in the Site. Your continued
use of the Services following any such changes will be considered as you
If you feel that your privacy was treated not in accordance with our 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: email@example.com and our
privacy officer shall investigate promptly.
Copyright (c) 2015 Hola Networks Limited. All Rights Reserved.