Privacy Policy

Last updated: Dec 31, 2023

This Privacy Policy describes Our policies and procedures on the collection,
use and disclosure of Your information when You use the Service and tells You
about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the
Service, You agree to the collection and use of information in accordance with
this Privacy Policy.

Interpretation and Definitions


The words of which the initial letter is capitalized have meanings defined
under the following conditions. The following definitions shall have the same
meaning regardless of whether they appear in singular or in plural.


For the purposes of this Privacy Policy:

  • Account means a unique account created for You to access
    our Service or parts of our Service.
  • Application means the software program provided by the
    Company downloaded by You on any electronic device, named HODL it!
  • Company (referred to as either “the Company”,
    “We”, “Us” or “Our” in this Agreement)
    refers to InnoCreatix OÜ.For the purpose of the GDPR, the Company is the Data Controller.
  • Country refers to: Tallinn, Estonia
  • Data Controller, for the purposes of the GDPR (General
    Data Protection Regulation), refers to the Company as the legal person
    which alone or jointly with others determines the purposes and means of
    the processing of Personal Data.
  • Device means any device that can access the Service such
    as a computer, a cellphone or a digital tablet.
  • Do Not Track (DNT) is a concept that has been promoted by
    US regulatory authorities, in particular the U.S. Federal Trade Commission
    (FTC), for the Internet industry to develop and implement a mechanism for
    allowing internet users to control the tracking of their online activities
    across websites.
  • Personal Data is any information that relates to an
    identified or identifiable individual.For the purposes for GDPR, Personal Data means any information relating to
    You such as a name, an identification number, location data, online
    identifier or to one or more factors specific to the physical,
    physiological, genetic, mental, economic, cultural or social identity.
  • Service refers to the Application.
  • Service Provider means any natural or legal person who
    processes the data on behalf of the Company. It refers to third-party
    companies or individuals employed by the Company to facilitate the
    Service, to provide the Service on behalf of the Company, to perform
    services related to the Service or to assist the Company in analyzing how
    the Service is used. For the purpose of the GDPR, Service Providers are
    considered Data Processors.
  • Usage Data refers to data collected automatically, either
    generated by the use of the Service or from the Service infrastructure
    itself (for example, the duration of a page visit).
  • You means the individual accessing or using the Service,
    or the company, or other legal entity on behalf of which such individual
    is accessing or using the Service, as applicable.Under GDPR (General Data Protection Regulation), You can be referred to as
    the Data Subject or as the User as you are the individual using the

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally
identifiable information that can be used to contact or identify You.
Personally identifiable information may include, but is not limited to:

  • Email address
  • Usage Data

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device’s Internet Protocol
address (e.g. IP address), browser type, browser 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 and other diagnostic data.

When You access the Service by or through a mobile device, We may collect
certain information automatically, including, but not limited to, 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.

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.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

  • To provide and maintain our Service, including to monitor
    the usage of our Service.
  • To manage Your Account: to manage Your registration as a
    user of the Service. The Personal Data You provide can give You access to
    different functionalities of the Service that are available to You as a
    registered user.
  • For the performance of a contract: the development,
    compliance and undertaking of the purchase contract for the products, items
    or services You have purchased or of any other contract with Us through the
  • To contact You: To contact You by email, telephone calls,
    SMS, or other equivalent forms of electronic communication, such as a mobile
    application’s push notifications regarding updates or informative
    communications related to the functionalities, products or contracted
    services, including the security updates, when necessary or reasonable for
    their implementation.
  • 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.
  • To manage Your requests: To attend and manage Your requests
    to Us.
  • To deliver targeted advertising to You: We may use Your
    information to develop and display content and advertising (and work with
    third-party vendors who do so) tailored to Your interests and/or location
    and to measure its effectiveness.
  • For business transfers: We may use Your information to
    evaluate or conduct a merger, divestiture, restructuring, reorganization,
    dissolution, or other sale or transfer of some or all of Our assets, whether
    as a going concern or as part of bankruptcy, liquidation, or similar
    proceeding, in which Personal Data held by Us about our Service users is
    among the assets transferred.
  • For other purposes: We may use Your information for other
    purposes, such as data analysis, identifying usage trends, determining the
    effectiveness of our promotional campaigns and to evaluate and improve our
    Service, products, services, marketing and your experience.

We may share Your personal information in the following situations:

  • With Service Providers: We may share Your personal
    information with Service Providers to monitor and analyze the use of our
    Service, to advertise on third party websites to You after You visited our
    Service, for payment processing, to contact You.
  • For business transfers: We may share or transfer Your
    personal information in connection with, or during negotiations of, any
    merger, sale of Company assets, financing, or acquisition of all or a
    portion of Our business to another company.
  • With business partners: We may share Your information with
    Our business partners to offer You certain products, services or promotions.
  • With other users: when You share personal information or
    otherwise interact in the public areas with other users, such information
    may be viewed by all users and may be publicly distributed outside.
  • With Your consent: We may disclose Your personal
    information for any other purpose with Your consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary
for the purposes set out in this Privacy Policy. We will retain and use Your
Personal Data to the extent necessary to comply with our legal obligations
(for example, if we are required to retain your data to comply with applicable
laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage
Data is generally retained for a shorter period of time, except when this data
is used to strengthen the security or to improve the functionality of Our
Service, or We are legally obligated to retain this data for longer time

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s
operating offices and in any other places where the parties involved in the
processing are located. It means that this information 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
than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such
information represents Your agreement to that transfer.

The Company 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 organization or a country unless
there are adequate controls in place including the security of Your data and
other personal information.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your
Personal Data may be transferred. We will provide notice before Your Personal
Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your
Personal Data if required to do so by law or in response to valid requests by
public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such
action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability

Security of Your Personal Data

The security of Your Personal 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.

Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to Your Personal Data. These
third-party vendors collect, store, use, process and transfer information
about Your activity on Our Service in accordance with their Privacy Policies.


We may use third-party Service providers to monitor and analyze the use of our

  • Google AnalyticsGoogle Analytics is a web analytics service offered by Google that tracks
    and reports website traffic. Google uses the data collected to track and
    monitor the use of our Service. This data is shared with other Google
    services. Google may use the collected data to contextualize and
    personalize the ads of its own advertising network.You may opt-out of certain Google Analytics features through your mobile
    device settings, such as your device advertising settings or by following
    the instructions provided by Google in their Privacy Policy:

    For more information on the privacy practices of Google, please visit the
    Google Privacy & Terms web page:

Email Marketing

We may use Your Personal Data to contact You with newsletters, marketing or
promotional materials and other information that may be of interest to You.
You may opt-out of receiving any, or all, of these communications from Us by
following the unsubscribe link or instructions provided in any email We send
or by contacting Us.

We may use Email Marketing Service Providers to manage and send emails to You.


We may provide paid products and/or services within the Service. In that case,
we may use third-party services for payment processing (e.g. payment

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.

Behavioral Remarketing

The Company uses remarketing services to advertise to You after You accessed
or visited our Service. We and Our third-party vendors use cookies and
non-cookie technologies to help Us recognize Your Device and understand how
You use our Service so that We can improve our Service to reflect Your
interests and serve You advertisements that are likely to be of more interest
to You.

These third-party vendors collect, store, use, process and transfer
information about Your activity on Our Service in accordance with their
Privacy Policies and to enable Us to:

  • Measure and analyze traffic and browsing activity on Our Service
  • Show advertisements for our products and/or services to You on third-party
    websites or apps
  • Measure and analyze the performance of Our advertising campaigns

Some of these third-party vendors may use non-cookie technologies that may not
be impacted by browser settings that block cookies. Your browser may not
permit You to block such technologies. You can use the following third-party
tools to decline the collection and use of information for the purpose of
serving You interest-based advertising:

You may opt-out of all personalized advertising by enabling privacy features
on Your mobile device such as Limit Ad Tracking (iOS) and Opt Out of Ads
Personalization (Android). See Your mobile device Help system for more

We may share information, such as hashed email addresses (if available) or
other online identifiers collected on Our Service with these third-party
vendors. This allows Our third-party vendors to recognize and deliver You ads
across devices and browsers. To read more about the technologies used by these
third-party vendors and their cross-device capabilities please refer to the
Privacy Policy of each vendor listed below.

The third-party vendors We use are:

  • Google Ads (AdWords)Google Ads (AdWords) remarketing service is provided by Google Inc.You can opt-out of Google Analytics for Display Advertising and customise
    the Google Display Network ads by visiting the Google Ads Settings page: also recommends installing the Google Analytics Opt-out Browser
    Add-on –
    – for your web browser. Google Analytics Opt-out Browser Add-on provides
    visitors with the ability to prevent their data from being collected and
    used by Google Analytics.

    For more information on the privacy practices of Google, please visit the
    Google Privacy & Terms web page:

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

  • Consent: You have given Your consent for processing
    Personal Data for one or more specific purposes.
  • Performance of a contract: Provision of Personal Data is
    necessary for the performance of an agreement with You and/or for any
    pre-contractual obligations thereof.
  • Legal obligations: Processing Personal Data is necessary
    for compliance with a legal obligation to which the Company is subject.
  • Vital interests: Processing Personal Data is necessary in
    order to protect Your vital interests or of another natural person.
  • Public interests: Processing Personal Data is related to a
    task that is carried out in the public interest or in the exercise of
    official authority vested in the Company.
  • Legitimate interests: Processing Personal Data is necessary
    for the purposes of the legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legal basis
that applies to the processing, and in particular whether the provision of
Personal Data is a statutory or contractual requirement, or a requirement
necessary to enter into a contract.

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data
and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the
EU, to:

  • Request access to Your Personal Data. The right to access,
    update or delete the information We have on You. Whenever made possible, you
    can access, update or request deletion of Your Personal Data directly within
    Your account settings section. If you are unable to perform these actions
    yourself, please contact Us to assist You. This also enables You to receive
    a copy of the Personal Data We hold about You.
  • Request correction of the Personal Data that We hold about You.
    You have the right to have any incomplete or inaccurate information We hold
    about You corrected.
  • Object to processing of Your Personal Data. This right
    exists where We are relying on a legitimate interest as the legal basis for
    Our processing and there is something about Your particular situation, which
    makes You want to object to our processing of Your Personal Data on this
    ground. You also have the right to object where We are processing Your
    Personal Data for direct marketing purposes.
  • Request erasure of Your Personal Data. You have the right
    to ask Us to delete or remove Personal Data when there is no good reason for
    Us to continue processing it.
  • Request the transfer of Your Personal Data. We will provide
    to You, or to a third-party You have chosen, Your Personal Data in a
    structured, commonly used, machine-readable format. Please note that this
    right only applies to automated information which You initially provided
    consent for Us to use or where We used the information to perform a contract
    with You.
  • Withdraw Your consent. You have the right to withdraw Your
    consent on using your Personal Data. If You withdraw Your consent, We may
    not be able to provide You with access to certain specific functionalities
    of the Service.

Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and
opposition by contacting Us. Please note that we may ask You to verify Your
identity before responding to such requests. If You make a request, We will
try our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our
collection and use of Your Personal Data. For more information, if You are in
the European Economic Area (EEA), please contact Your local data protection
authority in the EEA.

Our Service does not respond to Do Not Track signals.

However, some third party websites do keep track of Your browsing activities.
If You are visiting such websites, You can set Your preferences in Your web
browser to inform websites that You do not want to be tracked. You can enable
or disable DNT by visiting the preferences or settings page of Your web

Children’s Privacy

Our Service does not address anyone under the age of 13. We do not knowingly
collect personally identifiable information from anyone under the age of 13.
If You are a parent or guardian and You are aware that Your child has provided
Us with Personal Data, please contact Us. If We become aware that We have
collected Personal Data from anyone under the age of 13 without verification
of parental consent, We take steps to remove that information from Our

If We need to rely on consent as a legal basis for processing Your information
and Your country requires consent from a parent, We may require Your parent’s
consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us.
If You click on 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

We have no control over and assume no responsibility for the content, privacy
policies or practices of any third party sites or services.

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 “Last updated” 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


Read the Disclaimer from here

Contact Us

If you have any questions about this Privacy Policy, You can contact us: [email protected]