Privacy Policy

Last Updated: June 28, 2018 

This Privacy Policy of HolistiCyber Ltd. and its wholly owned subsidiary, HolistiCyber Inc. (“HolistiCyber”, “we” or “our”) applies only to information, including personal information (collectively, “information”), collected by us from purchasers of our services (“Customers“), from visitors of our website, from persons who contact us offline, and that is otherwise obtained by us and does not apply to any information collected by our Customers, even if such information is processed by our Services. Information collected by our Customers shall be governed solely by the Customers’ respective privacy policies. 

“personal information” means any information that may be deemed as private, personal or personally identifying or identifiable data or information pursuant to applicable law, including, for example, your name, email address, location, user ID, contact information or credit card information. 

By visiting our website or purchasing our services you agree to comply with and be bound by this Privacy Policy. 

1. Collection of Information

When you visit our website or purchase our services, we collect your information, including your personal information, as follows: 

Information that You Provide Us. We collect the information that you enter on our website or when you purchase our services, such as your name, company name, email address, phone number and other contact information, credit card or other financial account information, and feedback. 

Information that is Collected Automatically. We automatically collect certain types of information when you visit and interact with us on our website. This information may include location and email address. If you purchase our services, your IP address, name, location, phone numbers, and hardware settings will also be stored in with other information about you in order to make certain functions available to you.  

Cookies, Web Beacons, and Similar Technologies. We use cookies, web beacons, and similar technologies for various reasons, such as to understand and save your preferences for future visits, and to compile aggregate data about site traffic and site interaction. The information collected by such cookie, web beacon, or similar technology may include your IP address, your operating system, the browser language, browser type and version, the requested page and the time of the access. If you choose to provide personal information to us, then this personal information may be linked to data stored in the relevant cookie, web beacon, or similar technology. 

Opting Out. You can prevent collection of your information by not providing us with such information and by ceasing to visit and interact with us on our website. 

2. How we use your information.

Use of Your information. We access and use your information, including your personal information, that is collected by us when you purchase our services or visit and interact with us on our website solely in order to provide you with responses to your queries,  information about us and our services, to provide you with our services, for our internal purposes, such as to understand traffic to our site, and to comply with any legal obligation we are subject to under applicable law.  

If you visit or interact with us on our website, our legal basis for processing your personal information is that it is necessary for our legitimate interest in providing and developing our services and meeting the requirements of our current and prospective customers. If you purchase our services, our legal basis for processing your personal information is that it is necessary for the performance of the agreement between you and us. 

Promotional Use. We may use your information to contact you by email or otherwise, to deliver promotional materials or updates in which you may be interested, or to provide you with newsletters that you may register to receive. With respect to such use, our legal basis for processing your personal information is that it is necessary for our legitimate interests in conducting direct marketing of our services to current and prospective customers.  

Unsubscribing. You may choose at any time to unsubscribe from our promotional materials and updates by letting us know at  or by clicking the unsubscribe link at the bottom of each promotional material or update.

3. Disclosure of Your Information 

To Whom We May Disclose Your information. We may disclose your information, including your personal information, as follows: (i) to payment processing services providers in order to process your payment for our services, (ii) to service providers that operate on our behalf and who agreed to adhere to terms consistent with this Privacy Policy, (iii) to a governmental, administrative or law enforcement authority, where we in good faith believe it is required to be disclosed by applicable law, or court order, (iv) to third parties in connection with a merger, acquisition, or sale of all or a portion of our assets, (v) where we in good faith believe it is necessary in order to protect our safety or rights, or those of a third party, including but not limited to in connection with fraud detection or prevention, or security or technical issues, or (vi) where we in good faith believe it is necessary in order to enforce the provisions of this Privacy Policy or of our agreement with you. 

We will not disclose your information, including your personal information, to any third party or for any purpose except for those set forth in this Privacy Policy (as may be amended from time to time pursuant to Section 9 below), unless we have received your express written consent to such disclosure. 

Third Party Privacy Policies. Upon your information being shared with our payment processing and other service providers, we will treat this information according to the terms of this Privacy Policy, and the relevant payment processing or other service provider will treat it according to the terms of its own privacy policy. 

Third-Party Opting Out. If we disclose your information to a third party, you will need to be in direct contact with that third party in connection with any concern, question, request or demand that you may have in connection with such third party’s use or disclosure of your information. If you would like to request further details about the third parties to which your information may have been disclosed, please contact us at  

4. Information Security

We use commercially reasonable efforts, applying physical, electronic and procedural safeguards, to maintain and protect the confidentiality of all information collected by us, including your personal information, and to protect it from unauthorized access, disclosure or destruction. We allow only authorized personnel to access your information, on a need-to-know basis. 

Although we make good faith efforts to store your information in a secure operating environment, we cannot guarantee security. You understand and agree that all information collected through our website or in connection with your purchase of our services is at your own risk and is subject to the provisions and disclaimers of both this Privacy Policy and our agreement with you. 

In the event that we become aware of any accidental or unauthorized access to your information, we will use commercially reasonable efforts to notify you of such data breach. 

5. Transfer of Information to a Different Jurisdiction

HolistiCyber operates internationally and may process your information outside your country of residence, including outside the European Economic Area. We may decide to transfer information to a different jurisdiction at our sole discretion. In the event of such transfer we will ensure that it takes place in accordance with applicable law. 

6. Inquiries or Complaints

If you have an inquiry or complaint about this Privacy Policy or our information collection practices, please contact us at 

You may also have the right to lodge a complaint with a supervisory authority located in the EU. 

7. Retention of your information

If you purchase our services, we may retain your information throughout the term of our agreement with you and afterwards we may retain it in order to accommodate your choices regarding marketing and promotional materials. If you visit or interact with us on our website, we may retain your information in order to accommodate your choices regarding marketing and promotional materials. If you would like to contact us in connection with this Privacy Policy, including to request deletion of your information that is stored on our systems, please contact us at , detailing your request. In such event, your information will be deleted from our active database but a copy of such information, generated by our automated computer archival back-up systems, may remain in our archives for a period of up to 24 additional months. If we are required to maintain certain information about you, we will comply with your deletion request after fulfilling any legal requirements. We will ensure the confidentiality of any information retained by us in any of the circumstances described above. 

8. Rights You May Have

You may have certain rights in relation to personal information we collect about you under applicable law. These rights do not necessarily apply to all purchasers of our services or visitors to our websites. These include the right to request access to your personal information, that it be erased, that its processing be restricted, or that any inaccurate personal information be rectified. You may also have the right to object to the processing of your personal information, and under certain circumstances to obtain a copy of the personal information in machine readable format (portability right). Any such request may be submitted in writing to  

9. Updates

From time to time, we may update this Privacy Policy, and your continued use of our services and/or our website will signify your express agreement to such updated Privacy Policy. We will post any Privacy Policy changes prominently on our website, and in some cases, in our sole discretion, we may notify you by email of any changes. 

You agree to accept posting of a revised Privacy Policy electronically on our website as actual notice to you. We encourage you to periodically check for Privacy Policy updates. 

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