What is the difference between a data controller and a data processor?
A controller is the entity that determines the purposes, conditions and means of the processing of personal data, while the processor is an entity which processes personal data on behalf of the controller.
Hologo is a data processor acting on behalf of educational institutions -- who are the data controllers and have determined the means and the purpose of the processing of the data -- for any personal data provided by users of our iOS apps.
Personal data entered into the Hologo app apart from the email and name is inaccessible by Hologo and is only being processed for the functioning of the app.
Where does Hologo store my data? Is my data transferred internationally?
While Hologo is owned and operated in the United States of America, data is stored in secure servers using Amazon Web Services (AWS). Amazon is ISO 27001, 27017, and 27018 certified.
There is no obligation under the GDPR for personal data to be stored in the EU, and it's permissible for the data to be transferred internationally as long as it is adequately protected.
AWS's primary data storage is in the US and all Hologo account information is solely stored in the US. AWS has temporary backup servers located in Canada, Australia, South America (San Paolo, Brazil), and Asia (Mumbai, India; Seoul, South Korea; Singapore; and Tokyo, Japan) where non personally-identifiable assignment data could be stored.
The Standard Contractual Clauses will be employed for any transfer of personal data by AWS or any of its sub-processors to South America, Asia, or Australia.
If you have questions about the storage or transfer of Hologo's data, please contact firstname.lastname@example.org.
Who Hologo shares your data with
Hologo will never sell your personal data to third parties and does not engage in any personal predictive profiling.
To support the delivery of our services, to provide customer support, and for the delivery of notifications, Hologo engages with carefully selected data sub-processors. These sub-processors have access to certain customer data in order to perform their tasks. Prior to engaging any third party, Hologo performs due diligence to assess their privacy, security, and confidentiality practices. These companies are all confirmed GDPR compliant.
Hologo's current sub-processors, their location, and the services they provide are as follows:
Amazon Web Services: Database hosting and data transfer (USA)
OneSignal: Delivery of notifications. (USA)
Google: Website analytics (USA)
MailGun: To deliver product and user related mails. (USA)
Stripe: Payment processing in the website (USA)
If you have questions about the third party sub-processors who have access to your personal data, please contact us at email@example.com
How does Hologo validate a user before making changes to their personal information?
All Hologo access requires a dedicated user account. The user access is protected by a unique login and password. Passwords are hashed and never stored as plain text in our database.
Hologo users are able to change their their full name and password from within Hologo. Unique identifying usernames (i.e. those that are school-issued) need to be changed by a member of our support team (firstname.lastname@example.org).
Before Hologo's Support team will make changes to a user's account, a series of questions will be required in order to verify the user's identity.
Note that teachers and admins can request changes to accounts, including changes to students' accounts, but we will not make changes that are requested directly from students or parents.
What security measures does Hologo's database have in place?
We strive to ensure the highest level of security for our users and follow industry-wide best standards for data management and encryption. Any personal information entered into the Hologo iOS is anonymized and only being processed for the functioning of the App.
All Hologo access requires a dedicated user account. The user access is protected by a unique login and password. Passwords are hashed and never stored as plain text in our database.
We’ve taken the following actions to secure our database:
- Encryption of our entire database.
- Encryption of the internal transmission of data between the database and core services.
- Access of the database is restricted internally to two senior members of our data services team. Access by these two members requires a separate private access key.
The security of personal data is of utmost importance to Hologo. If you have questions related to our data management practices, please send them to email@example.com
Legal basis for processing personal data
Under the GDPR, data processors and controllers are required to demonstrate that all processing activities have a valid legal basis. There are six bases for processing data:
- The data subject provides valid consent;
- Processing is necessary for entering into or the performance of a contract;
- Processing is necessary for compliance with a legal obligationwhich the controller is subject;
- Processing is necessary in order to protect the vital interests of the data subject or other individual;
- Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested;
- Processing is necessary for the purposes of the legitimate interests pursued by the controller or third party, to the extent that it does not infringe on the fundamental rights and freedoms of the data subject, particularly where the data subject is a child.
Understanding the correct lawful ground for all processing activity is an essential element of GDPR compliance. As a data processor processing personal data on behalf of data controllers (educational institutions) Hologo does not need to rely on consent for its processing, but must have a legal basis attributed to this processing.
If you have any questions about Hologo's legal basis for processing information, please contact firstname.lastname@example.org
What does 'personal data' mean?
Personal data is any information about a person or 'data subject' that can be used to directly or indirectly identify the person. This can include information such as their name, email address, computer IP address or a photo.
Parental consent is required to process personal data for children under the age of 16.
Your right to access your data
As a data subject, you have the right to access information from your data controller in a commonly-used, electronic format, free of charge, within a reasonable timeframe.
Requests to access data can be made directly to your educational institution (the data controller), or via emailing Hologo on email@example.com
Note that requests must be made by a school teacher or administrator; Hologo will not accept data access requests from parents or students.
Your right to rectification of your data
Individuals have the right to have their data controller rectify inaccurate personal data
Requests to rectify inaccurate data can be made directly to your educational institution (the data controller), or via emailing Hologo on firstname.lastname@example.org
You can only change your personal data (profile name, email address) in Hologo by deleting your existing profile and creating a new profile. You can do this by requesting to Hologo on email@example.com
Your right to erasure of your data
Individuals have the right to obtain from the controller the erasure of personal data.
Requests to delete your data can be made directly to your educational institution (the data controller), or via emailing Hologo on firstname.lastname@example.org. Once your request has been verified, all third party subprocessors will be informed.
Requests must be made by a school teacher or administrator; Hologo will not accept data access requests from parents or students.
Note that if you are a teacher with active Hologo lessons and classes will be permanently deleted upon deletion of your account, and unable to be retrieved.
Your right to object data processing
Individuals have the right to object to the processing of personal data, including usage for profiling, direct marketing.
Requests to object the processing of your data for non-marketing purposes can be made directly to your educational institution (the data controller), or via emailing Hologo on email@example.com
Note that requests must be made by a school teacher or administrator; Hologo will not accept data access requests from parents or students.
Requests to object the processing of your data for marketing purposes can also be made through the form or by emailing on firstname.lastname@example.org.
Once your request has been verified, all third party subprocessors will be informed.
Your right to restrict the processing of your data
Individuals have the right to restrict processing of their data where:
- The accuracy of their data is contested;
- The processing is unlawful and the data subject opposed erasure of their personal data;
- The controller no longer needs the personal data, but is required to store it; or
- The data subject otherwise objects to the processing.
Requests to restrict the processing of your data can be made directly to your educational institution (the data controller), or via emailing Hologo on email@example.com
Note that requests must be made by a school teacher or administrator; Hologo will not accept data access requests from parents or students. Once your request has been verified, all third party subprocessors will be informed.
Data subjects will be notified prior to lifting the restriction on processing.
Data profiling and automatic processing
Data profiling is defined as any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person's performance at work, economic situation, health, personal preference, interests, reliability, behaviour, location, or Hologo does not engage in any automated decision making.
Your right to data portability and transfer
Individuals have the right to receive their personal data which they’ve provided to a controller in a commonly-used, readable, electronic format and also the right to transmit this data to another controller. Requests to transfer your data can be made directly to your educational institution (the data controller), or via Hologo (the data processor) emailing Hologo on firstname.lastname@example.org.
Note that requests must be made by a school teacher or administrator; Hologo will not accept data access requests from parents or students.
How can Hologo users unsubscribe from non-business critical communications?
Note: if you subscribe erroneously and would like to re-subscribe, by emailing Hologo.
How will I be informed if there's a data breach?
Hologo has been processing data records since April 2018 and has never had a data breach. In the unlikely event that a breach resulting in a risk to the rights and freedoms of personal data subjects Hologo users were to occur in the future, data controllers to whom the data subjects belong would be notified within 24 hours of Hologo learning of the breach and provided with detailed information as outlined in the GDPR. Hologo would then collaborate with the data controller(s) to ensure impacted users are notified in a timely manner.
What is a cookie?
Cookies are small text files sent by us to your computer or mobile device. They are unique to your account or your browser. Session-based cookies last only while your browser is open and are automatically deleted when you close your browser. Persistent cookies last until you or your browser delete them or until they expire.
How is Hologo using cookies?
Some cookies are associated with your account and personal information in order to remember that you are logged in and which workspaces you are logged into. Other cookies are not tied to your account but are unique and allow us to carry out analytics and customization, among other similar things.
Cookies can be used to recognize you when you visit a Site or use our Services, remember your preferences, and give you a personalized experience that’s consistent with your settings. Cookies also make your interactions faster and more secure.
If you're signed in to our Services, cookies help us show you the right information and personalize your experience.
Analytics and Research
How are cookies used for advertising purposes?
Cookies help us market more effectively to users that we and our partners believe may be interested in Hologo. They also help provide us with aggregated auditing, research, and reporting, and know when content has been shown to you.
What can you do if you don't want cookies to be set or want them to be removed, or if you want to opt out of interest-based targeting?
Some people prefer not to allow cookies, which is why most browsers give you the ability to manage cookies to suit you. In some browsers you can set up rules to manage cookies on a site-by-site basis, giving you more fine-grained control over your privacy. What this means is that you can disallow cookies from all sites except those that you trust.
If you limit the ability of websites and applications to set cookies, you may worsen your overall user experience and/or lose the ability to access the services, since it will no longer be personalized to you. It may also stop you from saving customized settings, like login information.
1.1 “Application” means any web-based or mobile application provided by Hologo, as part of the Services.
1.2 “Authorized Users” s defined in Section 2.2.
1.3 “Student Codes” are codes issued by Hologo to provide access to Authorized Users.
1.4 “Personal Information” means information about an identifiable individual, but excludes business contact information.
1.5 “Qualifying Educational Institution” means a preschool, K-12 school or post-secondary institution.
1.6 “Services” means Services provided by Hologo in connection with the website and Application, including services of data upload, download, hosting and syncing through Hologo’s servers or third-party data hosting services selected by Hologo.
1.7 “Website” means the Hologo IOS App and site through which Hologo provides Services.
2.1 Account. Access to certain functionality and Services requires a valid account from Hologo and is subject to payment of the applicable license fee(s). Some features may be available on a trial basis to qualified users, as set forth below. You are responsible for maintaining the confidentiality of your account information, password and login, including logins distributed to Authorized Users. You are responsible for all uses of your account. You agree to immediately notify Hologo of any unauthorized use of your account.
A limited use trial account (i.e. free account) permits use of the website and Services by individual teachers for themselves and their students within Qualifying Educational Institutions. If You are not an active teacher or instructor, but would like to try Hologo, please contact email@example.com to discuss our trial options. If You are an active teacher or instructor, but do not belong to a Qualifying Educational Institution, please contact firstname.lastname@example.org to discuss our trial options.
2.2 Fees. Hologo will invoice for all chargeable Services and timely payment must be made for access to the Services. Upon notice to You, Hologo reserves the right to change its price list for certain Services and to institute new charges at any time, which may be sent by email or posted on the website. If You continue to use those Services after such notification, that use constitutes your consenting to the new or increased charges. This Agreement does not include the provision by Hologo of any upgrades, updates, consulting services, customization or training. Such additional services may be available through separate agreements with Hologo.
2.3 Educational Users. The website and Services are designed for use by students, educators and parents/legal guardians in Qualifying Educational Institutions. Representatives of a school board, educational institution or teachers in Qualifying Educational Institutions will only grant Student Codes to (i) students who are currently enrolled and (in the case of minor students) who have been given permission by a parent/legal guardian, and (ii) parents/legal guardians of such minor students (collectively “Authorized Users”). As a representative of a school board, educational institution or as a teacher in a Qualifying Educational Institution, You represent and warrant that: You have permission from your school board or educational institution to enter into this Agreement and to use the Services as part of your curriculum; You are over the age of majority; and you are entering this Agreement on behalf of your school board or educational institution; and You have authority to bind such entity to the terms of this Agreement.
2.4 Student Users. The website and Services are also designed for use by student users at a Qualifying Educational Institution. Minor students agree that they have obtained consent from a parent/legal guardian for their use of the website and Services in connection with educational uses. By using the website and Services, if You are a minor, You represent that you have obtained consent from your parent/legal guardian who has read and agrees to this Agreement on your behalf. If you do not obtain such consent, then You are not authorized to use the website or Services.
2.5 Other User Restrictions. If You are accessing the Services as a publisher, You acknowledge and agree that the content you contribute to the Services as a publisher will be considered to be under Section 3.0 of this Agreement.
2.6 Parent Users. The website and Services are also designed for use by parents/legal guardians as Authorized Users in connection with a Qualifying Educational Institution. If You are a parent/legal guardian accessing the website and Services, You agree that you will only use the website and Services as access is permitted to you under this Agreement, in connection with educational uses.
You understand that your acceptance of this Agreement indicates that You agree to these terms both on your own behalf, and on the behalf of your child who uses the website. Minor students cannot use the website and Services without a parent/legal guardian first accepting this Agreement on their behalf.
2.7 Intellectual Property. Hologo and its third-party licensors own any and all intellectual property rights and all right, title and interest in and to the Website (including free, public or beta portions of the Website), Services, the Application and any desktop interface or documentation which accompanies or interfaces with the Website or Application. Subject to your payment of all applicable fees and these Terms, Hologo grants you a limited, non-exclusive license to download the Application and use the Services for your personal and/or educational purposes.
2.8 Trial Period, Public or Beta Usage. Any free, trial, public or beta portions of the website or Services are still subject to these terms, and in respect of those free, trial, public or beta portions of the website, You bear the entire risk of use; such portions of the website or Services may be changed, suspended, blocked by Hologo at any time without notice to You.
2.9 Third-Party Content. From time to time, we may make certain third-party content available on the website or Application, such as educational content or lesson plans.
(a) Some third-party content may be made available as a free download or as part of a free update for non-commercial use under Creative Commons or open-source license terms, and this type of content is not part of our chargeable Services. We do not charge any fee for the use of such third-party content, even though You may pay separately for other services or content from us.
(b) Other third-party content may be part of a paid download or upgrade, or made available as part of our chargeable Services. In both cases (chargeable and non-commercial content) this third-party content remains the property of the third-party owners or licensors, and we do not claim to own this third-party content. If any license terms apply to the third-party content, we will make those license terms (or appropriate links or references) available to You. You agree to abide by any applicable license terms.
3.0 User Content
3.1 User Content. The Services permit You to organize, upload and download content (including documents, images, and various digital content) through the Hologo servers. You represent and warrant that (a) You own or have all valid rights to such content that You organize, upload or download through the Services including any Personal Information; and (b) such content will not infringe or breach any third-party rights including privacy rights. You are solely responsible for any content or data that You organize, upload or download through the Services, including any consequences of making it available in connection with your use of the Services. If You provide access to your content to others, they may copy it, modify it or re-distribute it. Please consider carefully what You choose to share through the Services. Hologo has no responsibility for the activities of others.
3.2 User Postings. You hereby grant each user of the Services a non-exclusive license to access the content that you upload that you may input through the Services, and to distribute and display such content in compliance with the terms of this Agreement. Furthermore, You acknowledge and agree that, with your permission, Hologo also retains the right to distribute and display any such content. We do not claim any ownership rights to your content, and nothing in this Agreement will be deemed to restrict any rights that You may have to use and exploit your content.
3.3 Monitoring & Take-Down. Hologo does not monitor or screen your content nor does it claim any interest or ownership in such content. However, Hologo reserves the right to suspend, block or remove any user content from the Services at any time, for any reason (including, but not limited to, receipt of third-party claims or allegations relating to such content or breach of this agreement or any other agreement with Hologo by You or Authorized Users).
3.4 Archiving & Security. You are responsible for archiving and data back-up for your own purposes. You are responsible for security and encryption of any confidential or sensitive content or data.
4.0 Personal Information
4.2 Confidentiality. All data and content organized, uploaded and download by You through the device is resident on the device until deleted by You. Hologo does not collect or retain any user-generated content or any uploads or downloads by You through the Services.
4.3 Collection of User Information. Hologo collects limited Personal Information from administrative personnel at the school board, educational institution or teachers who have contracted with Hologo, only as needed for the operation and management of the Services and as needed for account administration, including communicating with users and designated third-party service providers as required for account administration.
4.4 Collection of Student Information. Hologo collects limited Personal Information from minor students, only as needed for the operation and management of the Services, and only where that student’s school board, educational institution or teacher has contracted with Hologo to do so. We first require the school board, educational institution or teacher to obtain the consent of parents/legal guardians prior to collecting such information. Minor student, cannot send any Personal Information about yourself or other students to Hologo, other than what is requested upon signing up for the Services. In the event that we discover we have the Personal Information of a student without consent of a parent/legal guardian, or information in excess of what we request upon sign-up, we will permanently destroy that information as quickly as possible. If you believe a student may have provided us Personal Information without consent of a parent/legal guardian, or information in excess of what we request upon sign-up, please contact us at email@example.com
4.5 Data Processing Agreement. If you are the school board, educational institution or teacher who is the primary contracting party with us and your students or other users are residents of the European Economic Area, you may be required to enter into a Data Processing Agreement with Hologo in order to use the Services.
5.1 Restrictions You shall not, and shall not authorize any third-party to:
(a) make copies of the website;
(b) modify, decompile, disassemble, translate into another computer language, create derivative works, access the source code, hack, decrypt, rename files, or otherwise reverse engineer the website;
(c) permit use of the Application or Services by anyone other than Authorized Users;
(d) use any Student Codes or other access codes, other than the ones assigned by the school board, educational institution or teacher;
(e) distribute Student Codes or other access codes to third-parties, or permit any third-party to use the Services other than Authorized Users;
(f) incorporate any portion of the website or Services into any products which will be sold, licensed or transferred to a third-party;
(g) distribute, sell, lease, transfer, assign, trade, rent, lease, lend or publish the website or license, sublicense or cross-license it or any part thereof and/ or copies thereof to others;
(h) use the Services to upload, post or otherwise transmit any materials that are harmful, fraudulent, threatening, abusive, harassing, tortious, defamatory, vulgar, profane, pornographic, obscene, libelous, offensive, or otherwise objectionable; or that promote discrimination, bigotry, racism, hatred, harassment or harm against an individual or group; or that promote illegal or harmful activities or substances; or that have the effect of harassing or stalking any person, or otherwise offend the acceptable use standards set by Hologo;
(i) upload, post or otherwise transmit any content through the Services that (i) would negatively affect the functioning of the system, including without limitation any harmful, disruptive or destructive files or computer programs or (ii) would impose an unreasonable or disproportionately large load on this system’s infrastructure;
(j) use the Services or any part thereof in violation of any law or regulation, or for any purpose other than as expressly permitted in this Agreement;
(k) distribute screen shots of the website without Hologo’s approval.
5.2 Acceptable Use: The Services may be used only for authorized purposes by users who have agreed to this Agreement. You must also abide by our acceptable use standards, and any acceptable use policy published by us from time to time. You may not:
(a) use the output of the Services for any purpose other than as required in connection with your personal, non-commercial use;
(b) engage in linking or framing of any portion of our website;
(c) aggregate, scrape, harvest or duplicate any portion of our website, including any personal or contact information, or use such personal or contact information for any secondary marketing purposes or unsolicited mass e-mail, or any purpose inconsistent with the purposes of the Services;
(d) corrupt, falsify or distort any content on the website.
5.3 Circumvention Prohibited. You specifically agree not to, in any way access (or attempt to access) a third-party database by any unauthorized or automated means, other than through the servers and interface that is provided by Hologo through the website.
6.0 Limitation of Liability & Disclaimer of Warranty
6.1 Disclaimer. The Website and Services are provided “AS IS” without warranties, conditions or representations of any kind, and Hologo expressly disclaims, to the fullest extent permitted by applicable law, any warranty or condition, express or implied, statutory or otherwise, whether arising from trade or course of dealing, including, without limitation, any warranty or condition that the Website and Services (a) shall correspond with a particular description, (b) are of merchantable quality, (c) are fit for your particular purpose, (d) are durable for a reasonable period of time, (e) do not and will not infringe any patent, trade-mark, trade-secret or other intellectual property or other proprietary rights of any third party, (f) are bug or error free, or (g) are accessible through all devices. You acknowledge that entry, conversion and storage of data is subject to human and machine error and Hologo is not responsible for such errors. Hologo is not responsible for third-party hardware or software, or for cell, wi-fi or other service providers. Hologo does not warrant that the website will be compatible with all platforms which may now or in the future be used.
6.2 Allocation of Risk. Hologo shall not be liable for any monetary damages whatsoever with respect to your use of the website and Services hereunder (or use by Your Authorized Users), nor shall Hologo be liable for any indirect, incidental, consequential, special, punitive or exemplary damages arising out of this Agreement, even if Hologo is advised of the possibility of such damages. The entire risk as to the results and performance of the website and Services is assumed by You and You agree to implement and adopt reasonable measures to examine and confirm results prior to use, to save data, and limit exposure to errors and failures in data.
6.3 Limitation of Liability. The total liability of Hologo, whether under the express or implied terms of this Agreement, in tort (including negligence or other duty of care) or at common law, for any loss or damage including but not limited to any data loss or corruption, suffered by You or any Authorized Users or third-parties, whether direct, indirect or special, or any other similar damage that may arise or does arise from use of the website and Services or any breach of this Agreement by Hologo, shall in no event exceed the amount paid by You to Hologo for the Services. These limitations of liability shall survive failure of any exclusive remedies provided in the agreement.
7.1 Indemnity. You indemnify, hold harmless and defend Hologo against any and all third-party claims (including all associated legal fees and disbursements actually incurred) against Hologo arising out of a breach by You of the obligations under this Agreement, or the use or misuse of the website or Services by You (or your Authorized Users).
8.0 Term & Termination
8.1 Termination Rights. (a) By Us: In the event You breach this Agreement or any other agreement with us, and such breach is not remedied or cured within 10 days of written notice, Hologo may suspend or terminate this Agreement and your access to the website and Services. If your employer, school board or educational institution under which You access the website and Services is in breach of any agreement with us, or the subscription term has expired, we may suspend or terminate this Agreement and your access to the Services. (b) By You: You may shut down your account and cease use of the Services at any time. We require reasonable written notice from You, to implement our standard security and data-handling policies. You are responsible for backing-up, saving, downloading or deleting any of your content and Personal Information, as You wish, prior to the termination of your account. After termination, we reserve the right to delete any content or Personal Information remaining on our servers. (c) By Your Employer/School Board/Educational Institution: Your employer, school board or educational institution may shut down or suspend your account access as part of their management of the relationship with You or in the event of termination or expiry of your employment or enrolment.
9.0 Governing Law & Disputes
9.1 Governing Law. This Agreement is governed by the laws of the State of Delaware, United States of America without regard to its conflict of laws rules.
9.2 Arbitration Agreement. You agree that all disputes arising out of or in connection with this Agreement, or in respect of any legal relationship associated with or derived from this Agreement, shall be arbitrated and finally resolved, pursuant to the Arbitration Rules of the State of Delaware, United States of America. The place of arbitration shall be State of Delaware, United States of America. The language of the arbitration shall be English. Arbitration fees and reasonable attorneys’ fees of both parties to be borne by the party that ultimately loses. The award rendered by the arbitrator shall be final and binding, and judgment may be entered upon it in any court having jurisdiction thereof.
9.3 Exception from Arbitration Agreement: Either party may obtain injunctive relief (preliminary or permanent) and orders to compel arbitration or enforce arbitral awards in any court of competent jurisdiction.
10.0 General Terms
10.1 Assignment. You will not assign, transfer, encumber or otherwise dispose of any or all of the rights granted to You under this Agreement without the prior written consent of Hologo. Hologo may assign this Agreement to a third-party.
10.2 Enurement. Subject to the limitations in this Agreement, this Agreement operates for the benefit of and is binding on the parties and their respective successors and permitted assigns.
10.3 No Waiver. No condoning, excusing or overlooking by any party of any default, breach or non‑observance by any other party at any time regarding any terms of this Agreement operates as a waiver of that party’s rights under this Agreement. No exercise of a specific right or remedy by any party precludes it from or prejudices it in exercising another right or pursuing another remedy or maintaining an action to which it may otherwise be entitled either at law or in equity.
10.4 Survival. All terms which require performance by the parties after the expiry or termination of this Agreement, will remain in force despite this Agreement’s expiry or termination for any reason. The following terms shall survive termination: 2.7, 5.0, 6.0, 7.0 and 9.0.
10.5 Severability. Part or all of any section that is indefinite, invalid, illegal or otherwise voidable or unenforceable may be severed and the balance of this Agreement will continue in full force and effect.
10.6 Entire Agreement. The Agreement and any mobile app terms set forth the entire understanding between the parties related to the website and Services, and replaces all prior versions.
10.7 Software & Hardware. You must provide your own computer hardware and software necessary to connect to the Services, including internet access and if applicable, a suitable mobile device, according to the optimal use standards and specifications we stipulate from time to time. The Services may experience temporary downtime as we perform routine maintenance or updates.
10.8 Linked Sites. Links available on the website may link to third-party websites not maintained or controlled by us and we provide these links for your convenience, and Hologo is not responsible for the contents of any linked site.
10.9 Changes. On release of any update or upgrade to the Website or Services, Hologo reserves the right to modify this Agreement and to impose new or additional terms or conditions on your use of the Website or Services. The then-current terms (including any modifications and additional terms and conditions if applicable) will be presented to You and will be effective immediately upon your acceptance of the terms and continued use of the Website or Services.
10.10 Language. It is the express will of the parties that this Agreement and all related documents be drawn up in English.
10.11 Electronic Acceptance. This Agreement may be agreed to by electronic acceptance.
10.12 Contact. If You have questions about these terms or wish to contact Hologo for any reason, please contact us at: Hologo World Inc., Email firstname.lastname@example.org
1. Our Privacy Pledge
In this Policy Personal Information” means personal information about an identifiable individual and information which can be used to identify an individual.
Hologo complies with the EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Information. Please refer to Addendum 1.1 of this policy for more information regarding EU Privacy Shield and Swiss-U.S. Privacy Shield Certification.
For residents of the European Economic Area, Hologo generally processes Personal Information in order to fulfill contracts we have with our customers and Users and to pursue our legitimate business interests listed above. Otherwise, Hologo will obtain consent from a Data Subject in respect of processing of Personal Information if required by law to do so.
By using our Services and supplying information to us, or by using the Hologo Application, you consent to the collection, use and disclosure of your Personal Information by us for the purpose of providing Services to you via the Hologo Application, and administering your account in accordance with: (a) this Policy, (b) any other agreement you may have entered into with us, and (c) applicable laws and regulations. It is your responsibility to ensure that we are kept informed of the correct and current contact information for you.
3. Single Sign-On
Hologo may allow users to be able to log in to our Services using certain specified third-party accounts such as Google. We may add other third-party sign-on functionality from time to time. By signing on in this way, you consent to the use of certain information to authenticate your identity, and you consent to share certain Personal Information with us (such as name, profile picture (if available) and email address) to pre-populate your profile. We safeguard this information the same way as any Personal Information collected by us through the Services, as outlined in this Policy.
Some third-party services give you the option to post or share information about your use of the services to your third-party account. The settings for that kind of sharing are outside of our Services. It’s up to you to check the sharing and privacy settings on your third-party account.
4. Collection of User Information
Hologo collects limited Personal Information from administrative personnel at the school board, educational institution, school, teachers or other organization that has contracted with Hologo, only as needed for the operation and management of the Services provided by Hologo and as needed for account administration, including communicating with users and designated third-party service providers as required for account administration.
5. Collection of Student Information
(a) Hologo collects limited Personal Information from minor students, only as needed for the operation and management of the services provided by Hologo, and only where that student’s school board, educational institution or teacher has contracted with Hologo to do so. In particular, Hologo collects names and usernames. This profile information collected allows students to interact with other teachers, students and other users from their school or institution as more particularly described below.
We first require the school board, educational institution or teacher to obtain the consent of parents/legal guardians prior to collecting such student Personal Information. If you are a minor student, do not upload or send any Personal Information about yourself or other students to Hologo, other than what is requested upon signing up for the Services. In the event that we discover we have the Personal Information of a student without consent of a parent/legal guardian, or information in excess of what we request upon sign-up, we will permanently destroy that information as quickly as possible. If you believe a student may have provided us Personal Information without consent of a parent/legal guardian, or information in excess of what we request upon sign-up, please contact us at email@example.com.
(c) Students who have signed up with an access code provided by a school or teacher should be aware that their parent/legal guardian has access to all information within or associated with their Hologo account, including, but not limited to, messages between other students, teachers, and assignment grades.
(d) All students and teachers within a single group in the password-protected portion of the Hologo site will not have the ability to view one another’s profiles as visibility is limited to such information as their names. Students are unable to see the grades of other students, irrespective of whether or not they are members of the same course group on the site.
7. Information of Others
By inputting any Personal Information into the Application (including the Personal Information of others), you consent to the use of that Personal Information within the Application, and you represent and warrant that you have obtained any permissions or authorizations for any Personal Information of others that you input or send through the Application. We do not use, collect or retain any of that information
You authorize us to communicate with you regarding our Services and your account. You authorize us to communicate with you via the internet and via the email address you have provided. You understand and accept the risk that data and information transmitted over the internet is susceptible to error or security breaches.
9. Information Use & Sharing
Hologo may use your Personal Information for the following purposes:
- To provide and maintain our Application and Services
- To notify you about changes to our Application and Services
- To allow you to participate in interactive features of our Application and Services when you choose to do so
- To provide customer support
- To gather analysis or valuable information so that we can improve our Application and Services
- To monitor the usage of our Application and Services
- To detect, prevent, and address technical issues
10. Dispute Resolution
In the event you have a question, complaint or dispute regarding your personal information or our personal information handling practices, contact us at the number(s) or email address(es) as displayed in the “Contact Us” section of our website. See also addendum 1.1 below in this regard.
11. Business Transfers
12. Retention of Data
Hologo will also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Services, or we are legally obligated to retain this data for longer time periods.
13. Transfer of Data
Your information, including Personal Information, may be transferred and maintained on servers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including Personal Information, to the United States and process it there.
14. Security of Data
The security of your data is important to us, but no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially-acceptable means to protect your Personal Information, we cannot guarantee its absolute security.
15. “Do Not Track” Signals
We do not 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.
16. Your Rights
Hologo aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information.
Whenever made possible, you can update your Personal Information directly within your account settings section. If you are unable to change your Personal Information, please contact us to make the required changes.
If you wish to be informed what Personal Information we hold about you and if you want it to be removed from our systems, please contact us.
In certain circumstances, you have the right:
- To access and receive a copy of the Personal Information we hold about you;
- To rectify any Personal Information held about you that is inaccurate;
- To request the deletion of Personal Information held about you;
- To limit further processing, disclosure or use of your Personal Information.
If you wish to exercise these rights contact us using the contact details set out below.
Where we act as Data Processor and not Data Controller, we will refer your request to the applicable Data Controller, which, if you are a student, may be your teacher, school district, or your educational institution.
You also have the right to data portability for the information you provide to Hologo. You can request to obtain a copy of your Personal Information in a commonly used electronic format so that you can manage and move it.
We will ask you to verify your identity before responding to such requests.
17. Service Providers
We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.
These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
In cases of onward transfer to third parties of Personal Information received, Hologo is potentially liable.
Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession), and any information about the individual associated with that information.
Usage Data is data collected automatically either generated by the use of the Services or from the Service’s infrastructure itself (for example, the duration of a page visit).
Cookies are small pieces of data stored on a User’s device.
Data Processor (or Service Providers)
Data Processor (or Service Provider) means any person (other than an employee of the Data Controller) who processes the data on behalf of the Data Controller.
We may use the services of various Service Providers in order to process your data more effectively
Data Subject is any living individual who is the subject of Personal Data.
The User is the individual using our Application or Services. The User corresponds to the Data Subject, who is the subject of Personal Data.
Changes to this Policy may be made from time to time by us, and the modified form of the Policy will take effect 10 days after posting on this page.