Privacy Policy

Last updated: 1st June 2025

This Privacy Policy explains how AIXR LTD collects, uses, and protects your personal information when you use Holito's community experience platform and website.

1. Information We Collect

When you use Holito's community experience platform and website, we collect various types of information to provide, maintain, and improve our services. This includes information you provide directly and information collected automatically through your use of our platform.

We are committed to transparency about our data collection practices and comply with UK GDPR, EU GDPR, and other applicable data protection laws. All data collection serves specific purposes related to platform functionality, security, and service improvement.

1.1 Personal Information You Provide

This includes your name, email address, phone number (when provided), company information, profile details, community posts, messages, uploaded content, responses to community or event registration questions, and any other information you voluntarily submit when creating an account, participating in communities, registering for events, or contacting our support team.

1.2 Automatically Collected Information

We automatically collect technical information including IP address, browser type, device information, operating system, pages visited, time spent on platform, click patterns, and interaction data. This is collected through analytics tools for comprehensive usage analytics and user behavior tracking.

1.3 Community and Event Information

When you join communities or register for events on Holito, we collect information about your participation, including community membership details, event attendance, and any additional information requested by community or event organizers through registration forms or surveys.

2. How We Use Your Information

We use your personal information to operate, maintain, and improve Holito's community experience platform. Our data processing is based on legitimate interests, contractual necessity, and where applicable, your explicit consent.

Data Usage Purposes

  • • Providing and maintaining the Holito platform and website functionality
  • • Creating and managing your user account and community memberships
  • • Facilitating community interactions, messaging, and content sharing
  • • Analyzing platform usage patterns and user behavior to improve our services
  • • Detecting and preventing fraud, abuse, and security threats
  • • Sending service-related communications and platform updates
  • • Personalizing your platform experience and content recommendations
  • • Complying with legal obligations and regulatory requirements

We use advanced analytics tools to track user interactions, feature usage, and platform performance. This comprehensive tracking helps us understand user needs and continuously improve the platform experience.

3. Information Sharing and Disclosure

We do not sell, rent, or trade your personal information to third parties. We only share your information in specific circumstances necessary for platform operation, legal compliance, community functionality, or with your explicit consent.

3.1 Community and Event Data Sharing

When you join a community or register for an event on Holito, certain personal information is shared with the community managers and event organizers to facilitate community management and event coordination. This shared information typically includes:

  • • Your name and email address
  • • Phone number (when provided during registration)
  • • Responses to community or event registration questions
  • • Your user profile information (which is public by default)
  • • Community participation and engagement data

Important: Your user profile information is visible to all users on the Holito platform by default. Even if you set your profile to private, your basic profile information (name, profile picture, and relevant details) will still be shared with community managers and event organizers when you join their communities or events. This sharing is necessary for community management, event coordination, and member engagement purposes.

3.2 Other Information Sharing

Information may also be shared with trusted service providers who assist in platform operations (such as cloud hosting, analytics, and security services), within community features where you choose to share content publicly, with law enforcement when legally required, or in the event of a business transfer or merger involving AIXR LTD.

Third-Party Service Providers

We work with carefully selected third-party providers for hosting, analytics, security monitoring, and platform infrastructure. All providers are contractually bound to protect your data and use it only for specified purposes.

3.5 Community Manager Data Protection Responsibilities

Community managers and event organizers who receive member data through Holito are encouraged to protect this information and use it responsibly for legitimate community management and event coordination purposes. While Holito is not responsible for how third-party community managers handle member data, we recommend they should:

  • • Use member data only for community management and event coordination
  • • Protect member information with appropriate security measures
  • • Respect member privacy preferences where possible
  • • Not share member data with unauthorized third parties
  • • Comply with applicable data protection laws and regulations

If you have concerns about how a community manager or event organizer is handling your personal information, please contact us at [email protected]. While we encourage responsible data handling practices, please note that Holito cannot be held responsible for the data protection practices of individual community managers or event organizers.

4. Data Security

We implement comprehensive security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. Our security practices are designed to meet industry standards and comply with applicable data protection regulations.

Security Measures

Our security framework includes SSL/TLS encryption for data transmission, secure cloud infrastructure, regular security audits, access controls and authentication systems, monitoring for suspicious activity, and incident response procedures for potential security breaches.

While we strive to protect your personal information, no internet transmission or electronic storage is completely secure. We cannot guarantee absolute security but maintain industry-standard protections and continuously monitor for threats.

5. Your Rights and Choices

Under UK GDPR and EU GDPR, you have specific rights regarding your personal data. We are committed to facilitating the exercise of these rights and will respond to your requests within the legally required timeframes.

5.1 Access and Portability

You have the right to access your personal data and receive a copy in a structured, machine-readable format. You can also request that we transfer your data directly to another service provider where technically feasible.

5.2 Correction and Deletion

You can request correction of inaccurate personal data or deletion of your personal data, subject to legal retention requirements. Some data may need to be retained for legal compliance, security, or legitimate business purposes.

5.3 Objection and Restriction

You can object to processing based on legitimate interests or request restriction of processing in certain circumstances. You also have the right to withdraw consent where processing is based on consent.

6. Cookies and Tracking Technologies

Holito uses cookies and similar tracking technologies to enhance your platform experience, analyze usage patterns, and provide personalized content. We use comprehensive analytics tools to track user interactions and platform performance.

Essential Cookies

Required for basic platform functionality, user authentication, security features, and maintaining your session state.

Analytics Cookies

Used by analytics tools to understand user behavior, improve platform features, and optimize user experience.

Functional Cookies

Enable enhanced functionality like remembering your preferences, community settings, and personalized content.

Performance Cookies

Help us monitor platform performance, identify technical issues, and optimize loading times and responsiveness.

You can manage cookie preferences through your browser settings or our cookie consent banner. Note that disabling certain cookies may affect platform functionality and your user experience.

7. International Data Transfers

As Holito operates globally and uses international service providers for platform infrastructure, your personal data may be transferred to and processed in countries outside the UK and European Economic Area (EEA).

We ensure appropriate safeguards are in place for international transfers, including Standard Contractual Clauses (SCCs) approved by the European Commission, adequacy decisions where available, and contractual commitments from service providers to maintain equivalent data protection standards.

8. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements.

Account information is retained while your account is active and for a reasonable period after account closure. Community content may be retained longer to maintain community integrity and continuity. Analytics data is typically retained for up to 26 months to enable meaningful trend analysis and platform improvement.

Retention Periods

  • • Account data: Duration of account + 2 years
  • • Community content: Up to 7 years after account closure
  • • Analytics data: Up to 26 months
  • • Security logs: Up to 12 months
  • • Marketing preferences: Until withdrawn

9. Children's Privacy

Holito is not intended for use by children under the age of 16 (or the minimum age for digital consent in your jurisdiction). We do not knowingly collect personal information from children under this age.

If we become aware that we have collected personal information from a child under the applicable minimum age without appropriate parental consent, we will take steps to delete such information promptly. If you believe a child has provided us with personal information, please contact us immediately.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes through the platform or by email.

The updated Privacy Policy will be posted on this page with a revised effective date. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information. Your continued use of Holito after any changes constitutes acceptance of the updated Privacy Policy.

Contact Us

If you have any questions about this Privacy Policy, want to exercise your data protection rights, or need to report a privacy concern, please contact us using the information below.

AIXR LTD

15 Eastwood Road
Rayleigh, Essex
SS6 7JD
United Kingdom

Legal Basis: We process your personal data based on contractual necessity (to provide Holito services), legitimate interests (platform security and improvement), and consent (for marketing and optional features). You have the right to object to processing based on legitimate interests.