1 What kind of information do we collect?
Hold AS processes personal data relating to users of Hold AS’ Services. The types of personal data processed are described below. The data Hold AS collects about the users is given by the user in connection with the appropriation of Hold AS’ Services, or later submitted by the user through the use of the Services.
Information you directly provide us
We collect different kinds of information about you in order to provide you with a user account.
In order to create an account and thereby getting access to the application (including easy access to the Hold function, marketplace, rewards claimed, stats, highscore, etc.) and to personalize the content for you (including providing appropriate content considering your educational institution), we need to collect some data about you. You provide this information during the onboarding process and by connecting your user account with your Facebook or Google account.
When connecting with Facebook or Google, we will collect the following data about you for your account:
Name to personalize the in-app experience
Email address to have an optional communication channel. We respect your inbox and won’t send any marketing emails, unless you opt in.
Profile picture to improve the user experience in the highscore. You won’t be visible to other users, unless you opt in to be visible in the highscore.
Facebook Friends IDs to show your friends in the highscore. You won’t be visible in the highscore, unless you opt in.
Later on in the process you will also be asked for your:
Educational institution to provide organization-specific marketplace offerings and highscore
Student email to verify your student status
Information you provide us when you use our Services
We collect information about your activity in our Services. For example, we may collect information about how you interact with the Services, such as time spent Holding, how many points you collect, when you collect them and what rewards you exchange them for.
When you contact us through the Help Centre within the app, we also collect certain device information that will help us diagnose any problems you might experience while using our Services. For example, we collect information such as the operating system, hardware and software versions, battery level, available storage space and IP Address.
In order to use the full Service within the app and earn points, iOS users need to allow location services. Hold needs to run in the background to determine if you’re using your phone or not. For technical reasons, we need you to allow location services to make this work. Your location data is not stored in any way. You can always revoke your consent to location services by changing the settings on your device. If you disable location services, certain features of the Services, like the Hold function, will no longer work.
The legal basis for the processing described above is the Norwegian Personal Data Act § 8 litra a (fulfilling an agreement to which the user is party) and § 8(1) (consent from the registered persons, which is voluntary to submit). Providing the data described above is voluntary, but necessary to get access to and use Hold’s Services. Hold’s Services will not be available if the data is not provided.
2 How and why do we use this information?
We process the data in order to deliver our Services that we constantly improve. Here are some of the ways we do that:
Develop, operate, improve, deliver and maintain our Services.
Personalize our Services by, among other things, customizing content we show you, including marketplace offerings.
Monitor and analyze usage.
Send you communications, including by email. We may use email to respond to customer support inquiries, contact you regarding competitions you joined or, if you decide to opt in, send marketing emails.
3 How is the information shared?
Here’s the type of information we may share about you with others and how we do so:
Sharing with other Hold users
If you opt in to be visible on the highscore, your earned points (daily, weekly, monthly and yearly), name and profile picture will show up under the highscore list. This data may be viewed by all Hold users. You can always revoke your consent to be seen on the highscore within the app under your profile.
With third parties
We may share information about you with service providers who perform services on our behalf and business partners that provide marketplace offerings. For example, if you participate in a competition, we will need to inform our business partner of the winner.
We may also share aggregated or de-identified information (for example impression, purchase, and redemption data) with our business partners. The data will be anonymized, and directly related to that partner’s offering in the marketplace.
4 How long is the data stored?
We delete or anonymize data as soon as the purpose of the processing is fulfilled. Information associated with a user account will be kept until the account is deleted.
5 How can you manage your data?
Access and updates
You can access your data in the application through your account, where you also have the possibility to update most of the data. If you wish to update data to a further extent than what is possible through the user account, you must contact us by email.
If for some reason you want to delete your account, you can do that at any time in the application by visiting your profile. Keep in mind that, if you ask to delete your account, all personal data will be anonymized or deleted immediately and you won’t be able to recover any information later.
If you change your mind about any consent you have given, you may revoke it at any time through simply changing the settings on your device or in the application under profile. Of course, if you do that, certain services may lose full functionality.
If you use our Services, you can contact us by email for any use of your rights under the General Data Protection Regulation – please see contact information under item 7 and 8 below.
6 How do we process data outside of the EU/EEA?
We may subcontract processing to, or share your personal data with, third parties located in countries other than your home country. Your personal data may therefore be subject to privacy laws that are different from those in your country of residence.
Personal data collected within the European Union (“EU”) may, for example, be transferred to and processed by third parties located in a country outside of the EU. In such instances Hold shall ensure that the transfer of your personal data is carried out in accordance with applicable privacy laws and in particular that appropriate contractual, technical, and organizational measures are in place such as the Standard Contractual Clauses approved by the EU Commission.
7 How to contact us with questions or file a complaint?
For any questions, enquiries or complaints relating to this policy or our processing of personal data, please write to us at contact(at)holdstudent.com.
Registered individuals may also file a complaint by contacting the data protection authority in Norway or if the customer is resident elsewhere in Europe their local data protection authority.
8 Information about us
Data controller for the processing is Hold AS, a company established and registered in the Norwegian Register of Business Enterprises with organization number 915 464 602, address: Olav Kyrres gate 8 A, 3046 Drammen, e-mail: contact(at)hold.app. Hold AS adheres to Norwegian personal data legislation.