Holol Loyalty Privacy Policy

This privacy policy applies specifically to Holol Loyalty — the loyalty program platform built and operated by HololTeck (Wyoming, USA, with a regional presence in Doha, Qatar). It covers member sign-up, points and rewards activity, digital wallet cards, campaigns, referrals and AI-powered personalization inside the platform.

It complements HololTeck's general Privacy Policy. If anything here conflicts with the general policy for loyalty member data, this policy prevails. Questions can be sent to privacy@hololteck.com or ask@hololteck.com.

The business that operates the loyalty program (the merchant or brand) is the data controller for its members' data. HololTeck acts as the data processor, operating the Holol Loyalty platform on the business's documented instructions under a written services agreement.

Members should direct requests about their loyalty data — access, correction, deletion, or opting out of marketing — to the business running the program. HololTeck assists the business in fulfilling those requests.

Identity and contact: name, phone number, email address, date of birth (where the business collects it for birthday rewards), and preferred language.

Loyalty activity: points earned and redeemed, stamps and buy-and-get-free progress, tier and level status, vouchers issued and used, referral activity, and transaction values linked to rewards.

Engagement: campaign messages received, opened and acted on; visit and purchase history at participating locations; and preferences chosen in the member profile or digital wallet card.

Technical data: device type, app or web session information, and IP-derived approximate location, used for security, fraud prevention and analytics.

Holol Loyalty is not designed to collect special category data (health, religion, biometrics) and businesses are instructed not to store it in the platform.

To run the loyalty program: registering members, tracking points, stamps and tiers, issuing and redeeming rewards, and operating digital wallet cards — on the basis of the member's relationship with the business.

To send program communications such as points updates, expiring rewards, campaigns and offers — on the basis of the member's consent or the business's legitimate interests, with opt-out available at any time.

To power AI personalization — suggesting relevant rewards, segmenting audiences, and timing campaigns — using only the minimum data needed, with human oversight by the business for decisions that materially affect a member.

To prevent fraud and abuse, such as duplicate accounts or reward manipulation, and to meet the business's accounting and legal obligations.

AI features may analyze purchase and engagement patterns to recommend offers, predict churn, or automate campaign timing. These features operate on the business's own member data only.

Member data is not used to train general-purpose AI models, is not shared with other businesses on the platform, and is processed through business-grade providers bound by contractual confidentiality.

Members can ask the business which AI features are applied to their profile and request human review of any automated decision that significantly affects them.

Member data is shared only with the providers needed to operate the platform: cloud hosting and databases, messaging providers (SMS, WhatsApp, email) for program communications, analytics tools, and AI model providers. Each is contractually bound to process data only for the service.

Member data is never sold, and never shared with advertisers or unrelated third parties. Disclosure outside this scope happens only where the law requires it or to protect the rights of members, businesses or HololTeck.

HololTeck operates between the United States, Qatar and the wider MENA region, so member data may be processed and stored outside the member's country. Where transfers involve data protected by GDPR, Qatar's PDPPL or similar laws, we rely on appropriate safeguards such as standard contractual clauses and vendor commitments.

Member data is kept for as long as the loyalty program is active and the business requires it. Points history and transaction-linked rewards may be retained longer where accounting or tax rules apply.

When a member deletes their account or a business ends its program, data is deleted or anonymized within a defined period, except where the law requires retention. Backups roll off on a fixed schedule.

Members can request access to their data, correct inaccurate details, delete their profile, object to marketing, and withdraw consent for optional processing — by contacting the business running the program or emailing privacy@hololteck.com.

Depending on the member's location, additional rights under GDPR, Qatar's PDPPL or other laws may apply, including the right to complain to a supervisory authority.

The platform uses encryption in transit and at rest, role-based access controls, audit logging and vendor security reviews. No system is perfectly secure; businesses are encouraged to use strong administrator credentials and limit staff access to member data.

Holol Loyalty is designed for programs directed at adults. Businesses must not knowingly enroll children below the age required by local law, and any such data discovered is deleted.

We may update this policy as the platform evolves; material changes will be posted on this page with a revised date, and businesses will be notified where the change affects their obligations.

Contact: privacy@hololteck.com or ask@hololteck.com. HololTeck, Wyoming, USA — with a regional presence in Doha, Qatar.