Last Updated: November 10, 2025

1. Overview

HOLOS INC (“HOLOS,” “we,” “us,” or “our”) respects your privacy and is committed to protecting it. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you:

Visit our websites,

Use our online training and coaching platforms, or

Communicate with us by email, text, or other electronic means

(collectively, the “Platform”).

Please read this Privacy Policy carefully so you understand our practices regarding your personal information. If you do not agree with this Policy, do not use the Platform.

By accessing or using the Platform, you acknowledge that you have read this Privacy Policy and consent to the handling of your information as described here.

We may update this Privacy Policy from time to time. Changes are effective when we post the revised Policy on the Platform. Your continued use of the Platform after any changes means you accept the updated Policy, so please review it periodically.

This Privacy Policy forms part of, and is governed by, any applicable Terms of Service or similar agreement covering your use of the Platform.

2. Information We Collect and How We Collect It

We may collect two broad categories of information about you when you interact with the Platform: Personal Information and Non-Personal Information (together, “Information”).

2.1 Personal Information

“Personal Information” is information that identifies or can reasonably be used to identify you, such as:

Name

Email address

Telephone number

Postal address

Employer / organization

Job title or role

Account credentials (such as login ID)

Billing and payment information (handled via our payment processors)

2.2 Non-Personal Information

“Non-Personal Information” is information that relates to you but does not, by itself, identify you. This may include:

Browser type and version

Device type and operating system

Referring URLs

Pages viewed and links clicked

Time and duration of visits

General location based on IP address

Aggregated or anonymized usage statistics

If you simply browse the Platform without submitting any forms or creating an account, we may still collect Non-Personal Information about your visit.

2.3 How We Collect Information

We collect Information in three main ways:

(a) Directly from You

You may provide Personal Information to us when you:

Create an account or profile on the Platform

Enroll in or use training programs, courses, or services

Request information, resources, or support

Sign up for newsletters, events, or webinars

Make a purchase or enter payment details via our payment partners

Communicate with us by email, phone, or other channels

If you provide Personal Information about someone else (e.g., a team member you enroll), you are responsible for ensuring you have the authority and any necessary consent to do so and for allowing us to use that information as described in this Privacy Policy.

(b) From Third Parties

We may receive Information about you from third parties, including:

Marketing and advertising partners

Data and analytics providers

Event hosts and conference organizers

Social media platforms, if you interact with our profiles or connect accounts

Service providers that support our Platform (e.g., payment processors, CRM tools)

Organizations that license or provide HOLOS Services to their teams or members

We take reasonable steps to confirm that such third parties are permitted to share your Personal Information with us and that it was collected lawfully.

We may combine Personal Information from different sources—including from you directly and from third parties—to improve the accuracy and completeness of our records and to better serve you.

(c) Automatically Through the Platform

We automatically collect certain information as you navigate and use the Platform through cookies, pixels, logs, and similar technologies. This may include:

IP address

Device identifiers

Browser type and settings

Usage data (pages viewed, actions taken, session duration)

We use this information for functionality, security, analytics, and personalization. For more details about cookies and how to manage them, please refer to our Cookies Policy (if published) or the cookie settings on the Platform.

3. How We Use Personal Information

We use the Personal Information we collect for the following purposes:

3.1 To Operate, Provide, and Improve the Platform and Services

We use your information to:

Deliver and support the Platform and HOLOS services

Set up and maintain your account

Personalize your experience, content, and training journey

Diagnose technical issues and maintain security

Monitor usage, performance, and reliability

Develop, test, and improve existing offerings and create new features or programs

Some features may use artificial intelligence or automation to enhance the experience (for example, personalized content suggestions). We do not use your Personal Information to develop or train generalized AI or machine learning models that are unrelated to providing services to you or your organization.

3.2 Customer Support and Service

We process your Personal Information to:

Provide technical and user support

Respond to questions, concerns, and feedback

Resolve issues and improve service quality

Confirm eligibility for certain offers, trials, or promotions

3.3 Business Operations

We use Personal Information for our internal business purposes, such as:

Billing, accounting, and financial reporting

Auditing, reconciliation, and compliance

Fraud monitoring, security, and risk management

Enforcement of our contracts, Terms of Service, and other agreements

Protecting our rights, property, and the rights and safety of others

3.4 Communication

We use your contact information to:

Send transactional messages (e.g., account confirmation, receipts, service notices)

Notify you about changes to the Platform, policies, or terms

Provide educational or training-related updates and content

Send marketing emails, newsletters, or invitations (where permitted by law and your preferences)

You can change your communication preferences or unsubscribe from marketing emails at any time using the links in those emails or by contacting us as described in the “How to Contact Us” section below.

3.5 Advertising and Marketing

Where permitted by law, we may use your Personal Information:

To tailor content, offers, and recommendations

To understand what materials, topics, and services are most relevant to you

To evaluate the effectiveness of our marketing campaigns

We may work with third-party advertising and analytics providers that use cookies or similar technologies on our Platform. You can manage many of these technologies through your browser settings and our cookie controls where available.

3.6 Analytics and Statistics

We may aggregate and anonymize data for reporting and analytics, such as:

Understanding how users engage with the Platform

Identifying trends in content usage and service demand

Improving user experience and training effectiveness

Aggregated or anonymized data is not considered Personal Information because it cannot reasonably identify you.

4. Legal Bases for Processing (EEA and UK Visitors) & Data Retention

4.1 Legal Bases (EEA/UK Only)

If you are located in the European Economic Area (EEA) or the United Kingdom, we process your Personal Information under one or more of the following legal bases:

Consent – When you have given us permission to process your Personal Information for a specific purpose (e.g., subscribing to a marketing newsletter).

Contract – When processing is necessary to perform a contract with you or to take steps at your request before entering into a contract (e.g., providing access to paid training).

Legal Obligation – When we must process your Personal Information to comply with applicable law or regulatory obligations.

Legitimate Interests – When processing is necessary for our legitimate business interests (such as improving our services, preventing fraud, or securing our systems) and those interests are not overridden by your rights and interests.

If we ask you to provide Personal Information because it is required by law or a contract, we will tell you at the time of collection and explain the consequences of not providing it.

4.2 Retention of Your Personal Information

We retain your Personal Information only for as long as reasonably necessary to:

Fulfill the purposes described in this Privacy Policy

Provide and support the Platform and our services

Comply with legal, regulatory, tax, and accounting requirements

Resolve disputes and enforce our agreements

To determine an appropriate retention period, we consider:

The amount, nature, and sensitivity of the Personal Information

The potential risk of harm from unauthorized use or disclosure

The purposes for which we process it and whether these can be achieved by other means

Applicable legal and regulatory requirements

In some circumstances, we may anonymize your Personal Information so that it can no longer identify you. We may then use that information indefinitely without further notice.

You may have the right to request deletion of your Personal Information; see “Your Legal Rights” below.

5. How We Protect Your Information

We use reasonable and appropriate administrative, technical, and organizational safeguards designed to protect your Personal Information against:

Accidental or unlawful destruction or loss

Unauthorized disclosure, access, or alteration

Misuse or other unlawful processing

We also require our service providers and vendors that handle Personal Information on our behalf to implement suitable protections and to process such information only as instructed.

However, no system or data transmission over the internet can be guaranteed to be 100% secure. If you believe your interaction with us is no longer secure (for example, if you think your account has been compromised), please notify us immediately using the contact details in the “How to Contact Us” section.

You are responsible for maintaining the confidentiality of your account credentials and for restricting access to your devices.

6. When We Share Your Information

We do not sell your Personal Information for monetary compensation.

We may share your Personal Information in the following situations:

6.1 Affiliates and Subsidiaries

We may share Personal Information with our affiliates and related entities, where they process it for purposes consistent with this Privacy Policy and subject to appropriate safeguards.

6.2 Service Providers (Suppliers and Vendors)

We engage trusted third parties to provide services on our behalf, such as:

Website and application hosting

Email and SMS delivery

Data storage and backup

Customer relationship management (CRM)

Analytics and reporting

Customer support tools

These service providers may have access to Personal Information only as needed to perform their functions and are obligated to protect it and use it only as instructed by us.

6.3 Partners

At times we may collaborate with third-party partners for:

Joint programs, events, or training initiatives

Co-branded offerings

Research or educational projects

Referral, affiliate, or reseller arrangements

If additional terms or privacy notices apply to a specific partnership, we will make them available to you.

6.4 Advertising and Marketing Partners

We may share limited information with third-party marketing and advertising partners to:

Deliver more relevant content and offers

Run and measure digital campaigns

Understand audience responses and engagement

Any sharing for targeted advertising or similar uses will be done in accordance with applicable law and your preferences.

SMS / Text Messaging Data

We do not share your mobile phone number or text message opt-in consent with third parties for their own marketing purposes without your express written consent to do so.

All categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties other than vendors necessary to deliver the text messaging services (such as SMS aggregators or carriers).

6.5 Social Networks and Third-Party Services

If you connect your HOLOS account to a social media or third-party account, or authorize a third-party service to access your information via the Platform, you are instructing us to share information with those parties under their own terms and privacy policies. You can typically revoke such access in your account settings with the third-party service.

6.6 Legal and Safety Reasons

We may disclose Personal Information when we believe it is necessary or appropriate to:

Comply with applicable law, legal process, or government requests

Respond to lawful requests from public authorities, including for national security or law enforcement

Enforce our agreements and policies

Protect the rights, property, or safety of HOLOS, our users, or the public

6.7 Business Transfers

We may disclose or transfer Personal Information in connection with:

A merger, acquisition, or sale of all or part of our business or assets

A corporate reorganization or restructuring

Bankruptcy or similar proceedings

In such cases, we will take steps to ensure the recipient handles your Personal Information in a manner consistent with this Privacy Policy.

6.8 With Your Consent

We may share your Personal Information with third parties for any other purpose disclosed to you at the time of collection, if you have given your consent.

6.9 Non-Personal or Aggregated Information

We may share aggregated, anonymized, or otherwise de-identified information with third parties for analytics, research, or other legitimate purposes. This information does not identify you personally.

7. Information from Children

The Platform is not intended for children under the age of 16, and we do not knowingly collect Personal Information from children under 16 (or a higher minimum age where required by local law, such as 13 in the United States under COPPA).

If you are under 16, do not use the Platform or provide any Personal Information to us.

If we learn that we have collected Personal Information from a child under 16, we will take reasonable steps to delete that information as soon as possible. If you believe we might have information about a child under 16, please contact us using the details in the “How to Contact Us” section.

8. Third-Party Websites and Services

The Platform may contain links to websites, applications, or services that are not operated by HOLOS. We are not responsible for the privacy, security, or information practices of these third parties, including:

Websites or services that link to or from our Platform

Social media platforms

App developers or device manufacturers

Other third-party tools integrated with the Platform

This Privacy Policy does not apply to information collected by those third parties. We encourage you to review the privacy policies of any third-party sites or services you visit or use.

9. Do Not Track

Some web browsers offer a “Do Not Track” (“DNT”) setting that signals your preference regarding tracking by websites. At this time, the Platform does not respond to DNT signals. You may manage cookies and similar technologies through your browser settings and any cookie controls we make available.

10. Your Legal Rights (General Overview)

Depending on where you live and the laws that apply, you may have some or all of the following rights regarding your Personal Information:

Access – To request confirmation that we process your Personal Information and to obtain a copy.

Correction – To request that we correct or update inaccurate or incomplete Personal Information.

Deletion – To request that we delete your Personal Information, subject to legal or contractual obligations.

Restriction – To request that we restrict the processing of your Personal Information in certain circumstances.

Objection – To object to certain types of processing, including direct marketing.

Portability – To request a copy of your Personal Information in a structured, commonly used, machine-readable format where technically feasible.

Consent Withdrawal – Where we rely on consent, you may withdraw it at any time without affecting the lawfulness of processing before withdrawal.

To exercise any of these rights, please contact us using the details in the “How to Contact Us” section below. We may need to verify your identity before responding.

Even if you request deletion or restriction, we may retain certain information as required or permitted by law (for example, for recordkeeping, compliance, or to complete transactions you initiated).

The following sections provide additional details for specific jurisdictions.

11. European Privacy Rights (EEA, UK, and Switzerland)

If you are located in the EEA, the UK, or Switzerland, you may have additional rights under the GDPR or similar laws, including:

The right to access, correct, or delete your Personal Information

The right to restrict or object to certain processing

The right to data portability

The right to withdraw consent where processing is based on consent

You can exercise these rights by contacting us as set out in “How to Contact Us.”

If you believe our processing of your Personal Information does not comply with applicable law, you may lodge a complaint with your local data protection authority. We encourage you to contact us first so we can address your concerns directly.

12. International Transfers

HOLOS is based in the United States and may process and store your Personal Information in the U.S. and other countries. These locations may have data protection laws that are different from those in your country.

When we transfer Personal Information internationally, we take steps to ensure an adequate level of protection under applicable law, which may include:

Using standard contractual clauses approved by relevant authorities

Relying on other lawful transfer mechanisms where appropriate

Implementing additional technical and organizational safeguards

By using the Platform or providing us with Personal Information, you acknowledge that your information may be transferred to and processed in the United States and other countries as described in this Privacy Policy.

13. California Privacy Rights (CCPA/CPRA)

This section applies only to California residents and supplements the rest of this Privacy Policy.

Subject to certain exceptions, the California Consumer Privacy Act (as amended, the “CCPA”) grants California residents the rights to:

Be informed about the categories of Personal Information collected, the purposes for which it is used, and whether it is sold or shared

Request access to specific pieces and categories of Personal Information we have collected about you

Request correction of inaccurate Personal Information

Request deletion of Personal Information, subject to legal exceptions

Opt out of the “sale” or “sharing” of Personal Information for cross-context behavioral advertising (if applicable)

Limit the use or disclosure of sensitive Personal Information (if collected)

Not be discriminated against for exercising CCPA rights

We do not sell your Personal Information for money. If we use Personal Information for cross-context targeted advertising that qualifies as “sharing” under CCPA, you may have the right to opt out. You can exercise this right by contacting us as described in “How to Contact Us” or using any opt-out mechanism we make available.

You may request access, correction, or deletion of your Personal Information by contacting us. We will verify your identity before honoring your request, which may involve matching information you provide with existing records.

You may, where permitted, authorize an agent to exercise your CCPA rights on your behalf. We may require proof of such authorization and may still ask you to verify your identity directly.

We describe the categories of Personal Information we collect and our purposes for using them in Sections 2 and 3 of this Privacy Policy. We limit our use of any sensitive Personal Information, if collected, to the purposes allowed by CCPA and other applicable law.

14. Colorado Privacy Rights (CPA)

If you are a Colorado resident, you may have rights under the Colorado Privacy Act, including:

To confirm whether we are processing your Personal Information and to access it

To correct inaccuracies in your Personal Information

To request deletion of your Personal Information

To obtain a portable copy of your Personal Information where technically feasible

To opt out of the processing of Personal Information for targeted advertising, the sale of Personal Information (if applicable), or certain profiling

You can exercise these rights by contacting us as described in “How to Contact Us.” We may need to verify your identity.

If we decline your request (where permitted by law) or do not take action within the required time, you have the right to appeal. You may submit an appeal using the same contact information.

15. Connecticut Privacy Rights (CTDPA)

If you reside in Connecticut, you may have rights under the Connecticut Data Privacy Act, including:

To confirm whether we are processing your Personal Information and to access it

To correct inaccuracies in your Personal Information

To request deletion of Personal Information

To obtain a portable copy of your Personal Information where technically feasible

To opt out of targeted advertising, the sale of Personal Information (if applicable), or certain profiling

You may exercise these rights by contacting us as described in “How to Contact Us.” If we decline your request (where allowed by law), you may appeal our decision using the same contact details.

16. Utah Privacy Rights (UCPA)

If you are a Utah resident, the Utah Consumer Privacy Act may provide certain rights, including:

To confirm whether we process your Personal Information and to access it

To request deletion of Personal Information you provided to us

To obtain a copy of your Personal Information in a portable format where technically feasible

To opt out of targeted advertising and the sale of Personal Information (if applicable)

You can exercise these rights by contacting us using the details in “How to Contact Us.”

17. Virginia Privacy Rights (VCDPA)

If you are a Virginia resident, you may have rights under the Virginia Consumer Data Protection Act, including:

To confirm whether we are processing your Personal Information and to access it

To correct inaccuracies in your Personal Information

To request deletion of your Personal Information

To obtain a copy of your Personal Information in a portable format where technically feasible

To opt out of targeted advertising, the sale of Personal Information (if applicable), or certain profiling

To not be discriminated against for exercising these rights

You may exercise these rights by contacting us as described in “How to Contact Us.” If we decline to act on your request (where permitted by law), you may submit an appeal using the same contact details.

18. How to Contact Us

If you have any questions about this Privacy Policy, our privacy practices, or if you wish to exercise your rights, you may contact us at:

HOLOS INC

3304 North State Street

Jackson, MS 39216

United States

Primary Privacy Contact (Email):

📧 [email protected]

General Inquiries:

📧 [email protected]

We will do our best to respond to your request or question in a timely and appropriate manner.