Privacy Policy

TMRW Spain S.L. (HOLOH)
FAIR PROCESSING NOTICES

1. Clients/Users

1.1 APPROPRIATE COMMUNICATION CHANNELS:
HOLOH's website, through a clear link(e.g., 'Privacy notice') accessible from the homepage, and preferably from all pages.

1.2 NOTICE CONTENTS:

TMRW Spain S.L (Av. Jean Claude Combaldieu, Nº5, 03008 Alicante, Spain, HOLOH)collects and processes personal data on you if you (or your company, which you representor for which you act as a contact person or user) are an actual, former or prospective clientof HOLOH, or a user of HOLOH products and services.

HOLOH acts as the controller of such processing and is committed to respecting yourprivacy and protecting your personal data in accordance with the law, in particular the EUGeneral Data Protection Regulation 2016/679 (GDPR).

PROCESSING PURPOSES. The processing of your data is based on the following grounds:

PURPOSE OF PROCESSING & GDPR LEGAL BASIS

HOLOH processes your data:* to manage your or your company's subscription to ourproducts and services and the onboarding process

The processing is necessary:

in order to take steps prior to entering into a contract with you or your company
for purposes of legitimate interests pursued by HOLOH (that is, client/prospectmanagement)
to manage the delivery of products and services you or your company have orderedor use, to manage your use of such products and services, including payments andother transactions you make through our products and services, as well as forbilling, accounting and administrative management purposes

The processing is necessary:

for the performance of a contract with you or your company
to comply with legal obligations to which HOLOH is subject
for purposes of legitimate interests pursued by HOLOH (that is,product/service delivery and improvement, client and user transactions andmanagement

for marketing (including client relationship management, subscription to newsletter,alerts and marketing materials, social media, communities and eventmanagement), business intelligence and product/services improvement purposes

The processing is necessary:

for purposes of legitimate interests pursued by HOLOH (that is, marketing,business intelligence and product/services improvement)

to manage and analyse your interactions with our website and products (see cookiepolicy) The processing is necessary:

for purposes of legitimate interests pursued by HOLOH (that is, businessintelligence, product and website management and improvement) Inexceptional cases, HOLOH may need your consent for certain processingoperations (which is not the case for the processing purposes detailedabove). In such case, HOLOH will ask for your consent separately.

DATA CATEGORIES. In addition to the information you have communicated to HOLOHdirectly or through your company, HOLOH may collect and process the following categoriesof personal data:

identity/details (contact person, company, phone, email, address, social mediadetails, personal interests),
account details (subscription details, subscribed options/products/services),credentials (login, password, security data, OTP), account profile (license/accounttype, profile picture and details, contact list),
products/services data (information provided through online form,products/services ordered/used, communications contents, audio/videosrecordings, clickstream data),
technical data (user account details, email, browser/devices/applications used,issue description by user, technical measures/recommendations, user follow up,technical support query status),
user interactions with products/services, use of product, server logfiles, identifiers(user name, IP address, email address, connection logfiles, cookies),
newsletter subscription form/details, social media user subscriptions, and
if you take part in events organised by HOLOH: invitees lists, significant other, eventmanagement data (no shows, venue, catering/food allergies where specified byyou), photos/videos. Where you provide personal data on third-parties (whetheryour employees, users or relatives) to HOLOH you should make sure you haveinformed them accordingly.

DATA RECIPIENTS. HOLOH may share your data with affiliated or third-party serviceproviders as necessary to deliver the products/services to you and other purposes listedabove, as well as to competent local authorities (tax authorities, regulators, lawenforcement agencies), external auditors, payment providers, banks and, where applicable(events) communication agencies and event management providers (venue, catering,security).

DATA TRANSFERS OUTSIDE THE EU/EEA. HOLOH may transfer your personal data outsideof the EU/EEA, including to countries which do not have a similar level of protection ofpersonal data as the EU. In such case, and in accordance with GDPR, data transfers will:

be limited to what is necessary to perform the contract with you, or conclude acontract with a third-party in your interest, or
be justified by the establishment, exercise or defence of legal claims, or
if appropriate, be covered by appropriate safeguards, such as entering into ECapproved standard contractual clauses, or
in exceptional cases, take place with your consent. In such case, HOLOH will ask foryour consent separately.

DATA RETENTION. HOLOH will retain your personal data for as long as required to deliverthe products/services you or your company have ordered or use, and/or for the mandatoryretention duration set forth by applicable law (up to 10 years after the termination of ourrelation for certain accounting and contractual data).

YOUR STATUTORY RIGHTS. You have certain rights concerning your personal data underGDPR as mentioned below, and can exercise them by contacting HOLOH atdataprotection@holoh.com.

Right to information. If you are a client-related third party (e.g., an employee of acorporate client), HOLOH may not have your current details and thus cannotcontact you conveniently and in confidentiality. You can find updated information onHOLOH's processing of your data at any time on this websitehttps://holoh.com/privacypolicy, or by contacting HOLOH atdataprotection@holoh.com.
Access right. You have the right to access your personal data. HOLOH processes alarge quantity of information, and can thus request, in accordance with GDPR, thatbefore the information is delivered, you specify the information or processingactivities to which your request relates.* Right to rectification. You can ask HOLOH to rectify, correct or update inaccurate and/or incorrect data.
Other rights. In certain limited cases (in which case HOLOH will first analysewhether the conditions for the exercise of such rights are fulfilled, in line withGDPR), you may object to, or request the limitation of, the processing of yourpersonal data, or request the erasure or portability of your personal data. WhereHOLOH asked for your consent to a specific processing, you have the right towithdraw such consent at any time (for future processing). You should note that thelaw authorizes HOLOH to retain and continue processing certain personal data,even where you have exercised your rights to object or erasure or -if applicable-withdrawn your consent: this is the case in particular where HOLOH has legitimateand compelling reasons for continuing the processing, such as compliance withapplicable law. Finally, you can contact the Spanish data protection authority(Agencia Española proteccion de datos AEPD) to introduce a claim. Agencia Española de Protección de Datos | AEPD.

Contact. You can contact HOLOH's Data Protection team here:

TMRW Spain S.L.
Av. Jean Claude Combaldieu, Nº5, 03008 Alicante, Spain.
Email: dataprotection@holoh.com

2. External Staff/Consultants

2.1 APPROPRIATE COMMUNICATION CHANNELS:

HOLOH's intranet (if any, and ifconcerned data subjects have access thereto) or website, through a clear link (e.g., 'Privacynotice') accessible from the homepage, and preferably from all pages.

2.2 NOTICE CONTENTS:

TMRW Spain S.L. (Av. Jean Claude Combaldieu Nº5, Alicante, Spain, HOLOH) collects andprocesses personal data on you if you (or your company) are an actual, former orprospective supplier of HOLOH.

If you are detached to HOLOH, please also refer to the Privacy Notice concerning HOLOH'semployees as some of processing operations detailed therein might also apply to yourpersonal data.

PROCESSING PURPOSES. The processing of your data is based on the following grounds:

PURPOSE OF PROCESSING & GDPR LEGAL BASIS

HOLOH processes your data:* to manage the contractual relation with you or yourcompany, the services you deliver, as well as for billing, payment and accounting purposeThe processing is necessary: * in order to take steps prior to entering into a contract withyou or your company, or to perform such contract * for purposes of legitimate interestspursued by HOLOH (that is, supplier management)

to comply with legal obligations to which HOLOH is subject
for supplier onboarding purposes, including granting you access to HOLOH's ITsystems as applicable

The processing is necessary:

in order to perform a contract with you or your company
for purposes of legitimate interests pursued by HOLOH (that is, suppliermanagement, IT systems and security management)

for communication and marketing purposes

The processing is necessary:

for purposes of legitimate interests pursued by HOLOH (that is,communications and marketing)

In exceptional cases, HOLOH may need your consent for certain processing operations(which is not the case for the processing purposes detailed above). In such case, HOLOHwill ask for your consent separately.

DATA CATEGORIES. In addition to the information you have communicated to HOLOHdirectly or through your company, HOLOH may collect and process the following categoriesof personal data:

identity/details (name, contact details),
work done, tariffs/expenses, time spent, bank details, invoice payment status,
pictures, photos, videos, articles, contributions, and
if you take part in events organised by HOLOH: invitees lists, significant other, eventmanagement data (no shows, venue, catering/food allergies where specified byyou), photos/videos.

Where you provide personal data on third-parties (whether your employees, users orrelatives) to HOLOH you should make sure you have informed them accordingly.

DATA RECIPIENTS. HOLOH may share your data with affiliated or third-party serviceproviders as necessary to receive and use the products/services you deliver and otherpurposes listed above, as well as to your company, competent local authorities (taxauthorities, regulators, law enforcement agencies), external auditors, payment providers,banks and, where applicable (events) communication agencies and event managementproviders (venue, catering, security).

DATA TRANSFERS OUTSIDE THE EU/EEA. HOLOH may transfer your personal data outsidethe EU/EEA, including to countries which do not have a similar level of protection ofpersonal data as the EU. In such case, and in accordance with GDPR, data transfers will:

be limited to what is necessary to perform the contract with you, or conclude acontract with a third-party in your interest, or
be justified by the establishment, exercise or defence of legal claims, or
if appropriate, be covered by appropriate safeguards, such as entering into ECapproved standard contractual clauses, or
in exceptional cases, take place with your consent. In such case, HOLOH will ask foryour consent separately.

DATA RETENTION. HOLOH will retain your personal data for as long as required to managethe products/services you or your company provide to HOLOH and related payments,and/or for the mandatory retention duration set forth by applicable law (up to 10 years afterthe termination of our relation for certain accounting and contractual data).

YOUR STATUTORY RIGHTS. You have certain rights concerning your personal data underGDPR as mentioned below, and can exercise them by contacting HOLOH atdataprotection@holoh.com.

Right to information. If you are a supplier-related third party (e.g., an employee of asupplier of HOLOH), HOLOH may not have your current details and thus cannotcontact you conveniently and in confidentiality. You can find updated information on HOLOH's processing of your data at any time on this websitehttps://holoh.com/privacypolicy, or by contacting HOLOH at dataprotection@holoh.com.
Access right. You have the right to access your personal data. HOLOH processes alarge quantity of information, and can thus request, in accordance with GDPR, thatbefore the information is delivered, you specify the information or processingactivities to which your request relates.* Right to rectification. You can ask HOLOHto rectify, correct or update inaccurate and/or incorrect data.
Other rights. In certain limited cases (in which case HOLOH will first analysewhether the conditions for the exercise of such rights are fulfilled, in line withGDPR), you may object to, or request the limitation of, the processing of yourpersonal data, or request the erasure or portability of your personal data. WhereHOLOH asked for your consent to a specific processing, you have the right towithdraw such consent at any time (for future processing). You should note that thelaw authorizes HOLOH to retain and continue processing certain personal data,even where you have exercised your rights to object or erasure or -if applicable-withdrawn your consent: this is the case in particular where HOLOH has legitimateand compelling reasons for continuing the processing, such as compliance withapplicable law. Finally, you can contact the Spanish data protection authority Agencia Española de Protección de Datos | AEPD.

Contact. You can contact HOLOH's Data Protection team here:

TMRW Spain S.L.
Av. Jean Claude Combaldieu, Nº5, 03008 Alicante, Spain.
Email: dataprotection@holoh.com

3. Job Applications, Employees, External Staff/Consultants

3.1 APPROPRIATE COMMUNICATION CHANNELS:

HOLOH's intranet (if any, and ifconcerned data subjects have access thereto) or website, through a clear link (e.g., 'Privacynotice') accessible from the homepage. It is not recommended adding this notice in theemployment or service contract as (i) this is not required or useful, and (ii) the contents ofthe notice are prone to change.

3.2 NOTICE CONTENTS:

TMRW Spain S.L. (Av. Jean Claude Combaldieu, Nº5, Alicante, Spain, HOLOH) collects andprocesses personal data on you when you apply for a job with HOLOH, or if you are anactual, former or prospective employee or external staff of HOLOH.

If you are detached to HOLOH as a consultant or external staff, please also refer to thePrivacy Notice concerning HOLOH's suppliers as some of processing operations detailedtherein might also apply to your personal data.

PROCESSING PURPOSES. The processing of your data is based on the following grounds:

PURPOSE OF PROCESSING & GDPR LEGAL BASIS

HOLOH processes your data:1. FOR JOB APPLICANTS:

to review job applications and manage recruitments

The processing is necessary:

in order to take steps prior to entering into a contract with you
for purposes of legitimate interests pursued by HOLOH (that is, HRmanagement)

2. FOR EMPLOYEES, INTERNS, EXTERNAL STAFF/CONSULTANTS:

as required by law (labour, tax, social, corporate, sanitary -e.g., COVID-19mandatory checks- or other) and make legally required filings or reporting toauthorities

The processing is necessary:

to comply with legal obligations to which HOLOH is subject

to manage staff onboarding, payroll management, process payments and expenses,benefits management

The processing is necessary:

for the performance of a contract with you or your company
to comply with legal obligations to which HOLOH is subject

for timekeeping, billing and invoicing

The processing is necessary:

for purposes of legitimate interests pursued by HOLOH (that is, financial management)
to comply with legal obligations to which HOLOH is subject

for physical security (badge issuance and management, access restrictions)

The processing is necessary:

for purposes of legitimate interests pursued by HOLOH (that is, premises,asset and information protection)

for IT management (IT licenses and accounts management, contacts/agendamanagement, collaborative tools, visio, chatrooms, file storage), electroniccommunications management (corporate email, mobile phones, telephony andconnectivity) and related monitoring and investigations

The processing is necessary:

for purposes of legitimate interests pursued by HOLOH (that is, IT and assetmanagement and protection)

for internal communications and marketing purposes

The processing is necessary:

for purposes of legitimate interests pursued by HOLOH (that is, internalcommunications and marketing)

DATA CATEGORIES. In addition to the information you have communicated to HOLOHdirectly (or, for external staff/consultants, through your company), HOLOH may collect andprocess the following categories of personal data:

for job applicants: identity (first/last name), contact details (address, phone, email,professional social media profiles), professional details (CV, experience, training,references, licenses, certifications, portfolios), tests, appraisals, role play videorecordings, background checks (former employers, schools/universities), sanctionslist research, interview notes, assessment, final decision, residence certificate,work permit, email correspondence with you, non-disclosure agreements,disclosures re. conflicts of interest, salary/benefits and professional expectations;
for employees and (where applicable) external staff/consultants: identity (first/lastname, social security number/affiliation details, ID/passport, address, phone,email), personal details (next of kin, emergency contacts, date of birth, nationality,civil status, household composition, personal interests), professional details(licenses, certifications), position (service, job description, position/professionalprofile, seniority, reporting lines, business cards, hiring/termination date), internalemployee number, salary, benefits (additional health insurance), financial data andbank details (IBAN), criminal record, residence certificate, visas, work permit,medical certificates, sickness/absence periods, occupational accidentsfiles/reports, workplace/job description adaptation (workplace and equipmentpreferences), including for disabled employees or employees with particularconditions, food allergies /preferences (internal events organisation), personalleave, parking allocation as applicable, payroll management (tax details,withholdings, tax card, deductions), presence/absence/working time management,time/job allocation, overtime work), attestations (work certificates), professionaltravel/venue arrangements, expenses (vouchers), employment contract details,disciplinary file, photo, appraisal interview notes and feedback, training followed(contents, certificates, presence, test results), training requests, training or HR-related interviews, feedback on employees, promotions/change, IT account details(internal number, name, account login, passwords, email, phone, address, function,office, department, reporting line/subordinates, professional groups, userprofile/access rights, IT user profile, access rights, corporate equipment/allocation,Outlook profile, emails, contacts, tasks, calendar, documents, Teamsprofile/logs/chats/visio data, access/logfiles, user interactions, IT traces, date/hourof connection, interactions with applications, IP addresses, license managementdata, software applications or paying/license-based web applications, licenserights, account credentials, use logs and related monitoring and investigationsresults) and project management data (task allocation/completion/priority,assignor/assignee, work log).

Where you provide personal data on third-parties (including your relatives) to HOLOH youshould make sure you have informed them accordingly.

DATA RECIPIENTS. HOLOH may share your data with affiliated or third-party serviceproviders as necessary to achieve the above listed purposes, as well as to your company(for external staff/consultants), competent local authorities (tax authorities, regulators, lawenforcement agencies), external auditors, payment providers, banks and, where applicable(events) communication agencies and event management providers (venue, catering,security).

be limited to what is necessary to perform the contract with you, or conclude acontract with a third-party in your interest, or
be justified by the establishment, exercise or defence of legal claims, or
if appropriate, be covered by appropriate safeguards, such as entering into ECapproved standard contractual clauses, or
in exceptional cases, take place with your consent. In such case, HOLOH will ask foryour consent separately.

DATA RETENTION.* For job applicants: HOLOH will retain your personal data as long asnecessary for the hiring process and, if your application is not retained, for up to 2 years aswe might have other positions matching your profile, unless you object to such retention byemail to your usual HR contact at HOLOH or to dataprotection@holoh.com.

For employees and external staff/consultants: HOLOH will retain your personal datafor as long as required to manage the employment relation or the business relationwith you or your company, and/or for the mandatory retention duration set forth byapplicable law (up to 10 years after the termination of our relation for certainaccounting and contractual data).

YOUR STATUTORY RIGHTS. You have certain rights concerning your personal data underGDPR as mentioned below, and can exercise them by contacting HOLOH atdataprotection@holoh.com.

Right to information. If you are a supplier-related third party (e.g., an employee of asupplier of HOLOH), HOLOH may not have your current details and thus cannotcontact you conveniently and in confidentiality. You can find updated information onHOLOH's processing of your data at any time on this websitehttps://holoh.com/privacypolicy, or by contacting HOLOH atdataprotection@holoh.com.
Access right. You have the right to access your personal data. HOLOH processes alarge quantity of information, and can thus request, in accordance with GDPR, thatbefore the information is delivered, you specify the information or processingactivities to which your request relates.* Right to rectification. You can ask HOLOHto rectify, correct or update inaccurate and/or incorrect data.
Other rights. In certain limited cases (in which case HOLOH will first analysewhether the conditions for the exercise of such rights are fulfilled, in line withGDPR), you may object to, or request the limitation of, the processing of yourpersonal data, or request the erasure or portability of your personal data. WhereHOLOH asked for your consent to a specific processing, you have the right towithdraw such consent at any time (for future processing). You should note that thelaw authorizes HOLOH to retain and continue processing certain personal data,even where you have exercised your rights to object or erasure or -if applicable-withdrawn your consent: this is the case in particular where HOLOH has legitimateand compelling reasons for continuing the processing, such as compliance withapplicable law. Finally, you can contact the Spansih data protection authority (Agencia Española de Protección de Datos | AEPD) to introduce a claim.

Contact. You can contact HOLOH's Data Protection team here:

TMRW Spain S.L.
Av. Jean Claude Combaldieu, Nº5, 03008 Alicante, Spain.
Email: dataprotection@holoh.com