Privacy Policy

Last updated: January 4, 2026

Introduction​

Welcome to Hashgraph Online DAO LLC.

Hashgraph Online DAO LLC ("us", "we", or "our") operates https://hol.org (the "Service"). This Privacy Policy governs your visit to the Service and explains how we collect, safeguard, and disclose information that results from your use of it. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise noted, capitalized terms have the same meaning as in our Terms and Conditions.

Our Terms and Conditions ("Terms") govern all use of the Service and together with this Privacy Policy constitute your agreement with us (the "Agreement").

Definitions​

• Service: The https://hol.org website operated by Hashgraph Online DAO LLC.
• Personal Data: Data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
• Usage Data: Data collected automatically, generated by the use of the Service or from Service infrastructure itself (for example, the duration of a page visit).
• Cookies: Small files stored on your device (computer or mobile device).
• Data Controller: A natural or legal person who determines the purposes for which and the manner in which any personal data are processed. For this Privacy Policy, we are the Data Controller of your data.
• Data Processors (or Service Providers): Any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers to process your data more effectively.
• Data Subject: Any living individual who is the subject of Personal Data.
• The User: The individual using our Service, corresponding to the Data Subject.

Information Collection and Use​

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected​

Personal Data​

While using our Service, we may ask you to provide certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to:

• Email address and other contact information you provide when creating or accessing an account
• Hedera wallet addresses (account IDs) you connect to your account
• Telegram account identifiers, profile information, or metadata you authorize us to receive through Telegram login, such as your Telegram user ID or username
• Twitter/X account information including username, profile data, and verification status when you link your account
• GitHub account information including username and profile data when you link your account
• LinkedIn account information when you link your account
• Any verification status associated with those contact methods (for example, whether your email has been confirmed)
• Support communications or preferences tied to your contact information
• Cookies and Usage Data

Usage Data​

We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device ("Usage Data"). This Usage Data may include information such as:

• Your computer's IP address (stored for security and session management purposes)
• Browser type and version
• The pages of our Service that you visit
• The time and date of your visit
• The time spent on those pages
• Unique device identifiers
• User agent strings
• Referral URLs and attribution data (UTM parameters, campaign sources)
• Other diagnostic data

When you access the Service with a mobile device, Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers, and other diagnostic data.

Tracking Cookies Data​

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information. Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags, and scripts to collect and track information and to improve and analyze our Service.

Cookie Consent: If you are located in the European Union (EU), European Economic Area (EEA), United Kingdom, or Switzerland, we will obtain your explicit consent before placing non-essential cookies on your device. You can manage your cookie preferences at any time through the "Cookie Settings" link in our website footer or through your browser settings.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept essential cookies, you may not be able to use some portions of our Service.

Types of cookies we use:

• Essential Cookies: Required for basic site functionality, authentication, and security. Cannot be disabled.
• Analytics Cookies: Used to understand how visitors interact with our Service. Requires consent in GDPR regions.
• Marketing Cookies: Used to serve you with advertisements that may be relevant to you and your interests. Requires consent in GDPR regions.

Lawful Basis for Processing (GDPR)​

Under the General Data Protection Regulation (GDPR), we process your personal data based on the following lawful bases:

Use of Data​

Hashgraph Online DAO LLC uses the collected data for various purposes:

• To provide and maintain our Service
• To authenticate you and allow you to access your account, including sending verification or transactional emails related to login or account activity
• To process Telegram-based authentication, including verifying Telegram credentials and communicating app notifications permissible under Telegram's policies
• To notify you about changes to our Service
• To respond to inquiries or support requests you send via email or other contact channels
• To allow you to participate in interactive features of our Service when you choose to do so
• To provide customer support
• To gather analysis or valuable information so that we can improve our Service
• To monitor the usage of our Service
• To detect, prevent, and address technical issues
• To fulfill any other purpose for which you provide data
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection
• To provide you with notices about your account and/or subscription, including expiration and renewal notices, email instructions, etc.
• To provide you with news, special offers, and general information about other goods, services, and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information
• In any other way we may describe when you provide the information
• For any other purpose with your consent

Data Retention Periods​

We retain your personal data for specific periods based on the type of data:

After these retention periods, data is either permanently deleted or anonymized so it can no longer be associated with you.

Transfer of Data​

Your information, including Personal Data, may be transferred to—and maintained on—computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Hashgraph Online DAO LLC will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy, and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place, including the security of your data and other personal information.

Disclosure of Data​

We may disclose personal information that we collect, or you provide:

• Disclosure for Law Enforcement: Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities.
• Business Transaction: If we or our subsidiaries are involved in a merger, acquisition, or asset sale, your Personal Data may be transferred.
• Other Cases: We may disclose your information to our subsidiaries and affiliates and if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.

Security of Data​

The security of your data is important to us, but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Our security measures include:

• Encryption of data in transit (HTTPS/TLS)
• Secure password hashing using industry-standard algorithms
• Regular security audits and vulnerability assessments
• Access controls limiting who can view personal data

Your Data Protection Rights Under the General Data Protection Regulation (GDPR)​

If you are a resident of the European Union (EU) and European Economic Area (EEA), you have certain data protection rights covered by the GDPR (https://eur-lex.europa.eu/eli/reg/2016/679/oj). We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

Exercising Your Rights​

You can exercise most of your data rights directly through our platform:

• Data Export: Visit your Privacy Settings page to download a copy of all your personal data in JSON format.
• Account Deletion: Visit your Privacy Settings page to delete your account and remove your personal data.
• Cookie Preferences: Click "Cookie Settings" in the website footer to manage your consent preferences.

For other requests or if you need assistance, please email us at help@hashgraphonline.com.

Your Rights Include:​

• Right of Access: The right to obtain a copy of your personal data we hold about you.
• Right of Rectification: The right to have inaccurate personal data corrected.
• Right of Erasure: The right to have your personal data deleted ("right to be forgotten").
• Right to Object: The right to object to our processing of your personal data.
• Right of Restriction: The right to request that we restrict the processing of your personal data.
• Right to Data Portability: The right to receive your personal data in a structured, machine-readable format.
• Right to Withdraw Consent: The right to withdraw consent at any time where we rely on consent to process your personal data.

We may ask you to verify your identity before responding to such requests, and we may not be able to provide Service without some necessary data. You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Your Data Protection Rights under the California Online Privacy Protection Act (CalOPPA)​

CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law's reach stretches well beyond California to require any person or company in the United States (and conceivable the world) that operates websites collecting personally identifiable information from California consumers to post a conspicuous privacy policy on its website stating the information being collected, with whom it is shared, and to comply with this policy. Learn more at https://consumercal.org/about-cfc/cfc-education-foundation/california-online-privacy-protection-act-caloppa-3/.

According to CalOPPA we agree to the following:

• Users can visit our site anonymously.
• Our Privacy Policy link includes the word "Privacy" and can easily be found on the page specified above on the home page of our website.
• Users will be notified of any privacy policy changes on our Privacy Policy Page.
• Users are able to change their personal information by emailing us at help@hashgraphonline.com.

Our Policy on "Do Not Track" Signals​

We honor Do Not Track signals and do not track, plant cookies, or use advertising when a Do Not Track browser mechanism is in place. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Your Privacy Rights Under the California Consumer Privacy Act (CCPA/CPRA)​

If you are a California resident, you have specific rights under the California Consumer Privacy Act as amended by the California Privacy Rights Act (collectively, "CCPA"). This section describes your CCPA rights and how to exercise them.

Categories of Personal Information We Collect​

Under the CCPA, "personal information" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. We collect the following categories of personal information:

Purposes for Collection and Use​

We collect personal information for the following purposes:

• To provide and maintain our Service
• To process your transactions and manage your account
• To communicate with you about your account
• For analytics and service improvement
• For security and fraud prevention
• To comply with legal obligations

Your CCPA Rights​

As a California resident, you have the following rights:

1. Right to Know: You have the right to request that we disclose:

   • The categories of personal information we have collected about you
   • The categories of sources from which personal information was collected
   • The business or commercial purposes for collecting or selling personal information
   • The categories of third parties with whom we share personal information
   • The specific pieces of personal information we have collected about you

2. Right to Delete: You have the right to request that we delete personal information we collected from you, subject to certain exceptions.

3. Right to Correct: You have the right to request that we correct inaccurate personal information we maintain about you.

4. Right to Opt-Out of Sale/Sharing: You have the right to opt out of the "sale" or "sharing" of your personal information for cross-context behavioral advertising purposes.

5. Right to Limit Use of Sensitive Personal Information: If we collected sensitive personal information, you would have the right to limit its use. However, we do not currently collect sensitive personal information as defined by the CCPA.

6. Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights.

Exercising Your Rights​

To exercise your CCPA rights, you may:

• Self-Service: Visit your Privacy Settings page to download your data or delete your account
• Email: Submit a request to help@hashgraphonline.com with "CCPA Request" in the subject line

We will verify your identity before processing your request. For requests submitted via email, we may ask you to provide information that matches information we have on file.

Response Time: We will respond to verifiable requests within 45 days. If we need additional time (up to 90 days total), we will inform you of the reason and extension period in writing.

Sale and Sharing of Personal Information​

We do not sell your personal information as defined by the CCPA. We do not receive monetary consideration in exchange for your personal information.

Sharing for Cross-Context Behavioral Advertising: We may share certain information with analytics providers (such as Google Analytics) for analytics purposes. You can opt out of this sharing by:

• Adjusting your Cookie Preferences via the "Cookie Settings" link in the footer
• Using the Google Analytics Opt-out Browser Add-on

Authorized Agents​

You may designate an authorized agent to submit CCPA requests on your behalf. To do so, you must provide the authorized agent written permission to submit requests on your behalf and verify your identity directly with us.

Financial Incentives​

We do not offer financial incentives for the collection, sale, or deletion of personal information.

California's "Shine the Light" Law​

California Civil Code Section 1798.83 permits users who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not disclose personal information to third parties for their direct marketing purposes.

Privacy Rights for Residents of Other US States​

Several US states have enacted comprehensive privacy laws similar to the CCPA. If you are a resident of Virginia, Colorado, Connecticut, Utah, Texas, Oregon, or Montana, you have rights under your state's privacy law.

Common Rights Under State Privacy Laws​

Residents of states with comprehensive privacy laws generally have the following rights:

1. Right to Access: The right to confirm whether we are processing your personal data and to access that data.
2. Right to Delete: The right to request deletion of your personal data.
3. Right to Correct: The right to correct inaccurate personal data.
4. Right to Data Portability: The right to obtain a copy of your data in a portable format.
5. Right to Opt-Out: The right to opt out of:
   • Targeted advertising
   • Sale of personal data (where applicable)
   • Profiling in furtherance of decisions that produce legal or similarly significant effects

State-Specific Information​

How to Exercise Your Rights​

To exercise your privacy rights under any state law:

• Self-Service: Visit your Privacy Settings page
• Email: Contact us at help@hashgraphonline.com with your state and request type in the subject line

Appeals Process​

If we decline to take action on your request, you have the right to appeal our decision. To appeal, please email help@hashgraphonline.com with "Privacy Appeal" in the subject line within 60 days of receiving our response. We will respond to your appeal within 60 days.

If you are not satisfied with our appeal response, you may contact your state's Attorney General to file a complaint.

Service Providers​

We may employ third-party companies and individuals to facilitate our Service ("Service Providers"), provide the Service on our behalf, perform Service-related services, or assist us in analysing how our Service is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Third-Party Data Processors​

We use the following third-party service providers who may process your personal data:

Analytics​

Email Services​

Infrastructure​

Authentication​

All third-party service providers are contractually bound to protect your data and use it only for the specific purposes outlined. Where required, we have Data Processing Agreements (DPAs) in place with these providers.

CI/CD Tools​

GitHub​

GitHub, provided by GitHub, Inc., is a development platform to host and review code, manage projects, and build software. For more information on what data GitHub collects, for what purpose, and how the protection of the data is ensured, please visit the GitHub Privacy Policy page: https://help.github.com/en/articles/github-privacy-statement.

Payments​

We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g., payment processors). We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express, and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

The payment processors we work with are:

• PayPal or Braintree: https://www.paypal.com/webapps/mpp/ua/privacy-full
• Apple Store In-App Payments: https://www.apple.com/legal/privacy/en-ww/ / https://support.apple.com/en-us/HT203027
• Google Play In-App Payments: https://policies.google.com/privacy?hl=en&gl=us / https://payments.google.com/payments/apis-secure/u/0/get_legal_document?ldo=0&ldt=privacynotice&ldl=en

Links to Other Sites​

Our Service may contain links to other sites that are not operated by us. If you click a third-party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Children's Privacy​

Our Services are not intended for use by children under the age of 13 ("Children"). We do not knowingly collect personally identifiable information from Children under 13. If you become aware that a Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information from our servers.

For users in the European Union, the minimum age for consent to data processing is 16 years (or lower as specified by individual EU member states, but not below 13 years).

Data Breach Notification​

In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, we will:

1. Notify the relevant supervisory authority within 72 hours of becoming aware of the breach
2. Notify affected individuals without undue delay if the breach is likely to result in a high risk to their rights and freedoms
3. Document the breach, its effects, and the remedial action taken

Changes to This Privacy Policy​

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via email and/or a prominent notice on our Service prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us​

If you have any questions about this Privacy Policy, please contact us:

• Email: help@hashgraphonline.com
• Data Protection Inquiries: For GDPR-specific inquiries, please include "GDPR Request" in your email subject line.

Response Times​

We aim to respond to all data protection requests within:

• GDPR requests: 30 days (as required by law)
• General inquiries: 5 business days