Website Privacy Notice
LAST UPDATED: FEB 2, 2022
This Website Privacy Notice (“Privacy Notice”) covers Hologram’s collection and processing of your Personal Data collected when you visit any web domains owned, operated, branded or co-branded by Hologram to which this Privacy Notice is posted or linked (“Websites”). Websites include Hologram’s support website and community forum. Websites do not include Hologram’s Careers Page or Hologram’s online customer dashboard or any other Hologram products or services that are only accessible to you after authenticating with Hologram (e.g., registering or signing in) or for which Hologram acts as a processor.
Section 1: Definitions
1.1 “Hologram” or “we”, “us” or “our” means Hologram, Inc..
1.2 “You” and “your” means yourself and the entity(ies) you represent.
1.3 “Personal Data” has the meaning given such term (or a similar term such as “personal information”) under data protection laws applicable to You. For example, for residents of the European Economic Area (“EEA”), United Kingdom (“UK”), and Switzerland, Personal Data is equivalent to “personal data” governed by European data protection legislation.
Section 2: What does this Privacy Notice cover?
2.1 Hologram respects your privacy and takes steps to protect your Personal Data. We strive to be transparent with you about how we collect and use your Personal Data in making available Hologram’s Websites and tell you about any privacy rights you may have.
2.2. Hologram provides a global IoT SIM and connectivity platform that enables devices to stay connected by automatically switching carriers when needed. Our products and services, and correspondingly, our Websites, are designed for businesses and their representatives. We do not offer products or services for use by individuals for their personal, family or household purposes, and do not intend our Websites to be accessed or used by individuals for such purposes. Accordingly, we treat all Personal Data we collect through the Websites as pertaining to individuals in their capacities as business representatives and not in their individual capacities. This Privacy Notice applies only to Personal Data collected through the Websites, as defined herein. It does not apply to Personal Data collected through our products and services, including Personal Data we collect in the role of a processor or service provider on behalf of our customers, such as where we offer to our customers various products and services through which our customers (or their affiliates): (i) create their own websites and applications running on our platforms; (ii) sell or offer their own products and services; (iii) send electronic communications to others; or (iv) otherwise collect, use, share or process Personal Data via our products and services. For detailed privacy information related to use of your Personal Data by a Hologram customer or a customer affiliate who uses Hologram products and services, please contact our customer directly. We are not responsible for the privacy or data security practices of our customers, which may differ from those explained in this Privacy Notice.
2.3 With that in mind, this Privacy Notice is designed to describe:
2.3.1 Who we are and how to contact us.
2.3.2 Your rights relating to your Personal Data.
2.3.3 Marketing communications preferences and other choices.
2.3.4 What Personal Data Hologram collects.
2.3.5 How Hologram collects Personal Data.
2.3.6 How Hologram uses your Personal Data and why.
2.3.7 Who Hologram shares your Personal Data with.
2.3.8 How Hologram keeps your Personal Data secure.
2.3.9 How Hologram uses cookies and other tracking or profiling technologies.
2.3.10 How long Hologram stores your Personal Data.
2.3.11 Hologram’s policy on children.
2.3.12 Third party links
2.4. Hologram reserves the right to make changes to this Privacy Notice at any time. If we make material changes to this Privacy Notice, we will notify you by updating the date of this Privacy Notice and by posting any modifications or changes to this Privacy Notice on this page or by other appropriate means.
Section 3: Who we are and how to contact us
3.1 Hologram is a Controller (for the purposes of the EU and UK General Data Protection Regulation (collectively referred to herein as “GDPR”) of your Personal Data. Our address is: 1608 S. Ashland Ave 25937, Chicago, IL 60608. You can contact us by emailing: privacy@hologram.io
3.2. Hologram has appointed PLANIT//LEGAL as its EEA representative, which can be contacted at PLANIT//LEGAL, Attn: Hologram, Inc., EU Representative, Jungfernstieg 1, 20095 Hamburg, Germany, E-Mail: hologram_eu_representative@planit.legal
and Sapphire Consulting Group as its UK representative, which can be contacted at
Sapphire – Data Protection Consultants, Attn: Hologram, Inc.
Central Point, Beech Street,
London EC2Y 8AD, England
E-Mail: info@sapphireconsulting.co.uk
Section 4: Your rights relating to your personal data
4.1 Under certain circumstances, if and to the extent provided by any law applicable to your Personal Data, you may have certain rights with respect to your Personal Data. Such rights may include the right to:
4.1.1 Request access to your Personal Data. This may enable you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
4.1.2 Request correction of the Personal Data that we hold about you. This may enable you to have any incomplete or inaccurate information we hold about you corrected.
4.1.3 Request erasure of your Personal Data. This may enable you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You may also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below).
4.1.4 Object to processing of your Personal Data. This right may exist in certain situations where we are relying on a legitimate interest as the legal basis for processing your Personal Data. You also may have the right to object where we are processing your Personal Data for direct marketing purposes.
4.1.5 Request the restriction of processing of your Personal Data. This right may enable you to ask us to suspend the processing of Personal Data about you, for example, if you want us to establish its accuracy or the reason for processing it.
4.1.6 Request the transfer of your Personal Data. In certain situations, you may have the right to request that we provide your Personal Data in a structured, commonly used, machine-readable format.
4.1.7 Withdraw consent. This right only may exist where we are relying on consent to process your Personal Data (“Consent Withdrawal”). If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of our Websites.
4.2. Please note that some of these rights may be limited where we have an overriding interest or legal obligation to continue to process the Personal Data or where certain exemptions apply.
4.3 If you are entitled to exercise any of the rights described above and wish to do so, please contact us via email at privacy@hologram.io. Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, except in relation to Consent Withdrawal under the GDPR, we may have the right to charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, we may have the right to refuse to comply with your request in these circumstances.4.4 We may need to request specific information from you to help us confirm your identity and ensure that you are qualified to exercise a right to access your Personal Data (or to exercise any of other rights). This is also a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
4.5 We try to respond to all legally valid and legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
4.6 If you would like to make a complaint regarding this Privacy Notice or our practices in relation to your Personal Data, please contact us at: privacy@hologram.io. We will reply to your complaint as soon as we can. If you feel that your complaint has not been adequately resolved and you are a resident of the EEA, please note that the GDPR gives you the right to contact your local data protection supervisory authority, which for Ireland is the Data Protection Commissioner, Canal House, Station Road, Portarlington, Co. Laois, Lo-Call: 1890 25 22 31, Tel. +353 57 868 4800, e-mail: info@dataprotection.ie, website: http://www.dataprotection.ie/ (http://www.dataprotection.ie/). If you are a resident of the UK, your local data protection supervisory authority is the Information Commissioner's Office, established at 45 Melville Street Edinburgh EH3 7HL. Tel: 0303 123 1115, e-mail: scotland@ico.org.uk., website: https://ico.org.uk/ (https://ico.org.uk/).
Section 5: Marketing communications preferences and other choices
5.1 You can ask us to stop sending you marketing-related emails at any time by following the opt-out links contained in any such marketing email sent to you AND/OR by contacting us at any time using the contact details shown here: privacy@hologram.io. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails. You may have the right to opt-out of receiving marketing or advertising calls, in which case you may do so during any such call or by contacting us using the contact information provided in the “who we are and how to contact us” section, above.
5.2 For information concerning your choices with respect to cookies and similar technologies, please see our Cookie Settings.
5.3 If you have registered for an account with us, you may review and update certain account information through the “settings” section in your account.
5.4 You may decline to provide Personal Data. However, note that we need to collect Personal Data to provide certain services and if you do not provide the information we identify as required or mandatory, we may not be able to provide those services.
Section 6: Data we collect
6.1 The Personal Data we collect, both from you and from third parties about you, through our Websites is outlined in the table below and is described further in Section 7.
Category of personal data collected: Identity data
What this means: First name, last name, email address
Category of personal data collected: Contact data
What this means: Billing address, shipping address, email address and telephone numbers
Category of personal data collected: Financial data
What this means: Your bank account and payment card details
Category of personal data collected: Transaction data
What this means: Any details about payments to and from you and other details of subscriptions and services you have purchased from us
Category of personal data collected: Marketing data
What this means: Your preferences in receiving marketing from us and details about your engagement with our marketing communications
Category of personal data collected: Communications data
What this means: The content of your communications to us
Category of personal data collected: User-generated content
What this means: Photos, images, videos, comments, questions, works of authorship, and other content or information that you generate, transmit or otherwise make available on the websites
Category of personal data collected: Technical data and online activity data
What this means: Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, pages or screens you viewed, navigation paths between pages or screens, access times and duration of access, and the website you visited before browsing to the Websites. Technical information in order to assist with troubleshooting.
6.2 We also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data, but once in an appropriately anonymized form, it will not constitute Personal Data as this data does not directly or indirectly reveal your identity (“Anonymous Data”). On the contrary, if it is still possible to combine or connect Aggregated Data with your Personal Data, we will treat the combined data as Personal Data which will be used in accordance with this Privacy Notice.
6.3 We do not intentionally collect “Special Categories of Personal Data” about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we intentionally collect any information about criminal convictions and offenses.
Section 7: How Hologram collects personal data
7.1 Hologram collects certain Personal Data from visitors to Hologram Websites. This data is collected via the following methods:
7.1.1 With your prior consent, where applicable, Hologram will store session information (often called “Cookies”) in your browser that will help Hologram to identify information such as browsing activity, IP addresses and page view order. You have the option not to allow these Cookies and can change your choices at any time via our cookie banner, except for strictly necessary cookies where your consent is not required (http://); the majority of browsers will also have a “help” tool that will help you to block Cookies, but Hologram recommends you keep Cookies active as it will provide a better user experience on Hologram’s Websites. For further information, please read our Cookie Notice (https://hologram.io/cookie-notice).
7.1.2 Information you provide:
7.1.2.1 When you submit a request or interact with our customer support on Hologram Websites, you provide us with your email address, the subject and description of your message, your phone number and any optional attachments. Where you contact our Sales team, we ask further information about your device, data usage and your deployment.
7.1.2.2. When you interact with us on social media, such as Facebook, LinkedIn or Twitter, Github, you provide us with Identity Data, Contact Data and Communications Data. By accessing and using those sites, you are agreeing to the social media platform provider’s privacy statement. This may include sharing with us your name, profile, photos, reactions and comments to our posts, etc. The social media platform provider’s privacy statement applies to your interactions with the platform and their collection, use and processing of your Personal Data. You or the platforms may provide us with Personal Data through the platform, and we will treat such information in accordance with this Privacy Notice.
7.1.2.3. When you create an account with Hologram, you may provide us with your email address, first name, last name, your company, and password. Hologram may also give you the option to voluntarily share other data with us that is connected to your account. If any of these details change, you may update your account at any time and modify, correct or delete your account details as described in the “marketing communications preferences and other choices” section, above.
7.1.2.4. When you provide information on Hologram Websites, for example when you post, message or interact on the support website or in the community forum. Note that certain information such as your username is required in order to post content in certain areas of the Websites.
7.1.2.5. You may provide payment details when purchasing products from Hologram through the Websites. You provide us with your first name, last name, email address, phone number, shipping address, shipping options and payment information and billing address. Hologram uses a third-party e-commerce site with a Level 1 PCI compliant payment system, for direct online sales.
7.1.2.6. When it is necessary for us to otherwise process your Personal Data, you may provide us with other data, not specifically listed here, which we will use as described in this Privacy Notice or as otherwise disclosed at the time of collection or as required by applicable law (e.g. to investigate or settle inquiries or disputes).
7.1.3 Information provided by third parties
7.1.3.1 At times Hologram may receive Personal Data about you from third parties, including public sources, data providers (e.g., information services and data licensors), our affiliate partners, marketing partners, and third-party services such as social media services. These sources may provide us with Personal Data or Aggregated Data or Anonymous Data that we may use as described in this Privacy Notice. Hologram may combine Personal Data we receive from you with Personal Data we collect from such third parties.
Section 8: Purposes for which Hologram uses your Personal Data, including our “legal basis” for processing
8.1 The table below identifies Hologram’s purposes for processing your Personal Data. Additionally, in respect of each of the purposes for which we use your Personal Data, the GDPR requires us to ensure that we have a “legal basis” for that use. Most commonly, we will rely on one of the following legal bases: (a) where we need to perform a contract we are about to enter into or have entered into with you (“Contractual Necessity”); (b) where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”) (more detail about the specific legitimate interests pursued in respect of each Purpose we use your Personal Data for is set out in the table below); (c) where we need to comply with a legal or regulatory obligation (“Compliance with Law”); or (d) where we have your consent to carry out the processing for the purpose in question (“Consent”). Generally we do not rely on your Consent as a legal basis for using your Personal Data other than in the context of direct marketing communications. Our legal bases for processing your Personal Data are also set forth in the following table.
Purpose: To contact you to respond to your emails, phone calls and requests
Categories of personal data involved: Identity Data, Contact Data, Communications Data
Our legal basis for this use of data: Contractual Necessity
Purpose: To register you as a customer and create and maintain your account
Categories of personal data involved: Identity Data, Contact Data
Our legal basis for this use of data: Contractual Necessity
Purpose: To enable you to use our Websites
Categories of personal data involved: Identity Data, Contact DataTechnical Data and Online Activity Data
Our legal basis for this use of data: Legitimate interests. It is in our legitimate interests to ensure the possibility to access our Websites and to administer such Websites.
Purpose: To provide our Websites and associated products and services to you, including to process and manage payments, fees and charges and to provide support for our services
Categories of personal data involved: Identity Data, Contact Data, Financial Data, Transaction Data, Marketing Data, Communications Data, User-generated Content, Technical Data and Online Activity Data
Our legal basis for this use of data: Contractual Necessity
Purpose: To improve our Websites and associated products and services, including to troubleshoot and enhance our Websites, products and services, including to generate data analytics
Categories of personal data involved: Technical Data and Online Activity Data
Our legal basis for this use of data: Legitimate Interests. It is in our legitimate interests that we are able to enhance, monitor and ensure the proper operation of our Websites and associated systems and services and to generate data analytics in order to better meet your needs and expectations.
Purpose: We, our service providers and our third-party partners may market to you, including by email and phone
Categories of personal data involved: Identity Data, Contact Data, Marketing Data, Communications Data, and Technical Data and Online Activity Data
Our legal basis for this use of data: Legitimate Interests. We have a legitimate interest in marketing our products and services to you. We may obtain your consent to receive such communications, where required under applicable law.
Purpose: For compliance and protection purposes, including to:
- Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
- Protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims)
- Audit our internal processes for compliance with legal and contractual requirements or our internal policies;
- Enforce our terms and conditions; and
- Prevent, identify, investigate and deter fraudulent, harmful unauthorized, unethical or illegal activity, including cyberattacks and identity theft
Categories of personal data involved: Identity Data, Contact Data, Financial Data, Transaction Data, Marketing Data, Communications Data, User-generated Content, Technical Data and Online Activity Data
Our legal basis for this use of data: Compliance with our legal obligations, and/or our Legitimate Interests in defending us in the context of legal claims.
8.2 Where we need to process your Personal Data to comply with law, or under the terms of a contract we have with you and you fail to provide the Personal Data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the functionalities of the Websites). In this case, we may have to decline to provide the relevant services, but we will notify you if this is the case.
8.3 As noted, we may also create Anonymous Data from your Personal Data and other individuals whose Personal Data we collect. We may use such Anonymous Data and share it with third parties for our lawful business purposes, including to analyze and improve the Websites and related products and services and to promote our business.
Section 9: Who Hologram shares your personal data with
9.1 Hologram may disclose to third-parties some of the Personal Data we have collected as described in this Section 9 and as otherwise described in this Privacy Notice or at the time of collection.
9.2 Hologram may share Personal Data with business and marketing partners, including, for example, companies that have created “Powered by Hologram” products and partners with whom we jointly offer products or services, or whose products or services may be of interest to you.
9.3 Hologram may share Personal Data with third parties that provide services on our behalf or help us operate the Websites or our business (e.g., payment processors, customer support, hosting, information technology, marketing, and analytics).
9.4 Hologram may share Anonymous Data publicly or as otherwise described in this Privacy Notice.
9.5 Hologram will share Personal Data with third parties, including authorities and others, if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
9.5.1 meet any applicable law, regulation, legal process or enforceable governmental action.
9.5.2 enforce applicable terms and conditions, including investigation of potential violations.
9.5.3 detect, prevent, or otherwise address fraud, security or technical issues.
9.5.4 protect against harm to the rights, property or safety of Hologram, our users or the public.
9.5.5 audit our internal processes for compliance with legal and contractual requirements or our internal policies.
9.6 Hologram may share Personal Data with professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
9.7 Certain user-generated content and other data you submit to us may be visible to other users of the Websites and to the public, such as when you post comments in publicly-accessible parts of the Websites. This information can be seen, collected and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), and we are not responsible for any such use of this information.
9.8 If Hologram or some or all of its assets are involved in, or if Hologram is contemplating, a business transaction, including a merger, acquisition, sale of all or a portion of our assets, corporate divestiture, reorganization, bankruptcy or similar event, we may disclose or transfer Personal Data to other entities involved in or contemplating such transaction, based on our legitimate interests in ensuring our business continuity.
Section 10: International data transfers
10.1. Our sharing of Personal Data, both within Hologram and with third parties, may involve transferring your Personal Data outside the EEA or the UK.
10.2 We endeavor to ensure that people to whom we provide Personal Data hold it subject to appropriate safeguards and controls. Whenever we transfer your Personal Data out of the EEA or the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
10.2.1 We may transfer your Personal Data from the EEA to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission. For further details, see European Commission: Adequacy of the protection of Personal Data in non-EU countries (https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en).
10.2.2 Where we use service providers outside the EEA or the UK, we may use specific contracts approved by the European Commission, which are designed to give Personal Data the same protection it has in the EEA or in the UK. For further details, see (i) for the EEA: the Commission Implementing Decision (EU) 2021/914 of 4 June 2021 on standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council, and (ii) for the UK: standard contractual clauses published by the UK Information Commissioner’s Office, based on an adapted form of those adopted by the European Commission pursuant to implementing Decision (EU) 2010/87
10.2.3 In any other circumstances, will take appropriate steps to ensure that transfers of Personal Data are in accordance with applicable laws. We can provide you with a copy of the appropriate safeguards that we have put in place by contacting us at: privacy@hologram.io.
Section 11: Information Security
11.1. The security of your Personal Data is important to us. We employ technical, organizational and physical safeguards designed to protect the Personal Data we collect. These measures are designed to provide a level of security appropriate to the risks of processing your Personal Data. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your Personal Data.
11.2 Hologram uses Secure Socket Layer (SSL) encryption on the APIs (Application Programming Interface) and Websites operated by Hologram.
11.3 Personal Data collected by Hologram via its Websites and services is stored on secure third-party servers.
11.4 Hologram has put in place security measures designed to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.
11.5 With respect to our personnel, we have implemented measures designed to limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality.
11.6 We have put in place procedures designed to deal with any actual or suspected data breach. In the event of any such breach, we have systems in place to help us work with applicable regulators. In addition, in certain circumstances (e.g., where we are legally required to do so) we may notify you of breaches affecting your Personal Data.
Section 12: How long Hologram stores your personal data
12.1 We will only retain your Personal Data for so long as we reasonably need to use it for the purposes for which they were collected, unless a longer retention period is required by law (for example for regulatory purposes, or for the purposes of responding to possible disputes or complaints).
Section 13: Our policy on children
13.1 The Websites and associated products and services are not intended for children below 16 and we do not knowingly collect data relating to such children. If we learn that we have collected Personal Data through our Websites from a child under 16 without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information. We encourage parents or guardians with concerns to contact us.
Section 14: Third-party links
14.1 The Websites may include links to third-party websites, plug-ins and applications. Additionally, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. Clicking on those links or enabling those connections may allow third parties to collect or share your Personal Data. We do not control these third-party websites and online services and are not responsible for their privacy statements or their actions. When you leave our Websites, we encourage you to read the privacy policy of every website or online service you visit.