Effective Date: October 17, 2022
• The ways we collect personal data about you and why we do so
• How we use your personal data, and
• The choices you have about your personal data.
INO Launchpad, Hololoot’s cloud services, websites and related services, which we here
collectively call the “Service” or the “Services”. We may periodically update this Privacy
Policy by posting a new version on hololoot.io. If we make any material changes, we will notify
you as required under applicable law, including by posting a notice in the Service prior to the
change becoming effective. Your continued use of the Service after the effective date will be
If you have questions about data protection, or if you have any requests for resolving issues
with your personal data, we encourage you to primarily contact us through the support features
within the Service, so we can reply to you more quickly. Alternatively, you may contact:
Name of the controller: Hololoot GmbH Switzerland, IDE-CHE-310.724.064;
Address: Kernserstrasse 17, 6060 Sarnen, Switzerland
THE DATA WE COLLECT
The categories of personal data we collect depend on the Services you use, and the requirements
of applicable law.
Data you provide us directly.
• Contact information (such as name and email address or phone numbers)
• User name or tag and password
• User information
• Your messages and other content you submit when you use the Service (such as chat logs and
player support tickets)
• Data you provide in connection with surveys, promotions, sweepstakes, competitions and
• Other data you choose to give us (such as data to identify a lost account or data you provide
to participate in survey or promotional programs)
Data we collect automatically.
• Data about your account, including in most cases an automatically created internal account
• Your IP address and mobile device identifiers (such as your device or advertising ID)
• Data about your device, such as device name and operating system, browser type and
language, internet service provider, and mobile carrier
• Data we collect with cookies and similar technologies (see more below)
• Approximate location data (as derived from IP address)
• Data about your use of the Service
Data we collect from our partners.
We also use third-party partners, such as social networking sites, data analytics providers and
advertising networks to supplement information we have about you, such as:
• Data we receive if you link a third party tool with the Service (such as Facebook or Google)
• Demographic data (such as to determine the coarse location of your IP address)
• Data to fight fraud
• Data from payment service providers (such as payment verification data)
• Data for advertising and analytics purposes, so we can provide you a better Service
• Data that you have made available to us from a third party service (Google or Facebook) via
your privacy settings
• Data we receive from third-party wallet providers such as blockchain address and certain other
information you choose to share with those wallets providers.
WHY DO WE COLLECT YOUR DATA
We use your data for a variety of business purposes, such as:
To make the Service work.
To perform the contract, we process data necessary to
• Create accounts and allow you use our Service
• Operate the Service
• Verify and confirm payments
• Provide and deliver products and services you request
• Send you Service-related communications
To make the Service more suitable for our users.
To provide a great Service to our users we have a legitimate interest to collect and process
necessary data to
• Update and develop user profiles
• Develop and improve the Service and user experience
• Manage our relationship with you
• Provide social features as part of the Service
• Customize your Service experience
• Respond to your comments and questions and provide player support
• Provide you offers in the Service
• Send you related information, such as updates, security alerts, and support messages
• Enable you to communicate with other users
To show personalized advertisements.
To show you personalized advertisements in the Service as well as in other websites and
services (including email) we have a legitimate interest to process necessary data to
• Track the content you access in connection with the Service and your online behavior
• Deliver, target and improve our advertising and the Service
For information on how to opt-out from personalized advertisements, see section ‘Your Rights
and Options’ below.
To keep the Service safe and fair.
In order to keep the Service and its social features safe and fair, to fight fraud and ensure
acceptable use otherwise, we have a legitimate interest to process necessary data to
• Analyze and monitor use of the Service and its social features
• Moderate chats either automatically or manually
• Take action against fraudulent or misbehaving players
To analyze, profile, and segment.
In all of the above cases and purposes, we may analyze, profile and segment all collected data.
With your consent.
With your consent, we may process your data for additional purposes, such as using your GPS
location to show you local events.
WHO CAN SEE YOUR DATA
Apart from Hololoot, your data can be accessed by others in the following situations:
Our Service Providers.
Hololoot has vendors to us provide the Services. These vendors process your data only at and
according to Hololoot ́s instructions to provide the Service, and perform tasks such as hosting,
player support, advertising, analytics and fraud prevention.
Other companies and public authorities.
In order to combat fraud and illegal activity, we may process and disclose data with other
companies and organizations and provide it to public authorities in response to lawful requests.
We may also disclose your data based on your consent, to comply with the law or to protect the
rights, property or safety of us, our users or others.
Advertising and Social Media partners.
The Service includes features from our partners, such as social media interaction tools,
functionalities through application programming interfaces (APIs) or software development
kits (SDKs) and in-application advertising. These partners may access your data and operate
under their own privacy policies. We encourage you to check their privacy policies to learn
more about their data processing practices.
We us following services:
https://sentry.io (no user specific data)
These partners may access data regarding your activities and your device (such as your IP
address, mobile identifiers, page(s) visited, location, time of day). We may also combine and
share data we have collected about you with third-party advertising partners. These advertising
partners may use this data (and similar data collected from other websites) for purposes of
delivering targeted advertisements to you when you visit third-party services within their
networks. These partners may operate under their own privacy policies. This practice is
commonly referred to as “interest-based advertising” or “online behavioral advertising.” If you
prefer not to share your personal data with third-party advertising partners, you may follow the
instructions in “Your Rights and Options” below.
INTERNATIONAL DATA TRANSFERS
Our Service is global by nature and your data can therefore be transferred to anywhere in the
world. Because different countries may have different data protection laws than your own
country, we take steps to ensure adequate safeguards are in place to protect your data as
explained in this Policy. Adequate safeguards that we may use include standard contractual
clauses approved by EU Commission and other lawful safeguards.
YOUR RIGHTS AND OPTIONS
Opt out of marketing emails and other direct marketing.
You may opt out of receiving promotional communications, such as marketing emails from us
by following the instructions in such communications, or by changing your in-application
settings. The updated settings may not be effective immediately. Note that you may still
continue to receive non-promotional communications from us, such as communications
We may send you push notifications through our mobile applications. You may at any time opt-
out from receiving these types of communications by changing the settings on your mobile
Opt-out of targeted advertising
You can opt-out of interest-based advertising on mobile applications by checking the privacy
settings of your Android or iOS device and selecting “Limit Ad Tracking” (Apple iOS) or “Opt-
out of Interest Based Ads” (Android).
Access the personal data we hold about you
If you request, we will provide you a copy of your personal data in an electronic format. You
have the right to request that your personal data be sent directly by us to another controller, if
Your other rights
You also have the right to correct your data, have your data deleted, object how we use or share
your data, and restrict how we use or share your data. You can always withdraw your consent,
for example by turning off GPS location sharing in your mobile device settings.
If you wish to exercise any of your data subject rights described above, please use the support
options described in “Contact Us” above. We will respond to all requests in accordance with
applicable laws. To protect your privacy, we may also take additional steps to verify your
identity before fulfilling your request, such as by requesting you provide us a purchase receipt
or other account information, asking you to link your email address with your application
account or asking you to answer questions regarding your activities on our Services. Once you
have verified your identity, you may also designate an authorized agent to exercise your rights
on your behalf by providing the agent’s contact information to our customer support staff, as
required by applicable law.
Finally, you always have the right to lodge a complaint with your local data protection authority
regarding our processing of your data. For more information, please contact your local data
You may have a right not to receive discriminatory treatment as a result of your exercise of
Note that the Services employ smart contracts that collect information that is then stored on a
blockchain that we do not control. If you use the Service, you are consenting to allow your
information to be cryptographically transmitted and stored on that blockchain, and any deletion
or modification of that information (to the extent possible on a blockchain) is governed by the
terms of the relevant smart contract.
COOKIES AND SIMILAR TECHNOLOGIES
and personalize the Service, analyse use, target advertisements and prevent fraud. Cookies and
similar technologies allow us and our partners to store their preferences and track your activities
within the Service. Note that our partners may operate under their own privacy policies.
We and our partners collect and store information about users’ interactions with unaffiliated
websites and applications that use our technologies, including cookies and similar tracking
technologies. This allows us to infer the presence of a common user or household behind
multiple devices or browsers, for instance, and then link those browsers and devices into a
device graph. We do so in order to:
● detect and prevent fraud;
● allow users to use the Service on one device and pick up seamlessly where they left off
on another device;
● analytics, personalization and attribution;
● limit the number of times a user is shown the same advertisement, across all known or
inferred devices; and/or
● provide personalized advertising on each device that is inferred from the browsing
patterns on all of the devices.
HOW DO WE PROTECT YOUR DATA
In order to help ensure a secure and safe player experience, we are continuously developing
and implementing administrative, technical and physical security measures to protect your data
from unauthorized access or against loss, misuse or alteration.
We retain your data for as long as your account is active or as needed to provide you the Service.
We may for example periodically de-identify unused accounts, and we may regularly review
and de-identify unnecessary data.
Note that if you ask us to remove your personal data, we will retain your data as necessary for
our legitimate business interests, such as to comply with our legal obligations, resolve disputes,
and enforce our agreements.
Protecting children’s privacy online is very important to us. Generally, our Services are not
directed to children and the Services do not knowingly collect personal data from children,
except as described in the following paragraph.
If you are a parent or guardian and wish to review personal data collected from your child, or
have that information modified or deleted, you may contact us as described above. If we become
aware that a child has provided us with personal data contrary to the above, we will delete any
personal data we have collected, unless we have a legal obligation to keep it, and terminate the
child’s account and/or revert them to the underage experience, as applicable.