Privacy Policy

1. General Provisions

This Privacy Policy (hereinafter referred to as the “Policy”) defines the procedure for processing and protecting personal data provided by users (hereinafter referred to as “Users”) when using the services provided by the provider (hereinafter referred to as “Holod Media”). Holod Media is committed to ensuring the confidentiality and security of personal data in accordance with applicable legal regulations.

2. Terms and Definitions

  • Personal Data – any information that directly or indirectly identifies an individual (User), including but not limited to: name, surname, email address, IP address, and other data.
  • Processing of Personal Data – any action or set of actions performed with personal data, including collection, recording, organization, storage, alteration, use, transfer, anonymization, and deletion.
  • User – an individual who uses any of the services provided by Holod Media.
  • Holod Media Services – digital platforms, including the website provided by Holod Media.

3. Processing of Personal Data

3.1. Holod Media processes Users’ personal data in accordance with the principles of legality, fairness, and transparency. Processing is carried out solely for the purposes defined by this Policy.

3.2. Users’ personal data is processed for the following purposes:

  • Ensuring the functionality of the services;
  • Providing support to Users and interacting with them;
  • Fulfilling contractual obligations, including the provision of paid services and delivery of goods;
  • Analyzing service usage and improving their quality;
  • Conducting marketing and advertising campaigns (with the User’s consent).

3.3. Holod Media does not store Users’ payment data on its servers. All payments are processed through certified third-party payment services.

4. Categories of Data Processed

Holod Media may process the following categories of personal data:

  • Identification data: name, surname, IP address, and any other identifiers provided by the User.
  • Contact data: email address, phone number, and other contact information.
  • Payment data: information about transactions made, including the date and time of the transaction, amount, and the last four digits of the payment card.

5. Transfer of Personal Data to Third Parties

5.1. In certain cases, Holod Media may transfer Users’ personal data to third parties if it is necessary to fulfill obligations to Users or to ensure the operation of the services. Data transfer is only possible to partners who adhere to the required data protection standards.

5.2. The transfer of personal data outside the European Union (EU) or the European Economic Area (EEA) is carried out only if there are lawful grounds and with sufficient levels of data protection in place.

6. Users’ Rights

6.1. Users have the right to access their personal data and to correct it if it is inaccurate or incomplete.

6.2. Users may withdraw their consent to the processing of personal data at any time by sending a request via email. Withdrawal of consent does not affect the lawfulness of data processing carried out before the withdrawal.

6.3. Users have the right to request the deletion of their personal data if its processing is no longer necessary for the purposes specified in this Policy, or if there are no other legal grounds for its retention.

6.4. In case of any violation of Users’ rights, they may file a complaint with the relevant data protection authority.

7. Retention of Personal Data

7.1. Users’ personal data is retained for the period necessary to achieve the purposes of processing as defined in this Policy or until the User withdraws consent unless otherwise provided by applicable legal regulations.

7.2. Upon the expiration of the retention period, personal data shall be deleted or anonymized in accordance with established procedures.

8. Policy Changes

Holod Media reserves the right to make changes to this Policy. Users will be notified of any changes through digital communication channels no later than 14 days before the changes take effect.

For further information or if you have any questions related to the processing of personal data, Users may contact Holod Media at [email protected].