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Privacy Notice Privacy policy All users


EU General Data Protection Regulation Privacy Notice For the Holo DevCamp

Full policy

This Privacy Notice applies to Holo’s DevCamp and is intended to comply with the European Union’s (“EU”) General Data Protection Regulation (“GDPR”). This Privacy Notice applies to personal data that Holo collects or processes about an individual (“Data Subject”) while the Data Subject is located in the EU, regardless of whether the Data Subject is a citizen or permanent resident of an EU country. “Personal Data” means any information relating to an identified or identifiable Data Subject.

Lawful Basis or Bases for Collecting and Processing Personal Data
Holo is a Gibraltar corporation that develops software frameworks and cloud hosting platforms, educates users and communities about development and design, and participates in various community engagement activities. The Holo DevCamp and associated websites collect, process and use Personal Data to administer online, blended, and face-to-face learning courses and programs on behalf of Holo.

Holo’s lawful basis or bases for collecting and processing personal data include the following:

• Processing is necessary for the legitimate interests pursued by Holo or third parties in providing tracking and grading for students using the Moodle learning management system.

• Processing is necessary for the performance of a contract to which the Data Subject is party or in order to take steps at the request of the Data Subject prior to entering into a contract.

• Processing is necessary for compliance with a legal obligation to which Holo is subject.

Types of Personal Data Collected/Processed and Purpose
Holo collects the following categories of Personal Data in order to provide a quality Moodle learning management system (LMS) experience for students and facilitators.

• Name

• Contact information including, without limitation, email address, IP address, and other location data

• Photographs of you

• Performance information

The Personal Data that Holo collects may be shared with: other third party Moodle LMS integrations related to Moodle.

If you have specific questions regarding the collection and use of your Personal Data, please contact our educational team at

If a Data Subject refuses to provide Personal Data that Holo requires in connection with one of Holo’s lawful basis or bases for collecting such Personal Data, such refusal may make it impossible for Holo to provide education, employment, research or other requested services.

Where Holo gets Personal and Sensitive Personal Data
Holo receives personal and sensitive Personal Data from multiple sources. Most often, Holo gets this data directly from the Data Subject or under the direction of the Data Subject who has provided it to a third party.

Individual Rights of the Data Subject under the GDPR
In addition to the right to receive the information provided in this Privacy Notice, Data Subjects covered by this Privacy Notice have the right to:

• Request from Holo access to and rectification or erasure of Personal Data or restriction of processing concerning the Data Subject, the right to object to processing and the right to portability of Personal Data;

• Where processing is based upon consent, to withdraw consent at any time, without affecting Holo’s right to process Personal Data based upon consent before its withdrawal;

• The right to file a complaint with a supervisory authority appointed by an EU member state for the purpose of receiving complaints;

• Additional notice of the existence of automated decision-making, including profiling;

• If the Personal Data is going to be further processed for a purpose other than that for which it was collected, then notice of the purpose and basis or bases for the further processing;

• If Personal Data is collected for Holo’s legitimate interests or for a task carried out in the public interest, then the Data Subject has the right to object, on the grounds of his or her particular situation, to the processing of Personal Data concerning him or her (including profiling);

• Where Personal Data are processed for direct marketing purposes, the right to object at any time to processing Personal Data concerning him or her for such marketing; and

• Not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her; provided, however, that this right does not apply if the decision is (a) necessary for entering into, or performance of, a contract between the Data Subject and Holo; or (b) is based upon the Data Subject’s consent.


Any Data Subject who wishes to exercise any of the above-mentioned rights may do so by filling such request with the legal contact at Holo at

Cookies are files that many websites transfer to users’ web browsers to enable the site to deliver personalized services or to provide persistent authentication. The information contained in a cookie typically includes information collected automatically by the web server and/or information provided voluntarily by the user. Holo’s website uses persistent cookies in conjunction with a third party technology partner to analyze search engine usage and web traffic patterns. This information is used in the aggregate to monitor and enhance our web pages. It is not used to track the usage patterns of individual users.

Security of Personal Data subject to the EU GDPR
All Personal Data and sensitive Personal Data collected or processed by Holo Ltd under the scope of the GDPR must comply with the security controls and systems and process requirements and standards set forth in Holo’s Policies and Procedures as they are amended from time-to-time, including without limitation:

Holo Ltd will not share your Personal Data with third parties except:

• as necessary to meet one of its lawful purposes, including but not limited to, its legitimate interest, contract compliance, pursuant to consent provided by the Data Subject, or as required by law;

• as necessary to protect Holo’s interests;

• with service providers acting on Holo’s behalf who have agreed to protect the confidentiality of the Personal Data.

Data Retention
Holo Ltd maintains records for the time periods specified in its Records Retention and Disposal Policy.