Hollox Privacy Policy

Version 1.0, last updated: january 4, 2022

Welcome to Hollox. The Privacy Policy stipulates the types of information of yours that we may collect through your log into this Website, your registration with this Website, and/or use the services we offer, as well as how we shall use and protect the information so collected. This section will assist you in understanding how we collect, use, store, disclose and protect personal information.

To protect your rights, please read the following thoroughly and contact us with any questions regarding our Privacy Policy.

Your consent

Your consent to Hollox’s processing and protecting your personal information according to the Privacy Policy is implied upon your use of the services of this website.

(a) You agree that Hollox may process personal information provided by you and hereby consent to the transmittal of your personal data outside the AFC Economic Area.

(b) You hereby acknowledge and agree that Hollox shall process personal information provided by you the purpose of performing our obligations under this Privacy Policy and for the purpose of administering the relationship between you and us. We may share your personal information with third parties in order to provide you with our services and improve our product and services in line with the applicable laws and our Privacy Policy. Hollox will not disclose your personal information to any third party without your prior consent and/or without having a legal basis to do so. 

(c) You agree that Hollox may pass information about you which you have provided to Hollox to other companies in Hollox’s group and to external companies to help Hollox to process and/or analyse it as part of the provision of services to you. 

(d) In the event that you consented for the use of personal data by Hollox for marketing and information management purposes, or to conduct market research for Hollox then Hollox may share these data with other companies in its group or with carefully selected external parties that may use the personal data to bring to the attention of the Client products and services that may be of interest to the Client and also to assist in the efficient provision of services. 

Your rights

You have a right to: 

• (a) Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can ask for your personal data by contacting privacy@hollox.finance. 
• (b) Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you completed or corrected, though we may need to verify the accuracy of the new data you provide to us. 
• (c) Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• (d) Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.
• (e) Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (i) if you want us to establish the data’s accuracy; (ii) where our use of the data is unlawful but you do not want us to erase it; (iii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• (f) Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• (g) Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Data we collect and why we collect it

• A. Required data

• (a) Biographical

Such as name, mail address, phone number, country, full address, date of birth and other related biographical data. We collect this information in order to identify you in our systems for a variety of reasons including fraud protection, and certain financial regulations in various jurisdictions.

 

• (b) Device identifiers

Such as IP addresses, cookies for user device authentication and other similar device identifiers.  This information is collected to identify you in our systems for a variety of reasons including fraud protection, and certain financial regulations in various jurisdictions. This information also helps keep your account secure, so we can keep a track of where your account has been accessed from. Logging your IP address also allows Hollox to offer you the best experience possible by determining your location for offer matching.

 

• (c) Hollox account details

Such as username, user profile Information in the “Bio” section, profile picture, joined date, default currency, time zone, default language and other related account details, to ensure you have the best experience possible on our platform. This information also allows other users to interact with you in easier ways.

 

• (d) Hollox account activity

Such as trade chat messages, trade chat attachments, trade activity, transaction history, affiliate name, affiliate ID, affiliate link, affiliate transactions, offers created, offer terms, trade instructions, account notifications, and other related account activities. This information is collected to provide you with improved user experience, as well as feedback for you, your account activity helps other users interact with you on Hollox easier. We also store this data in order to analyse transactions that may be in a dispute or other inquiry.

 

• B. Other data we may require

• (e) KYC documents

Such as ID, proof of address, selfie with ID, video and other related KYC Documents.  These documents are uploaded by customers who wish to verify their identity on the Hollox platform. This identity verification process allows you to have higher trade limits, and to have more access to offers on the platform.

All the aforementioned general categories of data may contain data that by itself does not identify you and is therefore not deemed as personal data.

 

How Long We Hold This Data

Hollox holds your account data indefinitely. This is because all account data is associated with financial transactions which may need to be referenced by government authorities. Hollox never sells this data or shares this data. All data is stored in encrypted servers.  When you close/delete your account, we will delete your informations after 15 days All data is stored in encrypted servers. 

 

 

Protection of personal data

• (a) We adopt appropriate electronic, management and technical measures so as to protect and safeguard the security of your personal data. We will, to the greatest extent possible, ensure that any personal data collected through our Website shall be free from being subject to nuisance by any third party unrelated to us. The security measures that we may take include but are not limited to:

- Electronic measures: The computer data that contain your personal information will be stored in computer systems and storage medias that are subject to strict login restrictions.

- Management measures: only staff members duly authorized by us can access your personal data, and these staff members shall comply with our internal code concerning personal data confidentiality.

- Technical measures: such encryption techniques as Secure Socket Layer Encryption may be used to convey your personal data.

- Other measures: our network servers are protected by proper 'firewall '.

• (b) If you are aware of any security flaws in our Website/MobileApp, please contact us immediately so that we can take appropriate action as soon as possible. 
• (c) Despite of the above-mentioned technical and security measures, we cannot guarantee that the information transmitted via the Internet is absolutely safe, so we cannot absolutely guarantee that the personal data that you provide to us through our Website/MobileApp will be safe at any time. We will not be held liable for any loss or damage arising from or caused by any event that may occur in connection with unauthorized access to your personal data, and we shall not be held liable for compensation for such loss or damage. 

 

Questions and concerns 

If you have any questions about this Privacy Policy or the use of your Personal Data, please contact our Data Privacy Officer by sending an email to privacy@hollox.finance with the subject “PRIVACY REQUEST”.

 

Additional contacts:

If you are unsatisfied with our response, you can reach out to the applicable data protection authority for GDPR purposes:
The Office of the Privacy Commissioner for Personal Data, Telephone: +234 01 454 3233;
E-mail: privacy@hollox.finance
You also have a right to complain to the data protection regulator in the country where you live or work.

 

Modifications to the Privacy Policy

Any changes we may make to our Privacy Policy in the future will be posted on this page and when appropriate we will notify you by email.