Privacy policy

Preamble

With the following privacy policy, we would like to explain to you what types of your personal data (hereinafter also referred to as "data") we process, for what purposes and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context of the provision of our services on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as "online offer").

We ask you to inform yourself regularly about the content of our privacy policy. We will adapt the privacy policy as soon as changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.

If we provide addresses and contact information of companies and organisations in this privacy policy, please note that the addresses may change over time and please check the information before contacting us.

The terms used are not gender-specific.

Status: 23 July 2024

Table of contents

  1. Preamble

  2. Person responsible

  3. Contact Data Protection Officer

  4. Overview of processing activities

    1. Purposes of processing

    2. Data categories

    3. Legal basis

  5. Safety measures

  6. Transmission of data, international data transfers

  7. Deletion of data

  8. Rights of the data subjects

  9. Use of cookies and similar technologies

    1. Cookies and similar technologies

    2. Protection of your privacy

    3. Necessary data processing

    4. Optional data processing

  10. Special notes on the mobile application

    1. Device permissions

    2. Appstores

  11. The processing activities in detail

    1. Provision of the online offer and web hosting

    2. Registration, login and user profiles

    3. Community functions and contributions

    4. Collaboration and communication tools

    5. Notifications (push, in-app, e-mail)

    6. Embedded partner content

    7. Contact and enquiry management

    8. Newsletter

    9. Surveys and interviews

    10. Usage analytics

    11. Presence in social networks (social media)

Person responsible

The controller responsible for the processing of your personal data as explained in this privacy policy is

Holi Moli GmbH
Eifflerstrasse 43
22769 Hamburg
Germany

Authorised representative: Piet Mahler

E-mail address: support@holi.social

Imprint: https://holi.social/imprint

Contact data protection officer

Our data protection officer, who you can contact with any questions about data protection, can be reached using the following contact details:

ISiCO Data Protection GmbH
Am Hamburger Bahnhof 4
10557 Berlin, Germany

E-mail address: holi.social@isico-datenschutz.de

Overview of processing activities

Below you will find an overview of the data processing that takes place in our online offering with regard to the purposes, data categories and legal bases of the processing.

Processing purposes

Data categories

Legal basis

Relevant legal bases according to the General Data Protection Regulation (GDPR): Below you will find an overview of the legal bases of the GDPR on the basis of which we process your personal data.

Safety measures

We take appropriate technical and organisational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to your rights and freedoms, in order to ensure a level of protection appropriate to the risk.

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access, input, disclosure, safeguarding availability and separation of your data. Furthermore, we have established procedures that guarantee the exercise of data subject rights and the deletion of data. We also take the protection of personal data into account when developing and selecting hardware and software.

We use TLS encryption to protect your data transmitted to our servers via our online offering. You can recognise such encrypted connections by the prefix https:// in the address bar of your browser.

Transmission of data, international data transfers

As part of our processing of personal data, the data may be transferred to other bodies, companies, legally independent organisational units or persons or disclosed to them. The recipients of this data may include, for example, contracted IT service providers or providers of services and content that are integrated into a website/App. In such cases, we observe the legal requirements and in particular conclude corresponding contracts or agreements with the recipients of your data. Information on the individual service providers can be found in the section on processing activities.

If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or if the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, bodies or companies, this is done in accordance with the legal requirements (Art. 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de ). This means the following in particular:

Subject to express consent or transfer required by contract or law (Art. 49 GDPR), we only process or have the data processed in third countries with a recognised level of data protection within the framework of an adequacy decision (Art. 45 GDPR), in the presence of and compliance with contractual obligations through so-called standard protection clauses of the EU Commission (Art. 46 para. 2 lit. b) GDPR), in the presence of certifications (Art. 46 para. 2 lit. f) GDPR) or binding internal data protection regulations (Art. 46 para. 2 lit. b) GDPR).

In the particularly important case of data transfer to the USA, the so-called "EU-U.S. Data Privacy Framework" (DPF) applies, with which the EU Commission has issued an adequacy decision for certified companies from the USA. The list of certified companies as well as further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ . Information in English and other languages can be found on the website of the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/eu-us-data-transfers_en . We will inform you in detail in the following section about the companies we use that are certified under the EU-U.S. Data Privacy Framework.

Deletion of data

The data processed by us will be deleted in accordance with the legal requirements. This means that data will be deleted without a request from you if the purpose for processing this data no longer applies or if it is no longer required for the purpose. If data storage is subsequently required for other legally required or authorised purposes, processing will be restricted to these purposes, i.e. the data will be blocked for active processing and moved to an archive with restricted access rights. This applies, for example, to data that must be stored for commercial or tax law reasons or whose storage is necessary for the assertion, exercise or defence of legal claims or to protect the rights of another natural or legal person.

Rights of the data subjects

As a user of our online offer and data subject, you are entitled to various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:

To assert your rights described here, you can contact us or our data protection officer at any time using the contact details above.

Use of cookies and similar technologies

Cookies and similar technologies

Tools used by us can use technologies to store information on your device or read information from your device. This serves, for example, to ensure the functionality, registration and authentication, the security and convenience of our online offer or to analyse your use. The following technologies may be used, for example:

Most browsers are set by default to accept cookies, the execution of scripts and the display of graphics. However, you can usually adjust your browser settings so that all or certain cookies are rejected or scripts and graphics are blocked. If you completely block the storage of cookies, the display of graphics and the execution of scripts, our services may not work or may not work properly.

Protection of your privacy

We use tools in accordance with the statutory provisions (Section 25 of the German Telemedia and Telecommunications Data Protection Act - TTDSG). We therefore generally obtain prior consent from the users (hereinafter: Optional data processing); exceptionally, consent is not required if the storage and reading of the information is absolutely necessary in order to provide the users with a telemedia service expressly requested by them (i.e. our online offering) (hereinafter: Necessary data processing). The absolutely necessary tools generally include functions that serve the display and operability of the online offer, load balancing, security, storage of the user's preferences and selection options or similar purposes related to the provision of the main functions of the online offer requested by the user. The revocable consent is clearly communicated to the users and contains the information on the respective tool use.

The cookies and similar technologies we use are listed in detail below.

Necessary data processing

Currently, the following necessary information is stored on your device, which does not require consent:

Optional data processing

To personalise the offer and analyse platform performance, the following information is also stored on your device after you have given your consent. Further information on this can be found below.

Special notes on the mobile application

Below you will find information on the special features of data processing when using our mobile application (hereinafter: app).

Device permissions

The use of our app may require user authorisations for access to certain functions of the devices used or to the data stored on the devices or accessible with the help of the devices. By default, these permissions must be granted by the users and can be revoked at any time in the settings of the respective devices. The exact procedure for controlling app permissions depends on the device and the user's software. Users can contact us if they require clarification. We would like to point out that the denial or revocation of the respective authorisations may affect the functionality of our app.

Appstores

Our app is obtained via special online platforms operated by other service providers (so-called "app stores"). In this context, the data protection notices of the respective app stores apply. This applies in particular with regard to the procedures used on the platforms to measure reach and for interest-based marketing as well as any obligation to pay costs. The processing is carried out under the sole responsibility of the operators of the app stores. The specific data processed, the purposes of the processing and the legal bases can be found in the corresponding data protection notices of the respective app stores:

The processing activities in detail

We collect and process personal data in particular for the purpose of providing and improving our online offering. Third-party providers store and process data exclusively on our behalf. Data processing that is not absolutely necessary, such as access to the photo library to optionally upload a photo/video, or the evaluation of click behaviour to analyse and personalise the offer, only takes place with your prior consent.

A detailed description of which data is collected and processed for which purposes can be found below.

Provision of the online offer and web hosting

We process personal data in order to provide you with a user-friendly and high-performance online service. The processed data includes technical data collected during use, communication and metadata as well as consent information for the use of cookies and similar technologies. In detail, we distinguish between the following processing operations:

Registration, login and user profiles

We process personal data in order to register users for our online services and to create a user account for them in which they can log in. Registration and login are necessary in order to use services such as Spaces or to participate in the community functions described below. The data processed includes login information (user name, password and an e-mail address). In order to make profitable use of the community functions described below, we also ask users to create a meaningful user profile and provide some personal information, such as voluntarily entering a surname, selecting relevant interests from a selection of social and ecological topics, as well as the matching SDGs (Sustainable Development Goals of the UN), specifying suitable skills, and specifying the location of use at the level of a city/town.

A profile picture can also be created, for which access to the photo library must be granted in the app. The holi.social app only uses images or photos from users' image libraries if users decide to use certain functions, such as displaying their photo/avatar on their profile, setting an avatar or cover image for their space, publishing posts or managing tasks and appointments. It should be emphasised that the provision of images for these functions is entirely in the hands of the user. Nevertheless, this improves the user experience and makes it possible to gain more benefits from our services, such as better visibility for making connections, sharing posts, participating in events and finding volunteers and partners for projects. If users have cancelled their user account, their data with regard to the user account will be deleted, subject to legal permission, obligation or consent of the users. With regard to the deletion of contributions, see "Community functions".

We use the following service provider for the provision and registration.

Community functions and contributions

We process personal data in order to provide users with the community functions and to display posts. The community functions we provide allow users to enter into conversations or otherwise interact with each other. For example, they can publish their own contributions (text, images, link posts), submit reactions and comments on posts or articles or publish video contributions on social and ecological challenges. User contributions are generally public, i.e. visible and accessible to all other users. However, users can use settings to determine the extent to which the posts and content they create are visible or accessible to the public or only to certain people or groups.

Please always note that the use of the community functions is only permitted in compliance with the applicable legal situation, our terms and conditions and guidelines as well as the rights of other users and third parties. In the event of illegal posts (e.g. insults, prohibited political propaganda, etc.), these, as well as technical data such as IP address and access times, are stored for evidence purposes. This is done in order to be able to take appropriate measures to protect other users and the community. In addition, the posts are deleted or removed from visibility for all other users.

Collaboration and communication tools

We process personal data in order to provide users with collaboration and communication tools. One aim of our platform is to make it easier for groups and initiatives to plan and organise projects together in the context of social and ecological transformation. We provide digital collaboration spaces for this purpose. Within these spaces, we offer participants various collaboration and communication tools. The aim of these offerings is in particular to ensure and simplify work organisation measures for the joint work of users, groups of people, teams and initiatives as well as communication management.

In detail, we distinguish between the following processing operations:

Notifications (push, in-app, e-mail)

Users of our platform are notified or informed about content and news relevant to them personally via various channels. Different channels can be used depending on the urgency of the notification. While most information is transmitted via the information centre contained in the app (or website), information that requires a response from the user, for example, is also transmitted by email. With prior consent, we can also send users so-called "push notifications" to draw their attention to particularly important information. These are messages that are displayed on users' screens, end devices or browsers, even if our online service is not currently being actively used.

To register for the push notifications, users must confirm the request from their browser or device to receive the push notifications. This consent process is documented and saved. The storage is necessary to recognise whether users have agreed to receive the push notifications, to be able to send the push notifications and to be able to prove their consent. Users can change the receipt of push notifications at any time using the notification settings of their respective browsers or devices.

A pseudonymous identifier (so-called "push token" or "push key"), the app installation ID and/or the device ID of a device are used and stored for the purpose of sending the notifications. These help us to assign the push messages to your device and your app and to send them to the correct device.

The following service providers are used to send the notifications.

Embedded partner content

We incorporate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). These may be, for example, graphics, videos or city maps (hereinafter uniformly referred to as "content"). The integration always presupposes that the third-party providers of this content process the IP address of the users on their own responsibility, as they would not be able to send the content to their browser without the IP address. The IP address is therefore required to display this content or function.

We endeavour to only use content whose respective providers only use the IP address to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The third-party providers are responsible for the associated data processing. In this respect, we refer to the data protection notices of the respective providers.

Among other things, content from the following third-party providers is regularly integrated into our online offering:

Contact and enquiry management

We process personal data when you contact us (e.g. by post, contact form, email, telephone or via social media). Technical data and the information you provide yourself will be processed insofar as this is necessary to respond to the enquiry.

We use the following service provider for this purpose:

Newsletter

We process personal data to send our newsletter by email about new features of our online offering, promotions, events and offers. We also measure the opening and click rates of the newsletter to improve the technical quality and content of our newsletter. For this purpose, the emails contain a so-called "web beacon", i.e. a pixel-sized file that is retrieved from the server when the newsletter is opened. As part of this retrieval, information about the browser and operating system, your IP address and the time of retrieval are collected. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. Registration for our newsletter takes place in a so-called double opt-in procedure, i.e. after registration you will receive an e-mail in which you will be asked to confirm your registration. This confirmation is necessary so that no-one can register with other people's email addresses. To subscribe to our newsletters, it is generally sufficient to enter your e-mail address. However, we ask you to provide a name so that we can address you personally in the newsletter, or other information if this is necessary for the purposes of the newsletter. In the event of obligations to permanently observe revocations, we reserve the right to store the e-mail address in a block list for this purpose alone.

We use the following service provider for data processing in connection with the newsletter:

Surveys and interviews

We process personal data in connection with occasional surveys and interviews. The surveys and questionnaires we conduct are analysed anonymously. Personal data is only processed to the extent that this is necessary for the provision and technical implementation of the surveys (e.g. processing of the IP address to display the survey in the user's browser or to enable the survey to be resumed with the help of a cookie).

We use the following service providers for the surveys:

Usage analytics

We process personal data with your prior consent in order to record and analyse your use. The purpose of the evaluation is to analyse and continuously improve the use of our platform. In detail, we distinguish between the following processing operations:

We use the following service providers for the aforementioned processing operations:

The personal data processed in the aforementioned processing operations will not be passed on for any purposes other than those stated and will not be processed by recipients for their own purposes.

Presence in social networks (social media)

We maintain online presences within social networks and process user data in this context in order to communicate with the users active there or to offer information about us. We would like to point out that user data may be processed by the operators of social networks outside the European Union. This may result in risks for users because, for example, it could make it more difficult to enforce users' rights.

Access to aggregated statistics

As part of the operation of our online presences, we may have access to information such as statistics on the use of our online presences provided by the social networks. These statistics are aggregated and may include, in particular, demographic information (e.g. age, gender, region, country) as well as data on interaction with our online presence (e.g. likes, subscriptions, shares, viewing of images and videos) and the posts and content distributed via it. This may also provide information about the interests of users and which content and topics are particularly relevant to them. This information can also be used by us to adapt the design and our activities and content on the online presence and to optimise it for our audience. Details and links to the social networks on which we are present can be found in the list below. The collection and use of these statistics is generally subject to joint responsibility. Where this applies, the relevant contract is listed below.

The legal basis for data processing is Art. 6 para. 1 sentence 1 lit. f) GDPR, based on our legitimate interest in effective information and communication with users, or Art. 6 para. 1 sentence 1 lit. b) GDPR, in order to stay in contact with our customers and inform them and to carry out pre-contractual measures with interested parties.

Communication via the social network:

In addition, the social network may allow us to get in touch with you. This can take place, for example, via direct messages or posted contributions. The content of communication via the social network and the processing of content data is the responsibility of the social network as a messenger and platform service. This is then the telecommunications provider.

Processing for market research and advertising purposes:

Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, user profiles can be created on the basis of user behaviour and the resulting interests of users. The user profiles can in turn be used, for example, to place adverts inside and outside the networks that presumably correspond to the interests of the users. For these purposes, information is usually also read or stored on the user's device. Furthermore, data can also be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).

Processing for market research and advertising purposes is carried out by the social networks under their own responsibility. You can find the legal basis for this in the data protection information for the respective social network. For a detailed description of the respective forms of processing and the opt-out options, please refer to the privacy policies and information provided by the operators of the respective networks.

Assertion of your rights as a data subject:

In the case of requests for information and the assertion of data subject rights, we would also like to point out that these can be asserted most effectively with the providers of the social networks. Only the providers have access to the users' data and can take appropriate measures and provide information directly. You can also contact us with your request. In this case, we will process your enquiry and forward it to the provider of the social network.

We are active on the following social networks:

Possibility of objection (opt-out):
https://privacy.xing.com/de/datenschutzerklaerung