Privacy Policy

1. Information We Collect

1.1 Personal Information

• Contact Information: Name, email address, phone number
• Account Information: Username, password, profile preferences
• Business Information: Business name, address, industry type
• Transaction Data: Visit history, points earned/redeemed, purchase behavior

1.2 Automatically Collected Information

• Usage Data: How you interact with our platform
• Device Information: IP address, browser type, device identifiers
• Location Data: General location for service delivery (with consent)
• Cookies and Tracking: For platform functionality and analytics

2. How We Use Your Information

2.1 Service Delivery

• Operate and maintain loyalty programs
• Process rewards and incentives
• Track customer engagement and visits
• Provide customer support

2.2 Communications

• Send SMS and email notifications about rewards
• Share promotional offers and campaigns
• Deliver program updates and announcements
• Send transactional messages (receipts, confirmations)

2.3 Platform Improvement

• Analyze usage patterns to enhance features
• Conduct research and development
• Ensure platform security and fraud prevention
• Generate aggregated, anonymized insights

3. SMS and Communication Practices

3.1 Consent Collection

We obtain consent for SMS communications through:

• Explicit opt-in during loyalty program registration
• Clear disclosure of message types and frequency
• Double opt-in verification for promotional messages
• Separate consent for different message categories

3.2 Message Types and Frequency

• Transactional: Account updates, reward notifications (as needed)
• Promotional: Special offers, campaigns (2-4 per month)
• Informational: Program updates, policy changes (rarely)

3.3 Opt-Out Rights

Users can stop SMS messages by:

• Replying "STOP" to any message
• Updating preferences in their account
• Contacting support at hello@hollusta.com
• Using unsubscribe links in email communications

4. Information Sharing and Disclosure

4.1 We Never Sell Your Data

Hollusta does not sell, rent, or trade personal information to third parties for their marketing purposes.

4.2 Limited Sharing Scenarios

• Business Partners: With participating businesses for program operation
• Service Providers: With trusted vendors who help operate our platform (like Twilio for messaging)
• Legal Requirements: When required by law or to protect rights and safety
• Business Transfers: In case of merger, acquisition, or asset sale

4.3 Data Security

We implement industry-standard security measures including:

• Encryption of data in transit and at rest
• Regular security audits and monitoring
• Limited access controls and authentication
• Secure data centers and infrastructure

5. Your Rights and Choices

5.1 Access and Control

• Access: Request copies of your personal information
• Correction: Update inaccurate or incomplete data
• Deletion: Request removal of your information
• Portability: Receive your data in a portable format

5.2 Communication Preferences

• Manage SMS and email preferences in your account
• Opt out of specific message types
• Adjust notification frequency
• Completely unsubscribe from all communications

6. Third-Party Services

Our platform integrates with third-party services including:

• Twilio: For SMS messaging services
• Analytics Providers: For usage insights and optimization
• Payment Processors: For subscription and payment handling
• Cloud Providers: For hosting and data storage

7. Contact Information

8. California Privacy Rights (CCPA)

California residents have additional rights under the California Consumer Privacy Act, including the right to know about personal information collection, opt-out of sales (though we don't sell data), and non-discrimination for exercising privacy rights.

9. European Privacy Rights (GDPR)

For users in the European Union, we process data under lawful bases including consent, legitimate interests, and contractual necessity. You have additional rights including data portability and the right to object to processing.