Privacy policy for Holo mortgage consultant
Last updated July 2024
This Privacy Notice (the “Privacy Notice”) relates to your use of the Holo Wbsite which offers Digital Mortgage services and other services available at: www.useholo.com/en/sa (the “Website”). The Website is made available to you by Holo, a Limited Liability Company incorporated and existing under the laws of the Kingdom of Saudi Arabia and registered in the commercial register in the city of Riyadh under number 1010829491 and unified ID number 7031021681 having its place of business at 4567 Prince Turki Al-Awwal rd. 12371 – 5260, Riyadh, Kingdom of Saudi Arabia, under the oversight and supervision of Saudi Central Bank (referred to in this Privacy Notice as “Holo”, “we”, “us” and “our”).
We take your privacy seriously and want you to feel comfortable whenever you use the Website. We process your personal data (“Personal Data”) in accordance with the Saudi Arabia Cabinet Decision No. 98/1443 On the Approval Of the Personal Data Protection Law and Royal Decree No. M148 of 05/09/1444 AH and the respective implementing regulations as amended from time to time.
Relevant regulations to Holo
| Regulation | Relevance |
|---|---|
| KSA Basic Law of Governance | Holo adheres to the principles of privacy and data protection with exceptions related to laws and regulations as described in this document. |
| E-Commerce Law | Holo complies with the e-commerce law in regards to protection and retention of data as defined within the principles and according to the clauses described in Holo’s Data Protection and Privacy Policy. |
| Cloud Computing Framework | Holo needs to ensure that its own data protection policies are applied by third parties and service providers. These clauses and principles should be added to contracts and performance measures with the service providers. |
| Anti-Cybercrime Law | Holo ensures that consent is obtained and clearly described to the data subjects as described in Holo’s Data Protection and Privacy Policy. |
| Instructions for digital brokerage activities by SAMA | Holo ensures to establish a Data Management and Personal Data Protection Strategy and develop a Data Management and Personal Data Protection Plan. |
| Data Management and Personal Data protection Standards by NDMO – SADAIA | Holo ensures to establish a Data Management and Personal Data Protection Strategy and develop a Data Management and Personal Data Protection Plan. |
This Privacy Notice constitutes an integral part of the Website's terms and conditions.
What Personal Data we collect and for what purposes
We collect the following types of Personal Data about you:
| Purpose | Types of Data Processed | Provided by | Mandatory and optional provision |
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| Optional |
You shall provide us only with Personal Data that are accurate, complete, up-to-date, and relevant for the purpose for which they are collected. We will take reasonable steps to ensure that your Personal Data are accurate, complete, up-to-date and relevant for the purpose for which they are collected but we will not be responsible for any inaccuracy, incompleteness, antiquity or irrelevance of the Personal Data if these are a consequence of your error or omission.
How we collect and process your Personal Data
- We collect and process Personal Data only when you specifically give it to us by registering on and/or using the Website or by the third parties mentioned in Section 2 above.
- The Personal Data you provide will be processed in compliance with the Applicable Laws and, in any case, in such a way as to guarantee the security and confidentiality of the same, to prevent unauthorized disclosure or use, alteration or destruction. The Personal Data will be processed on paper and/or via telematic means, also with the help of electronic and information means.
- We will process your Personal Data in our own technological infrastructure and/or using the technological infrastructure of third-party suppliers appointed as data processors. We process Personal Data for the purposes set out in Section 2.
You may reach out to Holo to the address indicated in Section 9 below for any queries related to collecting and processing your Personal Data.
Protecting your personal data
We recognize industry standards and employ security safeguards to protect Personal Data from unauthorized access and misuse. All information you provide to us is stored on secure servers.
Sharing your Personal Data with third parties
We may share Personal Data with third party providers so they can provide you with certain services through the Website; such as banks, finance companies and property providers. We will require these third party providers to take steps to ensure that your Personal Data is kept secure and used in accordance with this Privacy Notice. However, we shall not be liable for any unauthorised use of your Personal Data by a third party provider.
The Personal Data may be communicated, exclusively for the purposes indicated in this Privacy Notice, to the categories of subjects listed below:
- persons, companies, associations or professional firms that provide services and activities of assistance and consultancy to Holo, with particular but not exclusive reference to accounting, administrative, legal, finance matters;
- companies that provide certain services related to the website and to the management and orders through the website, with particular but not exclusive reference to the analysis of Personal Data, marketing activities, the management of services provided through the App and their customisation in your favour;
- subjects to whom the right to access the Personal Data is required by law, secondary legislation, a court order or by a regulatory authority of competent jurisdiction or if we believe that such disclosure is necessary, to protect, defend or enforce our rights.
- third party companies and clients with whom Holo collaborates as a business partner (e.g. for the promotion of the services) including those third parties assisting us in supplying our services to you or perform certain functions on our behalf, including IT support services or professional services.
The Personal Data may be communicated, exclusively for the purposes indicated in this Privacy Notice, to the categories of recipients listed above and having their registered offices in the Kingdom of Saudi Arabia and acting, as the case may be, as data processors for Holo or as separate data controllers, in this case providing you, under his/her own responsibility, with appropriate information.
Your Personal Data will be stored on the servers available to Holo or to the persons in charge located in Kingdom of Saudi Arabia. Should it become necessary for technical and/or operational reasons to use subjects located outside the Kingdom of Saudi Arabia, or should it become necessary to transfer some of the collected Personal Data to technical systems and services managed in the cloud and located outside the Kingdom of Saudi Arabia, the processing will be regulated in compliance with the provisions of the Applicable Laws regarding data transfers.
This Privacy Notice only applies to Personal Data collected on the Website. Although the Website may provide links to websites of third parties, such as banks, this Privacy Notice does not apply to any other application or website that you connect to from the Website. We are not responsible for the content or practices of applications and websites operated by third parties that are linked to or from the Website and you should refer to the relevant privacy policies issued by such third parties.
Data Retention Period
The Personal Data collected for the processing purpose indicated in Section 2 above shall be retained for the time necessary for the pursuit of such purposes and thereafter, and in any case for the permitted time under the Applicable Law from the achievement of the respective purposes as required by the Applicable Laws, except in case of extraordinary necessity of Holo to keep the Personal Data further in order to defend its rights, also in relation to disputes existing at the time of the request or upon indication of public authorities or as otherwise permitted by the Applicable Laws.
Some personal data may be stored for 10 years+ after the end of the relationship for AML purposes as required by SAMA; the data may be encrypted in case we didn’t delete your account.
Your rights
Unless otherwise permitted by the Applicable Laws, we hereby remind you that you have the following rights:
- to the extent that consent was given for any processing of Personal Data, the right to withdraw your consent at any time by sending an e-mail to us;
- the right to obtain information in relation to the purposes and legal basis for which your Personal Data is processed;
- the right to obtain correction of inaccurate, incomplete and/or outdated Personal Data relating to you;
- the right to obtain that the Personal Data concerning you is only kept without any other use of the Personal Data in the following cases: (a) you contest the accuracy of the Personal Data, for the period necessary to allow us to verify the accuracy of such Personal Data; (b) the Personal Data is necessary for the establishment, exercise or defense of legal claims; and (c) you object to the processing and are awaiting verification as to whether the legitimate grounds of the data controller for processing prevail over those of the data subject;
- the right to obtain the cessation of processing in cases where your Personal Data is processed for marketing purposes; and
- the right to receive in a readable and clear format, a copy of the Personal Data provided to us.
- Should you reckon that your Personal Data is being processed unlawfully, you may file a complaint with the relevant data protection authority. Please note that in the Kingdom of Saudi Arabia you have the right to turn to the national authority (SDAIA / NDMO) to assert your rights in relation to the processing of your Personal Data.
Changes to this privacy notice
any changes we may make to this Privacy Notice in the future will be posted on the website and, where appropriate, may be notified to you. By continuing to use the website you will be deemed to accept the changes to this Privacy Notice.
Contact
Your personal data processing controller is Holo. You can contact Holo at any time by mail or e-mail at [email protected]. If you have any questions regarding this Privacy Notice.
References
- Holo’s Data protection and privacy Policy
- AML policies and procedures
- Personal Data Protection Policy by NDMO – SADAIA
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