Privacy Policy of Hola

Introduction
This Privacy Policy sets out how we, X Communications, LLC. (“Hola”), use and protect your personal data that you provide to us, or that is otherwise obtained or generated by us, in connection with your use of our cloud-based communications services (the “Services”). For the purposes of this Privacy Policy, ‘we’, ‘us’and ‘our’refers to Hola, and ‘you’refers to you, the user of the Services.
1. Privacy Principles
We at Hola have a key fundamental principle that makes us supremely different from all other similar functioning systems: We Don’t Monetise Your Data. Simple! Hola maintains the tightest privacy and security communications structure to ensure your data is safe at all times.
You need to know, at Hola we collect the following information data only: your name, phone number, and email (only to reset passwords). We only collect data that Hola needs to function as the most private and secure communications phone app system on the market today. At Hola we cannot read, intercept, listen, view, record, save, print or access any of your text, voice, images, video, conference communications. Always, your communications are entirely private between you the sender and your receiving party (s). 
2. Terms of Service
This Privacy Policy forms part of our Terms of Service, which describes the terms under which you use our Services. This Privacy Policy should therefore be read in conjunction with those terms.
3. Table of Contents
This Privacy Policy explains the following: 1. the legal basis for processing your personal data; 2. what personal data we may collect from you; 3. how we keep your personal data safe; 4. what we may use your personal data for; 5. who your personal data may be shared with; and, 6. your rights regarding your personal data.
4. EEA Representative
If you live in a country in Europe, the Services are provided by Hola, which for the purposes of applicable data protection legislation, is the data controller responsible for your personal data when you use our Services. However, as Hola is located outside of Europe, we have designated one of our European-based partners, X Group Companies, Ltd.,   as a representative to whom you may direct any issues you have relating to our processing of your personal data and reachable through support at xgroupcommunity.net
5. Processing Your Personal Data – Legal
We at Hola use your data to operate Hola Communications Systems. In doing so, we provide a private and secure communications system, providing private, secure and innovative Services to all our users. Your data is also used to detect, prevent or otherwise address fraud or security issues in the Hola system. Notwithstanding, we place your privacy and security above all things.
6. What Personal Data We Use
a. Basic Account Data
Hola is a private and secure communications system. To create an account with Hola, you must provide your name and mobile number. A profile picture is optional.  We use your email address for password recovery only. And, to make our system easier to use, we allow you the option of synching your contacts to Hola thereby identifying other Hola users in the contacts application. 
b. Your E-mail Address
Hola only uses your email for account password recovery. 
c. Your Messages
All messages and the contents are end-to-end encrypted. This means only the sending and receiving parties can encrypt the messages sent, and this can only be done on the device.  Basic Hola users will only have access to their messages on their mobile devices. Premium uses who have purchased cloud storage will have access to their information on their devices, and also on their storage cloud. Again, all information on the Hola storage cloud is encrypted and cannot be accessed by anyone other than the recipient through their own private key. Messages, including all attachments that are on route but have not been accessed by recipients are held on the encrypted Hola cloud and will be accessible once the receiving mobile account authenticates the message into their device. 
d. Cloud Communications
Hola is a super-secure private cloud communications system. Premium users are able to store all communications, photos, videos and file documents from their devices on the Hola cloud. This allows users access to their data from any device anytime without having to rely on third-party backups. All stored data is heavily encrypted and all encryption keys in separate servers in numerous global data centres. Basic users have no access to cloud storage and must rely on their now devices to store all their data.
e. Secret Communications
All Hola communications use end-to-end encryption. This means that all data is encrypted with a key that only you and the recipient know. Secret Communications have another level of privacy: Each secret conversation has a pin code that locks the chat down. Thus, preventing anyone who might have access to the mobile device the ability to see inside the secret message. Note also, secret communications mode prevents screen capturing. Hola ensures that your secrets remain secret. 
f. All Attachments – Secret Communications
When you send an attachment, whether it be photos, videos, document binders or just files via secret communications, everything is heavily encrypted. There is no way that anyone can access the contents. Securing your files behind a private pin code ensures its security even if you leave your device lying around, still no one can access your data. 
g. Public Communications
In addition to the Hola secure communications system, Hola provides access to Social Space and Classifieds. Information posted in Social Space is accessible to those “followers” who have subscribed to follow the content contained therein. The author of the content should consider Social Space public as the information contained is consumed by a public audience. Information posted in Classifieds is accessible to all Hola users. They do not have to subscribe, all Classifieds are available to all Hola users. Classified adds are geographically organised according to regions, however, the search function allows for full search and find capabilities across the system. That said, all content is fully encrypted and only accessible through the Hola app on the users device. 
h. Phone Number and Contacts
Hola uses phone numbers as unique identifiers for easy connections between Hola users. We only need your name for this to work effectively within the contacts area. We ask your permission before syncing your contacts, and it is easy to stop synching through the settings panel in your device.  Hola also uses your geographical identity within your phone number to sort the most optimal Classified adds for each user. Classified adds are never sent to you. You can only access classified adds by clicking on the Classified adds button and engaging within that part of the Hola system. 
i. Cookies
Hola uses cookies to operate and provide our Services on the web. The 
cookies are small text files that allow us to provide you with an enhanced user experience. You can control these cookies from your browser, including whether or not to accept them and how to remove them. You may choose to block cookies with your web browser, however, if you do disable these cookies you will not be able to log in to Hola Web.
6. Keeping Your Personal Data Safe
a. Storing Data
All Hola data is stored in highly encrypted globally-located data centres. This data can never be compromised, and never intercepted. Data and private security keys are held at different data centres, ensuring the integrity of the Hola system.
b. End-to-End Encrypted Data
All communications, photos, document binders and files are transferred via end-to-end encryption only. This means your data  can only be processed on your device and on the device of your recipient. If any data is not received due to the recipient’s unavailability, or inability to process the message, the message remains on the Hola cloud in a fully encrypted state until your device authenticates the message. At that time, the message will decrypt on the recipients devise: fully end-to-end encryption.
c. Retention of your Data
The personal data that you provide us will only be stored for as long as it is necessary for us to fulfil our obligations with respect to the Hola Communications Services you have contracted. 
7. Processing Your Personal Data
a. Our Services
Hola is a private and secure cloud communications system. The Hola system will deliver your communications, including video, voice, conferencing, messages, files, binders, photos and all other attachments, including your stored communications to any device that you use to connect to the Hola system without the need for you to use third-party backups. And, everything, every time will be delivered using fully private, secure and entirely encrypted technology.
b. Safety and Security – Account Abuse
Hola services a global community and as such must be forever vigilant against any systems abuse and Terms of Service violations. Due to our global presence, Hola is a potential target for spammers, phishers and similar nefarious users. To maintain and improve the security of your account, as well as to prevent all kinds of account abuses and other violations of our Terms of Service, we rely on our members to report anything they deem a violation of our terms via the app directly.
When a report is made, the information is investigated by the Hola team; if confirmed, the responsible account may be temporarily or permanently closed.  Serious violations are dealt with on a case-by-case basis. Certain violations are taken extremely seriously and dealt with accordingly.
c. Advanced features
Hola may periodically add advanced user features, but in now way will these features require any additional user information. All new features will adhere to the Hola principles of privacy and security.
d. No Monetisation of your Data
Unlike all other similar App services on the market today who outright sell all your information, we don’t monetise your data. We store very limited data that will allow us to perform the functions necessary to operate Hola communications system.
6. Automated Integration
a. Ecosystem
Hola uses its own API’s (Application Programming Interface). This allows Hola system to talk with only selected applications. Having been carefully built from the ground up, with only one entry and exit point, we have maximised security whilst minimising opportunities for other systems to penetrate the Hola system’s integrity.  That said, we do not allow any third-party access gateways like other social systems. Our policy secures the potential loss of passwords, user data and other private information. 
7. Payment Services
a. Payment Information
Hola use a number of payment gateways for the initial purchase of the Hola Phone App, including the Hola blockchain wallet.  For purchase options inside the Hola system Hola uses multiple payment gateways for payments within Social Space, and Hola Classifieds. We also allow internal payments through the Hola Blockchain wallet. Both mechanisms can be used for purchasing of products and services through the Social Space and Classifieds, but also for advanced features to enhance your Hola experience. Note, these additional payment systems are very secure, but they may have additional sets of privacy statements. It is also likely you have used them before. However, please ensure you are comfortable with their use. 
b. Credit Card Information
When making a purchase, you enter your credit card details into a form supplied through a payment gateway that will be processing the payment, and this information goes directly to the payment provider‘s data base. Hola does not see your credit card details.  Hola does not access or store your credit card information. If you choose to save your credit card details, they are saved on the respective payment provider’s data base. When you leave your details for future payments, the payment provider gives Hola a digital token-code to allow for you future payments without the need to reenter your details. For payments using Hola blockchain wallet, you can apply existing credits for instant purchasing.
c. Shipping Information
During your payment process you will be directed to enter you shipping information. We will store your shipping information if you choose to save it for future purchasing. We will also delete your information if you ask us. 
d. Payment Disputes
Hola does not store your credit card details or transactional information, and it is impossible for us to handle complaints or cash-backs. Any disputed payments are the responsibility of the vendor, payment providers, and banks that participated in the exchange.  However, if you made your purchase through Hola blockchain wallet, we will certainly help you in every way we can. 
8. Who Your Personal Data May Be Shared With
a. Other Hola Users
Hola has a global presence, and as such, you may communicate and share information with any Hola user.   Note, by entering into Hola Terms and Conditions, you are choosing to communicate via the Hola system with any user, and  you are instructing us to transfer your personal data, on your behalf, to those users in accordance with this Privacy Policy. As noted throughout this Privacy Policy, Hola is a super-secure and private communications system and all your data is fully encrypted. Only you are the recipient that you have agreed to share your data with will have access to the contents of your communications. 
b. Hola’s Group Affiliated Companies
We may share your personal data with: (1) the parent company, X communications, LLC, and two regional supporting agencies:  X Group, llc, and X Group Companies, Ltd., to help provide, improve and support our Services. At all times, we implement necessary safeguards to protect the security and integrity of all data.  These safeguards  take the form of contractual agreement between us and our relevant group companies.
c. Law Enforcement Authorities
Hola will not tolerate at any time any abuse to the Hola system. If we receive a summons from a proven legal authority that confirms a Hola user is suspected of activities that are abhorrently illegal, we will assist those authorities in disclosing information available to us – as described in this  document – and within the limits of our systems capabilities.
9. Your Rights – The Data Maintained with Hola
a. Your Rights
Under applicable data protection legislation, in certain circumstances, you have rights concerning your personal data. You have a right to: (1) request a copy of all your personal data that we store and to transmit that copy to another data controller; (2) delete or amend your personal data; (3) restrict, or object to, the processing of your personal data; (4) correct any inaccurate or incomplete personal data we hold on you; and (5) lodge a complaint with national data protection authorities regarding our processing of your personal data. Keep in mind, the data we have have is your name, your phone number and your email which we use for account recovery only. Any addresses you give us in the course of purchasing items is yours at anytime to delete or save. 
b. Exercising Your Rights
If you wish to exercise any of these rights, kindly contact us through xgroupcommunity.com
c. Data Settings
You can control how your data is used via your settings menu in the Hola phone app. For example, you can delete synched contacts, amend your profile and additional options. 
10. Deleting data
a. Accounts
If at anytime you are not happy with our services, we will naturally delete your account at your request. Kindly contact us though xgroupcommunity.com. Deleting your account removes all communications, photos, binder files and documents, including all messages  and every other piece of data you store in the Hola cloud. This action must be confirmed through the Hola phone app and cannot be undone.
b. Messages
If you use secret chats (chats where you are using the pin code for an extra level of device privacy), you can delete a message at any time. Keep in mind, you are deleting your end of the conversation. The message recipient will not know that you have deleted the message and thus, the message will remain on their cloud until they delete it. All regular open chats function this way. Also note,  Delete means eliminated from our records! 
As to group chats, as a participant you at any time can delete your end of the conversation. You, however, cannot delete any other portion of the group chat. Only the administrator of the group can delete the conversation. Once s/he deletes the group, all contents of that correspondence is eliminated, entirely.  
c. Self-Destructing Messages
If you are looking to ensure all traces of your conversations are removed, then  messages sent through Hola Secret Chats can be programmed to self-destruct.  You send the message to your recipient (s) under conditions that the message will self-destruct within a set time.  When the timer expires, both devices participating in a secret chat are instructed to delete the entire contents of the message, including attachments.  Note, the timer is triggered when the message is viewed. For added security, when a message carrying a picture is received in a secret chat it is “blurred-out”. Thus, a recipient is unable to view it until they trigger the timer. And, once done, the self-destruction is set.
d. Account Deletion
With Hola, your account does NOT auto-delete after a period of non-use. Premium users must fund their accounts every 12 months. If you fail to do so, your account will revert to a Basic user account.  If users fail to fund the added features on their accounts they will be notified through their Hola accounts that these added features will expire. Users of Premium will be given notice within 30 days of their billing period. For accounts where there is dispute with the ownership of the phone number, each will be investigated on a case-by-case basis. Keep in mind the owner of the sim card with the number will control the number. 
11. Changes to this Privacy Policy
Hola may review and update this Privacy Policy from time to time. Any changes to this Privacy Policy will become effective when we post the revised version.  It is your responsibility to review these changes. At Hola we will send a message though our system advising you that changes have been made.
12. Questions and Concerns
If you have any questions about privacy and our data policies, please go to xgroupcommunity.com and use the community for all your questions and concerns. Simple type a key word and you should find your answer. If you are cannot find what you are looking for, please feel free to reach out via the questions & answers tab by sending your question directly to our team. We will get back to you within 24 – 48 hours. Hola also offers a ticket system to reach our team for more pressing issues. That said, feel free to explore xgroupcommunity.com and get to know more about us. 

Contact Us
If you have questions about our Privacy Policy please contact us at privacy@holaphoneapp.com
Effective as of May 25, 2018

Last Updated On April 21, 2019
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