Purpose of this Privacy Policy
This Privacy Policy aims to give you information on how HOLA collects and processes your personal information through your use of the Website, App and the Services, including any information you may provide when you sign up for a demo of our Services, when you create an account and a profile with us, when you purchase or use our Services, when you submit status updates, when you search for our Website or App, when you use our App, when you subscribe to our email alerts, when you contact our customer service, when you participate in surveys, public forums, chats, or when you respond to one of our requests for suggestions and other content.
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Please note that neither the Website, App nor the Services is intended for children under 16 years of age. No one under age 16 may provide any information to or on the Website, App or through our Services. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on the Website, App or on or through any of its features, use any of the interactive or public comment features of the Website or App or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us.
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It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your information. This Privacy Policy supplements the other notices and is not intended to override them.
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Controller or Processor
To the extent that HOLA holds information about you due to your use of our Services, HOLA is the controller and responsible for your personal information. To the extent that HOLA holds information about you due to its presence in content uploaded by HOLA customers, HOLA acts as a processor on behalf of such customers and the terms of this Privacy Policy does not apply to such information.

If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us using the details set out below.
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Contact Details
Our full details are:
     Hangzhou YuzhouBaba Trading Co., Ltd.
     Email address: support@holadropshipping.com
     Postal address: No. 38, Gaoji Street, Xihu District, Hangzhou City, Zhejiang Province, CN
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If you are based in the European Union, you also have the right to make a complaint at any time to your local supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the regulator so please contact us at support@holadropshipping.com in the first instance.
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Changes to the Privacy Policy and your duty to inform us of changes
This version was last updated on July 6th, 2020

We reserve the right to change the terms of this Privacy Policy at any time. When we do, we will post the revised Privacy Policy to our Website (as linked within the App) and the last revision date of revision will be updated so that you will always be able to understand what information we collect, how we use your information, and under what circumstances we may share your information with others.

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
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Third-party Links
The Website or App may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share information about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website or App, we encourage you to read the privacy notice of every website you visit.

Personal data, or personal information, means any information relating to an identifiable personwho can be directly or indirectly identified. It does not include data which cannot be related to an identifiable person (anonymous data).
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We may collect, use, store and transfer different kinds of personal information about you which we have grouped together follows:
     ● Identity Data includes first name, last name, username or similar identifier.
     ● Contact Data includes billing address, delivery address, email address and telephone numbers.
     ● Financial Data includes payment card details.
     ● Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
     ● Technical Data includes internet protocol (IP) address, your mobile device’s unique ID number, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Website or on which the App is installed and used.
     ● Profile Data includes your username and password, purchases or orders made by you, your location, preferences, feedback and survey responses.
     ● Usage Data includes information about how you use our Website, App, other app(s) and Services, such as the buttons, controls, products and ads you click on, pages of our App or Website that you visit, the time spent on those pages, your search queries, the dates and times of your visits or use, but also about the products that you are tracking through the App and Service, how often you use those products, and other related data regarding such usage by you.
     ● Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
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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 information but is not considered personal information in law as this information does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature. However, if we combine or connect Aggregated Data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this Privacy Policy.
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We do not collect any 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 collect any information about criminal convictions and offences.
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If you fail to provide personal information
Where we need to collect personal information by law, or under the terms of a contract we have with you and you fail to provide that information 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 ourservices). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

We use different methods to collect data from and about individuals including through:
Direct interactions by you
You may give us Identity, Contact and Financial Data by filling in forms, linking through your Shopify account or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide or permit use to access when you :
     ● sign up for a demo of our services;
     ● create an account and profile with us;
     ● purchase one of services;
     ● subscribe to our email alerts;
     ● complete one of our online forms to receive our reports and case studies;
     ● download or otherwise access one of our e-books, magazines, videos;
     ● contact our customer service;
     ● request marketing to be sent to you; or
     ● give us some feedback.

Automated technologies or interactions.
‍ As you interact with our Site, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data and Usage Data about you if you visit other websites employing our cookies..

Third parties or publicly available sources.
We may receive personal information about you from various third parties and public sources as set out below:
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     ● Technical Data from the following parties:
          a. analytics providers such as Google Analytics based outside the EU;
          b. search information providers such as Google based inside or outside the EU.
     ● Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe based outside the EU.
     ● Identity and Contact Data from our partners, data brokers or aggregators based inside or outside the EU.
     ● Identity and Contact Data from publicly available sources such as LinkedIn, Instagram, and other social networking sites based outside the EU.

Purpose of this Privacy Policy
‍We will only use your personal information when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
     ●  Where we need to perform the contract we are about to enter into or have entered into with you.
     ●  Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
     ● Where we need to comply with a legal or regulatory obligation.

The types of lawful basis that we will rely on to process your personal data are:
     ●  Legitimate Interest - this means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
     ●  Performance of Contract – this means processing your information where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
     ●  Comply with a legal or regulatory obligation -this means processing your personal information where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
     ●  Consent – this means you have consented to our use of data in this manner. We may ask for your express consent for certain uses, and you are free to withdraw that consent at any time. Generally we do not rely on consent as a legal basis for processing your personal information other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal information‍
We have set out below, a description of all the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your information. Please contact us if you need details about the specific legal grounds we are relying on to process your personal information where more than one ground has been set out in the table below.

Purpose/Activity Type of Data​Lawful basis for processing including basis of legitimate interest to register you as a new customer:
     a. Identity
     b. Contact
Performance of a contract with you to allow your use of the Service:
          a. Identity
          b. Technical
     c. Contactd. Financial
     e. Transaction

Performance of a contract with you to process and deliver your order including:
a. Manage payments, fees and charges

Collect and recover money owed to us
     a. Identity
     b. Contact
     c. Financiald. Transaction
     e. Marketing and

Communications
     a. Performance of a contract with you
     b. Necessary for our legitimate interests (to recover debts due to us)To manage our relationship with you which will include: Performance of a contract with youa. Notifying you about
changes to our terms or
     b. Necessary to comply with a legal obligation

Privacy Policy
     c. Necessary for our legitimate
     b. Asking you to leave a review or take a survey interests (to keep our records updated and to study how customers use our services)

To enable you to partake in a prize draw, competition or complete a survey
     a. Identity
     b. Contact
    c. Profile
    d. Marketing and

Communications
     a. Identity
     b. Contact
     c. Profile
     d. Usage
     e. Marketing and

Communications
     a. Performance of a contract with you
     b. Necessary for our legitimate interests (to study how customers use our services, to develop them and grow our business)
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To administer and protect our business and this Website and Mobile App (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) a. Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)

b. Necessary to comply with a legal
obligation
To use data analytics to improve our website, services, customer relationships and experiences
a. Identityb. Contact
c. Technical

Necessary for our legitimate interests (to define types of customers for our services, to keep our Website and Mobile App updated and relevant, to develop our business and to inform our strategy) To make suggestions and recommendations to you about services that may be of interest to you
     a. Technical
     b. Usage
     a. Identity
     b. Contact
     c. Technical
     d. Usage
     e. Profile

Necessary for our legitimate interests (to develop our services and grow our business) or where have otherwise consented to such usage

Marketing
We strive to provide you with choices regarding certain personal information uses, particularly around marketing and advertising. You may elect to opt out of receiving any further marketing or advertising emails from us through the mechanism provided in those emails. We may send you targeted advertising through the Service on to you.

Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-party marketing
We will get your express opt-in consent before we share your personal information with any company outside our company for marketing purposes, including service providers who perform marketing services on our behalf, such as conducting surveys, sending communications to you on our behalf, or serving advertisements to you.

Opting out
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal information provided to us as a result of a service purchase, service experience or other transactions.

Cookies (website only)
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Website maybecome inaccessible or not function properly.

Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at support@holadropshipping.com.

If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We may have to share your personal information with the parties set out below for the purposes set out in the table in paragraph 4 above.
     ● Third Party categories as set out below:
     ● Service providers who provide IT and system administration services.
     ● Social networking sites to which you have linked your account.
     ● Professional advisers including lawyers, bankers, auditors and insurers based in Canada and the United States who provide consultancy, banking, legal, insurance and accounting services.
     ● Regulators and other government authorities [acting as processors or joint controllers based in Canada, the United States and in the EEA who require reporting of processing activities in certain circumstances.
     ● Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this Privacy Policy.
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We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

We share your personal information within our company and to our third party service providers such as Amazon Web Services or other providers. This may involve transferring your information internationally, including without limitation, if you are based in the European Union, transferring your data outside the European Economic Area (EEA).
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Many of our external third parties are also based outside the European Economic Area (EEA) so their processing of your personal information will involve a transfer of data outside the EEA.
If you are based in the European Union, whenever we transfer your personal information out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring appropriate safeguards are implemented.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.