1. Who we are

Holicay ("Holicay", "we", "us", or "our") provides a travel content and commerce platform that enables creators and promoters to publish, promote, and sell digital itineraries and related services.

Data Controller: For personal data collected via our websites and services, Holicay is the controller. Where we process data on behalf of a creator (e.g., fulfilling a creator’s orders or communicating with their audience), we act as a processor.

Contact (privacy): [email protected] · Mailing: Holicay, Attn: Privacy, 123 Example St, City, Country.

2. Data we collect

Information you provide

  • Account & profile data (name, email, password, photo, biography, brand details).
  • Content you submit (texts, images, itineraries, reviews, messages).
  • Payment & payout details (billing address, transaction info; payouts may require tax and ID information subject to applicable law).
  • Communications with us (support requests, feedback, surveys).

Information we collect automatically

  • Usage data (pages viewed, features used, links clicked, referring/exit pages, timestamps).
  • Device & log data (IP address, browser type, operating system, language, crash logs).
  • Approximate location (derived from IP for fraud prevention, analytics, and localization).
  • Cookies and similar technologies (see Cookies).

Information from third parties

  • Analytics and marketing partners (aggregated engagement metrics).
  • Payment processors and anti‑fraud providers (to complete transactions and prevent abuse).
  • Social or single sign‑on providers (if you choose to connect your account).

3. How we use data

  • Provide and operate the Services (create and manage accounts, enable purchases, payouts, and promotions).
  • Personalize content and recommendations; remember preferences.
  • Measure performance, debug, and improve our Services.
  • Prevent fraud, abuse, and security incidents; enforce terms and policies.
  • Communicate with you (service messages, updates, marketing with your consent or as permitted by law).
  • Comply with legal obligations and protect our rights and users.

5. Cookies & similar technologies

We use cookies, web beacons, and local storage to keep you signed in, remember preferences, analyze traffic, and support marketing. Some cookies are essential to the website; others are optional.

Categories we use

  • Strictly necessary — required for core site functionality and security.
  • Analytics — help us understand usage to improve the product.
  • Advertising — measure ads and deliver relevant promotions.
  • Functional — enhance features (e.g., remembering preferences).

You can manage preferences at any time: Open cookie settings.

Browser settings may allow you to block cookies entirely; doing so might impact some features.

6. How we share information

  • Service providers that process data for us (hosting, analytics, email, payments, fraud prevention, customer support). They must follow our instructions and appropriate safeguards.
  • Creators & promoters when necessary to fulfill a transaction you initiate (e.g., providing purchase details so a creator can deliver content).
  • Legal & safety — to comply with law, respond to lawful requests, or protect rights, property, or safety of users and the public.
  • Business transfers — in connection with a merger, acquisition, financing, or sale of assets.

We do not sell your personal information for money. Where applicable law defines "sale" or "sharing" more broadly (e.g., for targeted advertising), you can opt out via privacy request or cookie settings.

7. Data retention

We keep personal data only as long as necessary for the purposes described in this policy, to comply with legal obligations, resolve disputes, and enforce agreements. Retention periods vary by data type and context.

8. International data transfers

We operate globally and may transfer personal data to countries that may not provide the same level of protection as your home jurisdiction. When we do, we use appropriate safeguards (e.g., Standard Contractual Clauses) and take steps to protect your information.

9. Your rights

Depending on your location, you may have rights to:

  • Access, correct, update, or delete your personal data.
  • Object to or restrict processing; withdraw consent.
  • Data portability (receive a copy in a usable format).
  • Opt out of targeted advertising, profiling, or certain disclosures.

To exercise rights, submit a request at /privacy-request or email [email protected]. We will verify your request consistent with applicable law. You may authorize an agent where permitted.

If we deny your request (where allowed by law), you may appeal by replying to our decision email with "Appeal" in the subject line.

10. U.S. state privacy disclosures

If you are a resident of California, Colorado, Connecticut, Utah, Virginia, or other U.S. states with privacy laws, you may have additional rights, including to opt out of the "sale" or "sharing" of personal information for targeted advertising. Use our privacy request portal or cookie settings to exercise those options.

Categories of personal information we may collect include identifiers, commercial information, internet activity, geolocation (approximate), and inferences. We collect these from you, your devices, and service providers, for the purposes described in this policy. We retain them as described above and disclose them to service providers and partners as needed to provide and improve our Services.

11. Children

Our Services are not directed to children under 13 (or the equivalent minimum age in your jurisdiction). We do not knowingly collect personal data from children. If you believe a child has provided personal data to us, please contact us and we will take appropriate steps.

12. Security

We use technical and organizational measures designed to protect personal data (encryption in transit, access controls, monitoring). No system is completely secure; please use strong, unique passwords and keep them confidential.

13. Changes to this policy

We may update this policy from time to time. We will post the updated version here and revise the "Last updated" date. If changes materially affect your rights, we will provide additional notice (e.g., email or prominent in‑product notice).

14. Contact us

Email: [email protected]

Mailing: Holicay, Attn: Privacy, 123 Example St, City, Country

For security or abuse reports, email [email protected].