Privacy Statement

This privacy statement was last updated March 28, 2019

Holler Technologies, Inc. (“Holler” “we” “us” or “our”) provides development and data tools to messaging services and applications with messaging functionality (“Application”) through our website, mobile services, and software (our “Services”). Depending on the type of Service selected by the developer of the Application you are using, we may collect certain information about you.

You are probably reading this because an Application you downloaded uses our Services and directed you to read this Privacy Statement so you can understand how we collect, use and share information about you when you use the Application, our Services, or otherwise interact with us, as well as what your choices are regarding the collection, use and sharing of your information.

By using the Application, you are agreeing to this Privacy Statement If you do not agree, then do not use the Application. We may change this Privacy Statement from time to time. If we make changes, we will notify you by revising the date at the top of the statement and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you a notification). We encourage you to review the Privacy Statement whenever you access the Services or otherwise interact with us to stay informed about our information practices and the choices available to you.

This Privacy Statement does not apply to the practices of third parties that we do not own or control, including those of the developer of the Application you are using. We encourage you to carefully review the privacy policies of any third-party services you access.

Information You Provide to Us

We collect information that you provide directly to us. For example, we collect information when you participate in any interactive features of the Services including engaging with our website(s), fill out a form or other questionnaire, participate in a contest or promotion, communicate with us via third party social media sites, request customer or technical support or otherwise communicate with us. The types of information we may collect include your Advertising ID (as defined below), or, if you fill out a survey, your name, email address, mailing and billing address, Advertising ID, mobile phone number, and any other information you choose to provide.

Information We Collect From Other Sources:

We may also obtain information about you from other sources and combine that with information we collect through the Services. For example, if you access the Services through third party applications and services, we may collect information about you from such third parties.  

Information We Collect Automatically When You Use Our Services:

When you access or use the Services, we automatically collect information about you, including the following:

Information Collected by Cookies and Similar Tracking Technologies:  

We (and our service providers) use different technologies to collect information, including cookies and web beacons.  Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits.  Web beacons (also known as“pixel tags” or “clear GIFs”) are electronic images that may be used in ourServices or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, see YourChoices below. We use technologies such as SoftwareDevelopment Kits (SDKs) or Application Programming Interfaces (APIs) to collect information about you as described below. We use these technologies to recognize your device and to track your activities in the Services. These technologies work by storing a line of code in the Services that resides in your mobile device and synchronizes information back and forth between your mobile device and our servers. When you remove the Services from your mobile device, this line of code will also be removed. We may also collect information when you fill out a form, communicate with us via third-party social media sites or otherwise communicate with us.

Information We Collect from OtherSources

We may also obtain information about you from other sources.  For example, if you access the Services through a third-party messaging service or application, we may collect information about you from such third parties, including some of the types of information listed under “Information You Provide to Us” above, such as usage information, log information and location information.

Information We Derive

We may derive information or draw inferences from you based on the information we or our partners collect. For example, we may combine your Advertising ID with non-personally-identifiable information in order to allow us to uniquely identify your device for purposes of storing specific and aggregate usage preferences and data.

How Do We Use the Information Collected?

We use the information we collect to:

How the InformationCollected is Shared:

We will not share your information except in the following circumstances:

We may also share aggregated information that does not identify any specific user, device, or partner publicly or with third parties including developers, advertisers, potential partners, or researchers. For example, we may disclose statistics that a certain percentage of users of a certain genre of an application spend a certain number of hours in such application compared to other applications or statistics regarding engagement with an advertiser’s branded content.

Please see the section “Your Choices” to learn about your options in connection with the collection of information from you through cookies and other technologies.

Advertising and Analytics Services

We may, or we may allow others to, provide analytics services and serve advertisements on our behalf across theInternet and in mobile applications. We or these entities may use cookies, web beacons, device or advertising identifiers and other technologies to collect information about your use of the Services, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in applications, links clicked and conversion information. This information may be used by Holler and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices (or http://www.youronlinechoices.eu if you are a resident of the EEA).

Transfer of Information to the U.S. and Other Countries

We are based in the United States and we process and store information in the U.S. As such, we and our service providers may transfer your information to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction.We will take steps to ensure that your personal data receives an adequate level of protection in the jurisdictions in which we process it.

Your Choices

Deleting or Updating Your Information

You can delete your information or update it if it’s inaccurate or incomplete at any time. Contact us at privacy@holler.io with your, but note that we may retain certain information as required by law or for legitimate business purposes.

AdvertisingID

The method for finding and disabling yourAdvertising ID varies depending on the manufacturer of your mobile device. You may stop us from collecting further information for marketing and advertising purposes by disabling the AdvertisingID on your mobile device. For more information on how to manage the privacy settings in your mobile device see, for example: https://www.apple.com/privacy/manage-your-privacy/ for your iOS device. For Android devices, see “Limit Ad Tracking” in your device’s privacy settings. You may also contact the manufacturer of your mobile device for instructions about finding your Advertising ID or opting out from ad tracking.

Even if you disable the Advertising ID in your mobile device, keep in mind that you may still receive (i) content, including branded content, from use of our Services, provided that our content recommendations will not be personalized to you, (ii) interest based advertising, including from third parties to whom your Advertising ID had been previously disclosed and (iii) advertising from third parties, though such advertising may not be based on your interests and preferences. For any privacy or data-protection-related questions, please write to privacy@holler.io.

Cookies

Most web browsers are set to accept cookies by default.  If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.

Promotional Communications

You may opt out of receiving promotional emails from Holler by following the instructions in those emails or by following the instructions in those emails. If you opt out, we may still send you non-promotional emails, such as those about your use of the Services or our ongoing business relations.

MobilePush Notifications/Alerts

With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

Data Retention

We will retain your information until the earlier of (i) the information is no longer necessary to accomplish the purpose for which it was provided; or (ii) you ask that we delete your Advertising ID from our records, as described above. We may retain your information for longer periods to the extent that we are obliged to do so in accordance with applicable laws and regulations and/or we reasonably believe that retaining the information is necessary to protect our legal rights or legitimate business interests.

Your California Privacy Rights

Consumers residing in California are afforded certain additional rights with respect to their personal information under the California Consumer Privacy Act (CaliforniaCivil Code Section 1798.100 et seq.) (the “CCPA”).If you are a California resident, this section applies to you

California Consumer Privacy Act

Additional DisclosuresRelated to the Collection, Use, Disclosure of Personal Information

As used herein, "personal information" means any data or information that is personally identifiable or otherwise identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Holler customer or consumer or his or her household, as such definition may be updated from time to time pursuant to the CCPA.

 

Collection and Use of Personal Information: In the preceding 12 months, we have collected the following categories of personal information: identifiers,

commercial information, Internet or other electronic network activity information, geolocation data, inferences drawn about you, and other categories of personal information that relate to, describe or are reasonably capable of being associated with you. For examples of the precise data points we collect and the sources of such collection, please see “Collection ofInformation” above. We collect personal information for the business and commercial purposes described in “Use of Information” above.

 

Disclosure of Personal Information:We may share your personal information with third parties as described in the“Sharing of Information” section above. In the preceding 12 months, we have disclosed the following categories of personal information for business or commercial purposes: identifiers, Internet or other electronic network activity information, and geolocation data.

Sale of Personal Information: Holler does not sell the personal information of our users.

Your Consumer Rights

If you are aCalifornia resident, you have the right to request (1) more information about the categories and specific pieces of personal information we have collected, [sold] and disclosed for a business purpose in the last 12 months, (2) deletion of your personal information, and (3) to opt out of sales of your personal information, if applicable. You may make these requests by emailing us at privacy@holler.io. Once we receive your request, we will verify it by email at the address provided in the original request. If you would like to use an authorized agent registered with the California Secretary of State to exercise your rights, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit requests on your behalf. We will not discriminate against you if you exercise your rights under the CCPA.

Additional Disclosures for Individuals in Europe

If you are located in the European Economic Area or Switzerland, you have certain rights and protections under the law regarding the processing of your personal data.

1. Legal Basis for Processing

2. Data Subject Requests

You have the right to access personal data we hold about you and to ask that your personal data be corrected, erased, or transferred. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, you may contact us at privacy@holler.io with your Advertising ID

3. Questions or Complaints

If you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. For contact details of your local Data Protection Authority, please see http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm, or for Swiss residents, seehttps://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html.

Questions or Comments

We welcome questions and comments about this Privacy Statement. Questions or comments should be directed to privacy@holler.io.

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