Welcome to ConsiderBeyond (our Service). The Service is operated and controlled by Holvic Inc. (Holvic). Holvic respects the privacy rights of its users and protects the personal information collected, stored and used in connection with our Service. To further this commitment, we have adopted this Privacy Policy (Privacy Policy) to guide how we collect, store, and use the information you provide us.  

By clicking the “I accept” button(or its equivalent), you (or the entity you are authorized to represent) are accepting the practices described in this Privacy Policy.  

We will notify you of any substantive revisions to this Privacy Policy in accordance with our Terms of Use. You will be deemed to have agreed to any such modifications by your continued use of our Service after any such modification is posted. It is important that you review this Privacy Policy regularly to ensure you are updated as to any changes. If you do not agree with the modifications, please discontinue use of our Service immediately. 

We do not knowingly collect personal information from children under the age of 13.
If you are a parent or guardian and believe your minor child has provided us with personal information without your consent, please contact us as described in the “Inquiries” section below and we will take steps to delete such personal information from our systems. 

1.      SCOPE OF PRIVACY POLICY


This Privacy Policy describes Holvic’s collection and use of information submitted and collected through our Service. Personal information includes any individually identifiable information about you, such as your name, address, telephone number, or e-mail address, and information concerning you collected and/or maintained in personally identifiable form.  

2.      INFORMATION WE COLLECT 

Information you provide us. For certain activities, such as when you register, upload content to the Service, or contact us directly, you may provide some or all of the following information: 

- Registration information, such as name, age, address, username and password, language, and email or phone number.
- Profile information, such as name, social media account information, and profile image.
- Your phone and social network contacts, with your permission. Information you provide us to complete a purchase such as PayPal or other third-party payment information (where required for the purpose of payment).
- Your inquiries and interactions  with us in respect of support requests and customer service (such as emails, chats and support tickets).
- Your messages within our Service (such as user feedback, chat and video logs).
- User-generated content that you choose to upload or share on the Service (User Content)
- Other data you choose to give us (such as information from your social network or data to identify a lost account). 

Information we collect automatically.

We automatically collect certain information from you when you use the Service. Information we collect automatically includes:  
- Information regarding your use of the Service. 
- Information about the device you use to access the Service, including unique device identifiers, model of your device, operating system, your mobile carrier, your IP address, time zone setting, app and file names and types.
- Information you provide in the context of composing, sending, or receiving messages through the Service’s messaging functionality. That information includes the content of the message and information about when the message has been sent, received and/or read, as well as the participants of the communication. Messages sent to the users of the Service will be accessible by those users and that we are not responsible for the manner in which those users use or disclose messages.
- Information about your location, including location information based on your SIM card and/or IP address. With your permission, we may also collect Global Positioning System (GPS) data.
- When you upload User Content, you automatically upload certain metadata that is connected to the User Content. Metadata describes other data and provides information about your User Content that will not always be evident to the viewer. In connection with your User Content the metadata can describe how, when, and by whom the piece of User Content was collected and how that content is formatted. It also includes information, such as your account name, that enables other users to trace back the User Content to your user account.
- Holvic and our third party business partners and service providers use cookies and other similar technologies (e.g. web beacons, flash cookies, etc.) (Cookies) to automatically collect information, measure and analyze which web pages you click on and how you use the Service, improve the Service, enhance your experience using the Service, and provide you with targeted advertising on the Service. Web beacons are small images pieces of data embedded in images, also known as “pixel tags” or “clear GIFs,” that can recognize Cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar information from your computer or device. Cookies are small files which, when placed on your device, enable the Service to provide certain features and functionality. We are not responsible for the privacy practices of third party business partners and service providers, and the information practices of these partners and providers are not covered by this Privacy Policy. 

We may aggregate or de-identify the information described above. Aggregated or de-identified data is not subject to this Privacy Policy. 

The following analytics technologies are in use: [Google Analytics, Facebook Analytics] 

You have access to tools to control the data collected by, web beacons, cookies, and other similar technologies. For example, you can control in your Internet browser how websites you visit are able to use cookies. However, if you disable cookies, your ability to use some functionalities of our Service may be affected. 

Information we collect from others.
 
- If you choose to link or sign up using your social network (such as Facebook, Apple, Instagram or Google), we may collect information from these services, including your contact lists for these services and information relating to your use of the Services in relation to these services.
- We may collect information about you from third-party services such as advertising partners and analytics providers to operate and improve our Service.
- We may collect information about you from other publicly available sources. 

Please keep in mind that when you voluntarily disclose personal information which is publicly viewable, that information will be publicly available and can be collected and used by others. For example, if you post your email address, you may receive unsolicited messages. We cannot control who views information (and what they do with information) you voluntarily post publicly. 

3.      USE & SHARING OF INFORMATION COLLECTED

We use the data we collect from you: 

To operate our Service.
To perform our agreement with you and provide our Service, we process data necessary to: 

- Create accounts and use our Service
- Complete purchases or requests you make
- Help us manage, operate and deliver our Service to you
- Provide you with customer support
- Communicate with you about our Service (unless you have not consented to allow us to use your data for these purposes)
- Develop new products or services, or make informed business decisions Use User Content consistent with the functionality of our Service, and as part of our advertising and marketing campaigns to promote the Service.

To provide a great experience to our users. To provide our Service to our users, we have a legitimate interest to collect and process necessary data to: 

- Update and develop user profiles
- Complete purchases or requests you make
- Provide you with Holvic offers within our Service as well as in other web sites and services, and by email
- Customize your experience
- Develop and improve our Service and user experience
- Manage our relationship with you
- Enable you to communicate with other users
- Provide social features as part of the Service
- Send you related information, such as updates, security alerts, and support messages 

To keep our Service safe.
In order to keep our Service and its interactive features safe, we have a legitimate interest to process necessary data to: 

- Verify accounts and activity, combat harmful conduct, detect and prevent spam, maintain the integrity of our Service  
- Analyze and monitor use of our Service and its features
- Take action against fraudulent or abusive users 

For all the foregoing purposes, we may use individual data or aggregate your individual data with other data to analyze, profile and segment all collected data. 

With your consent, we may process your data for additional purposes. 

Sharing. Other than Holvic, your personal information may be seen by third parties in the following situations: 

- Other users of our Service consistent with the functionality of our Service.  
- Partners, vendors and service providers who support our business, such as by providing technical infrastructure services, analyzing how our Service are used, providing customer service, facilitating payments or conducting surveys. A list of subprocessors we use to support delivery of our Service is available at www.considerbeyond.com/subprocessors.
- If the ownership or control of all or part of our Service or their assets changes, we may transfer your data to the new owner.
- To comply with applicable law or respond to valid legal process, or to help our affiliates, partners or vendors comply, we may access, transfer,disclose, and preserve your personal information. That includes, for example,your private content.
- Our Service may include features from our partners, such as social media interaction tools. A list of these partners is available at www.considerbeyond.com/partneroptout. These partners may access your data and operate under their own privacy policies. We encourage you to check their privacy policies to learn more about their data processing practices.
- We may share your information for other purposes pursuant to your consent or with your further direction.
- For other legitimate purposes. 

Holvic will not sell personal information to advertisers or other third parties without your consent. 

4.       SAFEGUARDS

Holvic maintains appropriate safeguards that ensure the security, integrity, and privacy of the personal information we collect and store about our account holders. Personal information collected by Holvic is stored in secure operating environments that are not available to the public and that are only accessible by authorized employees. We also have security measures in place to protect the loss, misuse,and alteration of the information under our control (i.e., maintain data quality). Before we allow web users to access their personal information, for example,we verify their identity by requesting that they submit information such as their username and password.  

However, unfortunately, no data transmission over the internet or any wireless network can be guaranteed to be secure. As a result, while we strive to protect your personal information, you acknowledge that: (a) the security, integrity and privacy of any and all information and data exchanged between you and us through our Service cannot be guaranteed; and (b) any such information and data may be viewed or tampered with in transit by a third party. 

5.      LINKS TO THIRD PARTY SITES OR SERVICES 

You should be aware that our Service may from time to time contain links to third-party sites, products or services. Holvic is not responsible for the privacy practices or the content of such sites or services. If you are concerned about the privacy policy of a certain third party, we recommend that you read the privacy policy of the site or service to which you link before you submit any personal information. 

6.      YOUR RIGHTS RELATED TO PERSONAL INFORMATION 

You have certain rights regarding your personalinformation, subject to local data protection laws. These may include thefollowing rights: 

- to access your personal information held by us (right to access); to rectify inaccurate personal information and ensure it is complete (right to rectification);
- to erase/delete your personal information to the extent permitted by other legal obligations (right to erasure; right to be forgotten);
- to restrict our processing of your personal information (right to restriction of processing);
- to transfer your personal information to another controller to the extent possible (right to data portability);
- to object to any processing of your personal information carried out on the basis of our legitimate interests (right to object). Where we process your personal information for direct marketing purposes or share it with third parties for their own direct marketing purposes, you can exercise your right to object at any time to such processing without having to provide any specific reason for such objection;
- not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects ("Automated Decision-Making"). Automated Decision-Making currently does not take place on our websites; and
- to the extent we base the collection, processing and sharing of your personal information on your consent, to withdraw your consent at any time, without affecting the lawfulness of the processing based on such consent before its withdrawal. 

To exercise your rights, please contact us in accordance with the “Inquiries”section below. We try to respond to all legitimate requests within 30 days and will contact you if we need additional information from you in order to honor your request. Occasionally it may take us longer than a month, taking into account the complexity and number of requests we receive.  

Holvic enables you to review, update or correct your personal information in our possession.In order to do so, please log into your account or contact our Privacy Policy Administrator at privacy@considerbeyond.com. If you contact us, we will need sufficient information from you to establish your identity and to verify your access request, and also to assist us in handling your request.  

7.      SHARING FOR DIRECT MARKETING PURPOSES (“SHINE THE LIGHT”) 

If you are a California resident, once a calendar year, you may be entitled to obtain information about personal information that we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information, as well as the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year. To submit a request, contact us at privacy@considerbeyond.com 

8.      CONTENT REMOVAL FOR USERS UNDER 18 

Users of the Service who are California residents and are under 18 years of age may request and obtain removal of User Content they posted by contacting us at privacy@considerbeyond.com. All requests must be labeled “California Removal Request” on the email subject line. All requests must provide a description of the user Content you want removed and information reasonably sufficient to permit us to locate that User Content. We do not accept California Removal Requests via postal mail, telephone, or facsimile. We are not responsible for notices that are not labeled or sent properly, and we may not be able to respond if you do not provide adequate information. Please note that your request does not ensure complete or comprehensive removal of the material. For example, materials that you have posted may be republished or reposted by another user or third party. 

9.        RETENTION; Deactivated or Terminated Accounts 

When you sign up for an account with Holvic, Holvic retains personal information you store on our Service for as long as your account is in existence or as long as we need it to provide you our Service. If you delete your account, we will initiate deletion of this information after 30 days, but please note: (1) there might be some latency in deleting this information from our servers and back-up storage; (2) a request to delete and/or terminate your account will not result in the removal of information collected and already put in aggregate form; (3) we are not able nor are we obligated to remove any of your information from a third party provider or platform; and (4) we may retain your information if necessary to comply with our legal obligations, resolve disputes, or enforce our agreements. 

10.    OPTING OUT - DIRECT MARKETING COMMUNICATIONS PREFERENCES
 

If we process your personal information for the purpose of sending you marketing communications, you can manage your receipt of marketing and non-transactional communications from us by clicking on the “unsubscribe” link located on the bottom of our marketing emails, by replying or texting ‘STOP’ if you receive SMS communications, or by turning off push notifications on our apps on your device. Additionally, you may unsubscribe here or by contacting us using the information in the “Inquiries" section below. Note that opting-out of marketing communications does not opt you out of receiving important business communications related to your current relationship with us, such as information about your subscriptions, service announcements or security information. 

11.   INTERNATIONAL PRIVACY PRACTICES  

Personal information we collect may be stored and processed for the purposes set out in this Privacy Policy in the United States or any other country in which Holvic, its parents, subsidiaries, or third party agents operate. By using or accessing our Service, residents and citizens of countries and jurisdictions outside of the United States agree and consent to the transfer, storage and processing of your information on servers located in the United States and other countries that may not offer the same level of privacy protection as the laws in your country of residence or citizenship. In this event, we will ensure that such recipient offers an adequate level of protection, for instance by entering into standard contractual clauses for the transfer of data as approved by the European Commission (Art. 46 GDPR), or we will ask you for your prior consent to such international data transfers. 

12.     INQUIRES
             
If you have any questions regarding the data Holvic collects or how we use it, please feel free to e-mail us at privacy@considerbeyond.com.

13.      HOLVIC’S DATA PROTECTION OFFICER 

Holvic’s Data Protection Officer is responsible for matters relating to privacy and data protection. The Data Protection Officer can be reached at Holvic Inc., Attn:Data Protection Officer, [***].