Last Modified: September 13, 2024

Ho’ōla, LLC (which is referred to in this Privacy Policy as “Ho’ōla”, “us,” “we” or “our”) recognizes that the privacy of your personal information is important. This Privacy Policy is intended to inform you, a visitor to the Ho’ōla website, of our policies and practices regarding the collection, use, and disclosure of any Personal Information (defined below) the Ho’ōla website collects or receives. This policy does not apply to information collected through other means (e.g., telephone, postal mail). Ho’ōla will use Personal Information provided through your use of our website as described in this Privacy Policy.

Collection of Information
Personal Information. “Personal Information” is information that identifies you and may include your name, address, email address, telephone or fax number, company name, IP address, any content you post in your resume or CV, and any other information you may provide to us that identifies you.

1. In particular, our websites have collected the below categories of Personal Information from consumers within the last twelve (12) months. We may share your personal information by disclosing it to a third party for business purposes. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the Personal Information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed Personal Information for a business purpose to the categories of third parties indicated in the chart below. We do not sell your Personal Information.

Category	Whether Data is Collected and the Source of Collection	Business or Commercial Purpose for Collection or Use	Category of Third-Party Recipient
A. Identifiers.  Examples: A real name, email address, or other similar identifiers.	Yes Your device, Our service providers	Inform you about our other products, services, and offers that may be of interest to you; Meet our contractual obligations with service providers; Respond to legal requests and meet other legal and regulatory requirements; provide customer service Detect and protect against security events, fraud, and illegal activities, Aid us in enforcing our Terms and Conditions	Service providers, Business partners with which we jointly offer services, Recipients as required by law, regulation, judicial process, or order
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).Examples: A name, telephone number, or other similar identifiers.	Yes You Our service providers	Inform you about our other products, services, and offers that may be of interest to you; Meet our contractual obligations with service providers; Respond to legal requests and meet other legal and regulatory requirements; provide customer service Detect and protect against security events, fraud, and illegal activities, Aid us in enforcing our Terms and Conditions	Service providers, Business partners with which we jointly offer services, Recipients as required by law, regulation, judicial process, or order
C. Protected classification characteristics under California or federal law.	No	N/A	N/A
D. Commercial information.	No	N/A	N/A
E. Biometric information.		N/A	N/A
F. Internet or other similar network activity. Examples: Usage data, device data, referral data, information from cookies and page tags, information on a consumer’s interaction with a website, application, or advertisement.	Yes, Your device third-party analytics providers	Make our websites easier to use, Provide you with personalized content, Improve our services	N/A
G. Geolocation data. Examples: Physical location or movements.	Yes, Your device third-party analytics providers	Monitor our Services; Meet our contractual obligations with service providers or business partners; Respond to legal requests and meet other legal and regulatory requirements; Detect and protect against security events, fraud, and illegal activities	Service providers, Business partners with which we jointly offer services, Recipients as required by law, regulation, judicial process, or order
H. Sensory data.	No	N/A	N/A
I. Professional or employment-related information.	No	N/A	N/A
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	No	N/A	N/A
K. Inferences drawn from other personal information.	No	N/A	N/A

Information Collected Automatically. When you visit the Ho’ōla website, we automatically collect and analyze certain information about your computer. This information includes, but may not be limited to, the IP address used to connect your computer to the Internet, information about your browser type and language, the date and time you are accessing the website, the content of any undeleted cookies that your browser previously accepted from us, and the referring website address.

Cookies and other Technologies. We may use various technologies to collect information about you and your organization’s activities on the Ho’ōla website.

• When you visit the Ho’ōla website, we may assign your computer one or more “cookies.” A cookie is a small text file that contains information that can later be read by us to facilitate your access to the site and personalize your online experience. Through the use of a cookie, we may automatically collect information about your online activity on the Ho’ōla website, such as the web pages you visit, the links you click, and the searches you conduct. Most browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies by visiting the Help portion of your browser’s toolbar. If you choose to decline cookies, please note that you may not be able to sign in or use some of the interactive features offered on the Ho’ōla website.
• Other technologies. We may use standard Internet technology, such as web beacons (also called clear GIFs or pixel tags) and other similar technologies, to deliver or communicate with cookies and track your use of the Ho’ōla website. We also may include web beacons in e-mail messages or newsletters to determine whether messages have been opened and acted upon. The information we obtain in this manner enables us to customize the services we offer and measure the overall effectiveness of our online content, advertising campaigns, and the products and services offered through the site.
  

Information Collected by Third Parties. Third parties, such as vendors, advertising entities, and business partners, may use cookies and other technologies (such as web beacons) to collect information about your online activities. The purposes for collecting this information includes: to measure usage of Ho’ōla websites; to analyze, modify, and personalize advertising content on Ho’ōla websites; and to provide ads about goods and services we hope will be of interest to you. We do not have access to or control over cookies or other features these third parties may use, and the information practices of these third parties are not covered by this Privacy Policy. Some of these third parties may be third-party network advertisers that offer you the option of not having this information collected. For more information about these some of these third parties, you may wish to visit http://www.networkadvertising.org.

Use and Disclosure of Personal Information

Uses by Ho’ōla. We use the Personal Information collected through the Ho’ōla website as described in the table above.

Unless you affirmatively elect not to receive (“opt-out”) communications from us, Personal Information we collect from you may be used to respond to inquiries you submit to us; facilitate your access to Ho’ōla resources and materials; send you general informative announcements, electronic newsletters, and marketing-related emails about us or our products; and aid us in serving you better. At the bottom of every newsletter or general informative email we send you, you will be given the opportunity to opt-
out or unsubscribe from future email communications.

Disclosure. We may share your Personal Information as described in the table above including with third parties who perform functions or services on our behalf as outlined in this Privacy Policy and as otherwise permitted by law. In the event we share Personal Information with third parties, we take reasonable measures to ensure such parties observe the relevant portions of the Privacy Policy, restrict the use and retention of the information to the purposes and timeframe of such outsourcing, and take other measures to require the observance of the relevant portions of the Privacy Policy.

We may also share aggregate or anonymous information with third parties, including advertisers, investors, and partners. This information does not contain any Personal Information and is used to develop content and services.

We may disclose any information we deem necessary, in our sole discretion, to comply with any applicable law, regulation, court order, subpoena, legal process, or government regulation. We may work with law enforcement officials in investigating activities that are illegal or that violate Ho’ōla’s rules.

What Are Your Rights to Your Information?

Depending on the jurisdiction, you may have the right to access, correct, update, restrict processing or object to processing, or delete certain Personal Information covered by this Privacy Policy. Depending on the jurisdiction, you may also have the right to request that we refrain from processing Personal Information. Please bear in mind that if you object this may affect our ability to provide our Services to you. While we will make reasonable efforts to accommodate your request, we also reserve the right to impose certain restrictions and requirements on such requests if allowed or required by applicable law. Please note that it may take some time to process your request, consistent with applicable law.

For How Long Do We Retain Your Data?

We retain your data as long as necessary to provide our services and to comply with our legal obligations. We reserve the right to delete or purge such data.

Supplemental Notice to Residents of Certain States (including California)

Residents of certain states (including California) may have additional rights regarding your Personal Information under state law. If you are a California resident, you may have certain rights regarding your personal Information under state law.

• Our website collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device. Personal information does not include:
• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Other information excluded from the scope of state privacy laws.
  

If you reside in certain states including California), you have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past twelve (12) months (the “right to know”). Once we receive your request and confirm your identity, we will disclose to you:

• The categories of Personal Information we have collected about you
• The categories of sources for the Personal Information we have collected about you
• Our business or commercial purpose for collecting or selling that Personal Information
• The categories of third parties with whom we share that Personal Information
• If we sold or disclosed your Personal Information for a business purpose, two separate lists
  disclosing:
  – sales, identifying the Personal Information categories that each category of recipient purchased; and
  – disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained

• The specific pieces of Personal Information we collected about you (also called a data portability request).

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities
• Debug products to identify and repair errors that impair existing intended functionality
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.)
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent
• Enable solely internal uses that are reasonably aligned with consumer expectations based upon your relationship with us
• Comply with a legal obligation
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
  

We will delete or deidentify Personal Information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

You have the right to request that we amend incorrect Personal Information that relates to you (the “right to correct”).

You have the right to opt-out from the sharing of your Personal Information for cross-context behavioral advertising (the “marketing opt-out right”).

You may limit the sharing of some sensitive Personal Information that relates to you (the “right to limit sensitive information sharing”). We still may use sensitive Personal Information for permitted business purposes, such as to ensure data integrity and security, to meet legal or regulatory obligations, or to prevent fraud or misuse of our services.

If you choose to exercise these rights, we ask you to provide sufficient information, including the services you have used in the past, your state and country of residence, and contact information, in order for us to verify your identity and process your request. Depending on the types of requests, additional information may be requested. We will only use Personal Information provided in this retest to verify the requestor’s identity or authority to make it.

You may use an authorized agent to submit a request on your behalf related to your Personal Information. If you choose to use an authorized agent, you should supply your agent with written permission to act on your behalf in relation to your request, and your agent must provide us with proof of such authorization before we process your request.

To exercise a right related to your Personal Information, please contact us by email to marketing@Ho’ōlahealthcare.com or by calling us at 636-536-9443. We will confirm receipt of your request within ten (10) business days. We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another forty-five (45) days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the twelve (12) month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, utilizing AES 256 encryption. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

We will not discriminate against you for exercising any of your California privacy rights. Unless permitted by law, we will not:

• Deny you goods or services
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties
• Provide you a different level or quality of goods or services
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services

Information Security

Within Ho’ōla, we restrict access to Personal Information to employees, contractors, and agents who need to know that information in order to operate, develop, or improve our programs and services. As described above, we subject our third party contractors and agents to controls to help ensure that they apply suitable protections to any Personal Information they access or receive from us.

Children

The Ho’ōla website contains business-related content and is specifically aimed at and designed for use by adults. We do not knowingly solicit or collect Personal Information from or about individuals under the age of 13 years. Please contact us if you believe we have collected Personal Information from a child under the age of 13 through this website. If we discover that we have received Personal Information from an individual whom we believe to be under the age of 13 in some other manner, we will delete such information from our systems.

Media Contacts and Influencers

Ho’ōla obtains contact details and other Personal Information regarding media contacts and influencers from a variety of sources including Cision. If you wish to know more about how such information is collected and used, please refer to Cision’s privacy notice at:  www.cision.com/us/legal/privacy-policy/.

Changes to This Policy

If Ho’ōla changes the Privacy Policy, we will post the revised Privacy Policy here, with an updated revision date. If Ho’ōla makes significant changes to the Privacy Policy, we may also notify you by other means, such as sending an email or posting a notice on our external website.

Contact

If you have any questions about this Privacy Policy, please contact us at:
Ho’ōla, LLC
1600 Kapiolani Blvd., Suite 900
Honolulu, HI 96814

Ho’ōla is a Surround Care Company