COOKIE POLICY

1.INTRODUCTION, SCOPE, PURPOSE, DEFINITIONS & GENERAL PRINCIPLES

1.1 Introduction

This Cookie Policy explains how Holora Performance Ltd. („Holora,“ „Company,“ „we,“ „our,“ or „us“) uses cookies and similar technologies when Users access, browse, register for, subscribe to, purchase, interact with, or otherwise use:

  • Holora websites
  • Holora mobile applications
  • Holora web applications
  • Holora dashboards
  • Holora marketplaces
  • Holora AI services
  • Holora wearable services
  • Holora enterprise services
  • Holora Human Performance Intelligence systems
  • Future Holora technologies

This Cookie Policy forms part of the broader Holora legal framework.

1.2 Relationship To Other Policies

This Cookie Policy should be read together with:

  • Terms of Service
  • Privacy Policy
  • AI Policy
  • Health Disclaimer
  • Marketplace Terms
  • Trainer Agreement
  • Community Guidelines
  • Payment & Refund Policy

Where conflicts arise, the document most directly governing the issue shall prevail.

1.3 Purpose Of This Policy

The purpose of this Cookie Policy is to explain:

  • What technologies Holora uses
  • Why such technologies are used
  • How Users may control such technologies
  • How technologies support Platform functionality
  • How technologies support AI functionality
  • How technologies support security
  • How technologies support personalization

Holora is committed to transparency regarding the use of such technologies.

1.4 What Are Cookies

Cookies are small data files placed on a browser, device, application, or system when a User accesses digital services.

Cookies help systems:

  • Recognize devices
  • Remember preferences
  • Maintain sessions
  • Improve security
  • Improve functionality

Cookies generally do not provide direct access to a User’s device.

1.5 What Are Similar Technologies

In addition to cookies, Holora may use:

Local Storage

Session Storage

SDK Technologies

Authentication Tokens

Device Identifiers

Pixels

Web Beacons

Mobile Application Technologies

Future Similar Technologies

For purposes of this Policy, these technologies are collectively referred to as „Technologies.“

1.6 Why Holora Uses Technologies

Holora uses Technologies to support:

Security

Authentication

Platform Functionality

Personalization

AI Experiences

Performance Optimization

Marketplace Operations

Enterprise Services

Analytics

Fraud Prevention

User Experience Improvements

1.7 Core Principles

Holora’s use of Technologies is guided by the following principles:

Transparency

Users should understand how Technologies are used.

Security

Technologies should help protect Users and the Platform.

Privacy

Technologies should be used responsibly and in accordance with applicable privacy laws.

User Benefit

Technologies should improve User experiences and Platform functionality.

Compliance

Technologies should support compliance with applicable laws and regulations.

1.8 No Sale Of Health Information Through Cookies

Holora does not use cookies or similar technologies to sell:

Health Information

Recovery Information

Nutrition Information

Wearable Information

Biometric Information

Human Performance Information

to advertisers, data brokers, or unrelated third parties.

This principle applies globally.

1.9 Holora’s Unique Technology Environment

Unlike many traditional fitness applications, Holora may combine:

Artificial Intelligence

Human Expertise

Marketplace Services

Wearable Integrations

Recovery Systems

Human Performance Intelligence

Global Professional Networks

As a result, certain Technologies may support more advanced personalization and service functionality than traditional websites or applications.

1.10 Technology Categories Covered By This Policy

This Policy applies to Technologies supporting:

Authentication

Security

Preferences

Personalization

AI Functionality

Analytics

Marketplace Functionality

Enterprise Functionality

Wearable Functionality

Human Performance Intelligence

Future Platform Services

1.11 Global Operations

Holora operates internationally.

Accordingly, Technologies may function across multiple jurisdictions and may be subject to:

GDPR

UK GDPR

ePrivacy Requirements

CCPA

CPRA

Future International Privacy Laws

where applicable.

1.12 User Choice

Where required by law, Holora may provide mechanisms allowing Users to:

  • Accept Technologies
  • Reject Technologies
  • Modify preferences
  • Withdraw consent

Certain Technologies may remain necessary for Platform operation.

1.13 Future Technologies

Technology evolves rapidly.

This Cookie Policy applies not only to current Technologies but also to future technologies performing substantially similar functions.

Examples may include:

  • AI personalization systems
  • Voice technologies
  • Wearable synchronization technologies
  • Human Performance Intelligence systems

unless governed by separate policies.

1.14 Transparency Commitment

Holora is committed to providing clear information regarding:

  • Technology usage
  • Personalization practices
  • Security technologies
  • User controls

and will continue updating this Policy as services evolve.

1.15 Scope Of Application

This Cookie Policy applies to:

Users

Subscribers

Professionals

Trainers

Nutritionists

Recovery Specialists

Enterprise Clients

Marketplace Participants

Visitors

who interact with Holora services.

1.16 Effective Date

This Cookie Policy becomes effective upon publication and remains in effect until replaced by an updated version.

2 .COOKIE CATEGORIES, TECHNOLOGY TYPES, AUTHENTICATION TECHNOLOGIES, SECURITY TECHNOLOGIES & FUNCTIONAL TECHNOLOGIES

2.1 Overview

Holora utilizes various categories of cookies and similar technologies to support:

  • Security
  • Authentication
  • Platform functionality
  • User preferences
  • Personalization
  • Analytics
  • Performance optimization
  • Service delivery

Different technologies serve different purposes and may operate for varying periods of time.

2.2 Categories Of Technologies

Holora may utilize:

Cookies

Local Storage

Session Storage

Authentication Tokens

Device Identifiers

Software Development Kits (SDKs)

Web Beacons

Pixels

Application Storage Technologies

Future Similar Technologies

collectively referred to in this Policy as „Technologies.“

2.3 Strictly Necessary Technologies

Certain technologies are essential to operation of the Platform.

Without these technologies, many Platform features cannot function properly.

Examples include:

  • Login functionality
  • Session management
  • Security controls
  • Fraud prevention
  • Authentication
  • User account protection

These technologies generally cannot be disabled while using the Platform.

2.4 Authentication Technologies

Authentication technologies help verify User identity.

Examples may include:

Login Tokens

Authentication Cookies

Session Tokens

Security Tokens

Access Tokens

Refresh Tokens

These technologies help prevent unauthorized account access.

2.5 Session Technologies

Session technologies allow Holora to:

  • Maintain active sessions
  • Remember authentication status
  • Preserve user interactions
  • Support secure navigation

Session technologies typically expire automatically after inactivity or logout.

2.6 Security Technologies

Security technologies may be used to:

Detect Fraud

Detect Abuse

Detect Unauthorized Access

Detect Account Compromise

Prevent Security Incidents

Protect Platform Infrastructure

Security technologies are considered essential for operation of the Platform.

2.7 Account Protection Technologies

Holora may utilize technologies designed to:

  • Identify unusual activity
  • Detect suspicious logins
  • Monitor authentication attempts
  • Protect user accounts

These technologies help improve Platform security.

2.8 Functional Technologies

Functional technologies improve User experiences by remembering preferences including:

Language Preferences

Regional Preferences

Accessibility Preferences

User Interface Preferences

Platform Settings

Notification Preferences

These technologies help personalize Platform functionality.

2.9 Preference Technologies

Preference technologies may remember:

  • Display settings
  • Measurement units
  • Time zones
  • Language selections
  • User choices

The purpose is to improve convenience and usability.

2.10 Accessibility Technologies

Holora may utilize technologies supporting accessibility features including:

  • Display preferences
  • Interface adjustments
  • Accessibility settings

where such functionality is available.

2.11 User Experience Technologies

Certain technologies may be used to improve:

Navigation

Functionality

Performance

Stability

User Experience

These technologies help ensure efficient Platform operation.

2.12 Platform Integrity Technologies

Holora may utilize technologies intended to:

  • Prevent abuse
  • Prevent manipulation
  • Prevent unauthorized automation
  • Maintain service integrity

These technologies help protect both Users and the Platform.

2.13 Login Persistence Technologies

Where Users choose to remain signed in, Holora may use technologies that remember authentication status between sessions.

Users may revoke such functionality by:

  • Logging out
  • Clearing browser data
  • Adjusting device settings

2.14 Multi-Device Technologies

Holora may utilize technologies that help support:

  • Device recognition
  • Session continuity
  • Cross-device functionality

where available and appropriate.

2.15 Security Monitoring Technologies

Security systems may utilize technologies to identify:

  • Repeated login failures
  • Suspicious activity patterns
  • Potential fraud indicators
  • Unauthorized access attempts

The objective is to protect Users and Platform infrastructure.

2.16 Fraud Prevention Technologies

Fraud prevention technologies may be used to:

  • Detect abuse
  • Prevent account takeovers
  • Prevent payment fraud
  • Prevent marketplace fraud
  • Protect Platform participants

These technologies are considered important security measures.

2.17 Marketplace Technologies

Holora Marketplace services may utilize technologies supporting:

  • Professional accounts
  • User accounts
  • Messaging
  • Service delivery
  • Transaction tracking

The objective is to facilitate Marketplace operations.

2.18 Enterprise Technologies

Enterprise services may utilize technologies supporting:

  • Authentication
  • Reporting
  • Administration
  • Security
  • Access management

for authorized organizational users.

2.19 Retention Of Essential Technologies

Retention periods vary according to:

  • Technology purpose
  • Security requirements
  • Operational requirements
  • Legal obligations

Certain security and authentication technologies may remain active for extended periods where reasonably necessary.

2.20 User Control Limitations

Because certain technologies are essential to Platform operation, disabling them may:

  • Prevent login
  • Disable functionality
  • Reduce security
  • Limit service availability

Users acknowledge that some functionality requires such technologies.

2.21 Future Essential Technologies

This section applies to future technologies performing similar functions including:

  • AI authentication systems
  • Advanced identity systems
  • Wearable authentication technologies
  • Human Performance Intelligence systems

unless superseded by future policies.

2.22 Transparency Commitment

Holora seeks to maintain transparency regarding technologies required to operate, secure, and protect the Platform.

3. ANALYTICS TECHNOLOGIES, PERFORMANCE TECHNOLOGIES, AI PERSONALIZATION TECHNOLOGIES, RECOMMENDATION ENGINES & USER EXPERIENCE OPTIMIZATION

3.1 Overview

Holora utilizes analytics, performance, personalization, and Artificial Intelligence technologies to improve Platform functionality and User experiences.

These technologies help Holora better understand:

  • Platform usage
  • User preferences
  • Service performance
  • Feature effectiveness
  • User engagement
  • Educational effectiveness
  • Recommendation quality

The purpose is to improve services while supporting privacy, transparency, and responsible technology use.

3.2 Analytics Technologies

Holora may utilize analytics technologies to understand:

Platform Usage

Feature Usage

User Journeys

Service Performance

Error Patterns

Technical Performance

Engagement Trends

Analytics help identify opportunities to improve Platform experiences.

3.3 Purpose Of Analytics

Analytics technologies may be used to:

  • Improve functionality
  • Improve stability
  • Improve performance
  • Improve navigation
  • Improve user experience
  • Improve AI systems
  • Improve educational effectiveness

Analytics are intended to support service enhancement.

3.4 Usage Information

Analytics technologies may collect information including:

  • Device type
  • Browser type
  • Operating system
  • App version
  • Session duration
  • Pages viewed
  • Features accessed
  • General interaction patterns

Collection methods may vary depending on Platform functionality.

3.5 Performance Technologies

Performance technologies help Holora evaluate:

Loading Speeds

Response Times

Stability

Error Rates

System Availability

Infrastructure Performance

The objective is to maintain reliable services.

3.6 Error Monitoring Technologies

Holora may utilize technologies designed to detect:

  • Application errors
  • System failures
  • Connectivity issues
  • Performance issues
  • User experience issues

Error monitoring helps identify and resolve technical problems.

3.7 Service Optimization

Analytics and performance technologies may be used to:

  • Improve application speed
  • Improve platform responsiveness
  • Improve feature reliability
  • Improve scalability
  • Improve infrastructure efficiency

3.8 Artificial Intelligence Personalization

Holora’s Platform includes Artificial Intelligence systems designed to provide personalized experiences.

Certain technologies may support:

AI Memory Systems

AI Personalization

AI Recommendations

Goal Awareness

Progress Awareness

Educational Guidance

Human Performance Intelligence

3.9 Purpose Of AI Personalization

AI personalization technologies may help Holora provide experiences tailored to:

  • Goals
  • Preferences
  • Habits
  • Progress
  • Recovery trends
  • Training patterns
  • Nutrition patterns

The objective is to improve relevance and usefulness.

3.10 AI Memory Technologies

Holora may utilize technologies that allow AI systems to maintain awareness of:

User Goals

User Preferences

Historical Interactions

Training History

Nutrition History

Recovery History

Educational Interests

where permitted by applicable laws and Platform settings.

3.11 Recommendation Technologies

Recommendation technologies may be used to generate:

Training Recommendations

Recovery Recommendations

Nutrition Recommendations

Educational Recommendations

Professional Recommendations

Marketplace Recommendations

The objective is to assist Users in discovering relevant content and services.

3.12 Human Performance Intelligence Systems

Future Holora systems may utilize technologies designed to integrate information relating to:

  • Training
  • Recovery
  • Nutrition
  • Wearables
  • Behavior patterns
  • Goal progression

to support Human Performance Intelligence functionality.

3.13 Personalization Technologies

Personalization technologies may be used to remember:

  • User preferences
  • Content preferences
  • Language preferences
  • Feature preferences
  • Notification preferences

to improve Platform experiences.

3.14 Goal-Based Experiences

Certain technologies may help Holora provide experiences aligned with User goals.

Examples may include:

Weight Management Goals

Fitness Goals

Performance Goals

Recovery Goals

Longevity Goals

Wellness Goals

The purpose is to improve relevance rather than provide medical advice.

3.15 Content Recommendations

Holora may recommend:

  • Educational content
  • Professional content
  • Training content
  • Nutrition content
  • Recovery content

based upon Platform interactions and preferences.

3.16 Marketplace Personalization

Marketplace technologies may help Users discover:

Trainers

Nutritionists

Recovery Specialists

Educators

Courses

Digital Products

Programs

based upon preferences and Platform activity.

3.17 Behavioral Insights

Certain technologies may help identify general patterns relating to:

  • Consistency
  • Engagement
  • Adherence
  • Platform usage

The purpose is to improve User experiences and educational guidance.

3.18 User Experience Improvement

Analytics may be used to determine:

  • Which features are useful
  • Which features require improvement
  • Which services create value
  • Which experiences need refinement

3.19 Aggregated Analytics

Holora may utilize aggregated or de-identified analytics information to:

  • Improve products
  • Improve services
  • Improve AI systems
  • Improve recommendations
  • Improve Platform functionality

where permitted by applicable law.

3.20 Research & Development

Analytics technologies may support:

Product Development

Service Development

AI Development

Performance Research

User Experience Research

Human Performance Intelligence Development

The objective is continuous improvement.

3.21 AI Training Limitations

Holora seeks to implement controls designed to ensure AI-related processing occurs in accordance with applicable privacy commitments and legal obligations.

Additional details are provided in the Privacy Policy and AI Policy.

3.22 User Controls

Where available and required by law, Users may be provided controls relating to:

  • Analytics technologies
  • Personalization technologies
  • Preference technologies

Certain features may be affected if such technologies are disabled.

3.23 Business Intelligence Technologies

Holora may utilize business intelligence technologies to understand:

  • Service demand
  • Marketplace activity
  • Platform growth
  • Feature adoption

for operational and strategic purposes.

3.24 Enterprise Analytics

Enterprise services may utilize analytics technologies to support:

  • Reporting
  • Program administration
  • Service delivery
  • Performance evaluation

subject to applicable privacy requirements.

3.25 No Sale Of Health Information

Analytics and personalization technologies are not used to sell:

Health Information

Recovery Information

Nutrition Information

Wearable Information

Biometric Information

to advertisers, data brokers, or unrelated third parties.

3.26 AI Transparency Principle

Holora seeks to maintain transparency regarding the use of technologies supporting:

  • AI personalization
  • Recommendation engines
  • Memory systems
  • Human Performance Intelligence

and will continue evolving disclosures as technologies develop.

3.27 Future Personalization Technologies

This section applies to future technologies supporting:

AI Coaches

AI Assistants

Voice AI

Predictive Systems

Human Performance Intelligence

Adaptive Experiences

unless superseded by future policies.

3.28 User Benefit Principle

Analytics and personalization technologies exist to help improve:

  • Understanding
  • Relevance
  • Education
  • Guidance
  • Platform quality

while supporting responsible use of information.

3.29 Transparency Commitment

Holora is committed to helping Users understand how personalization, analytics, and recommendation technologies contribute to Platform experiences.

3.30 Core Principle

The purpose of analytics, personalization, and AI technologies is not to make decisions for Users.

Their purpose is to help Users better understand themselves, access relevant knowledge, discover appropriate expertise, and receive more meaningful guidance through the Platform.

4.MOBILE APPLICATION TECHNOLOGIES, SDKS, DEVICE IDENTIFIERS, PUSH NOTIFICATIONS, APP ANALYTICS & APP STORE TECHNOLOGIES

4.1 Overview

Holora primarily operates through mobile applications, web applications, wearable integrations, and future Human Performance Intelligence technologies.

Accordingly, Holora may utilize mobile-specific technologies that differ from traditional website cookies.

These technologies help support:

  • Authentication
  • Security
  • Notifications
  • Analytics
  • Personalization
  • AI functionality
  • Marketplace services
  • Payment functionality
  • Service delivery

This section explains how such technologies may operate.

4.2 Mobile Application Technologies

Unlike websites, mobile applications may utilize technologies including:

Mobile SDKs

Application Storage

Device Identifiers

Push Notification Tokens

Authentication Tokens

Mobile Analytics Technologies

Deep Linking Technologies

Future Mobile Technologies

These technologies may perform functions similar to traditional cookies.

4.3 Software Development Kits (SDKs)

Holora may utilize Software Development Kits („SDKs“) supplied by trusted service providers.

SDKs may assist with:

  • Authentication
  • Security
  • Analytics
  • Infrastructure
  • Notifications
  • Payments
  • Error monitoring
  • Platform functionality

SDKs may process information necessary to provide their functionality.

4.4 Purpose Of SDKs

SDKs may be used to:

Improve Security

Improve Reliability

Improve Performance

Support Authentication

Support Communications

Support Service Delivery

Support User Experience

Support Marketplace Operations

4.5 Device Identifiers

Holora may collect or utilize device identifiers including:

Device IDs

Application Instance IDs

Installation IDs

Push Notification Tokens

Operating System Identifiers

Device Security Identifiers

These identifiers help support Platform functionality and security.

4.6 Purpose Of Device Identifiers

Device identifiers may be used for:

  • Security
  • Authentication
  • Fraud prevention
  • Service delivery
  • Performance monitoring
  • Personalization
  • Technical support

4.7 Push Notification Technologies

Holora may utilize push notification technologies to deliver:

Account Notifications

Security Alerts

Service Messages

Goal Reminders

Recovery Reminders

Educational Content

Marketplace Messages

Promotional Communications

where permitted by law and User preferences.

4.8 Push Notification Tokens

To deliver notifications, Holora may process notification tokens assigned by:

  • Operating systems
  • Device manufacturers
  • Notification service providers

Notification tokens do not generally provide direct access to User devices.

4.9 Notification Preferences

Users may generally manage notification preferences through:

  • Application settings
  • Device settings
  • Operating system settings

Certain critical service notifications may remain necessary.

4.10 Deep Linking Technologies

Holora may utilize deep linking technologies that allow Users to navigate directly to:

  • Content
  • Marketplace listings
  • Programs
  • Professional profiles
  • Educational materials
  • Platform features

These technologies help improve usability and service delivery.

4.11 Mobile Authentication Technologies

Mobile applications may utilize authentication technologies including:

Access Tokens

Refresh Tokens

Session Tokens

Device Verification Systems

Security Credentials

These technologies help maintain secure access to User accounts.

4.12 Mobile Session Management

Holora may utilize technologies that allow Users to remain authenticated between application sessions.

Such technologies help improve convenience while maintaining security.

4.13 Mobile Analytics Technologies

Holora may utilize mobile analytics technologies to understand:

  • Application performance
  • Feature usage
  • Stability
  • User experience
  • Technical issues

Analytics support service improvement and optimization.

4.14 Crash Reporting Technologies

Holora may utilize technologies designed to identify:

Application Crashes

Technical Errors

Stability Issues

Performance Issues

The objective is to improve reliability and user experience.

4.15 Error Diagnostics

Diagnostic technologies may collect technical information necessary to:

  • Identify issues
  • Investigate failures
  • Improve performance
  • Resolve technical problems

Such information is used to support Platform operations.

4.16 Operating System Information

Holora may process information relating to:

  • Operating system versions
  • Application versions
  • Device compatibility
  • Security compatibility

to support Platform functionality.

4.17 Mobile Security Technologies

Security technologies may be used to:

Detect Fraud

Detect Unauthorized Access

Prevent Abuse

Protect User Accounts

Protect Marketplace Services

Protect Infrastructure

These technologies are considered essential.

4.18 Biometric Authentication Technologies

Where supported by User devices, Holora may allow authentication through:

Face Recognition

Fingerprint Recognition

Device Biometrics

Biometric authentication is generally managed by the User’s device operating system.

Holora typically does not receive or store raw biometric templates used by device authentication systems.

4.19 App Store Technologies

Applications distributed through app marketplaces may utilize technologies necessary to support:

App Store Distribution

Subscription Management

Application Updates

License Verification

Security Verification

Platform Compliance

4.20 Apple Platform Technologies

Users accessing Holora through Apple devices may interact with technologies provided through:

Apple App Store

Apple Authentication Systems

Apple Notification Services

Apple Subscription Systems

where applicable.

4.21 Google Platform Technologies

Users accessing Holora through Android devices may interact with technologies provided through:

Google Play

Google Authentication Systems

Google Notification Services

Google Platform Services

where applicable.

4.22 Authentication Providers

Holora may support authentication through:

Email Authentication

Social Authentication

Platform Authentication Providers

Future Identity Providers

subject to Platform functionality.

4.23 Stripe-Related Technologies

Holora may utilize technologies supporting payment processing and subscription management.

Payment information is generally processed by authorized payment providers.

Holora does not store full payment card information processed by payment processors.

Additional information is available within the Privacy Policy and Payment & Refund Policy.

4.24 Marketplace Mobile Technologies

Marketplace services may utilize mobile technologies supporting:

  • Messaging
  • Bookings
  • Program delivery
  • Service management
  • Notifications
  • User communications

4.25 AI Mobile Technologies

Holora may utilize mobile technologies supporting:

AI Conversations

Voice AI

AI Recommendations

AI Memory Systems

Human Performance Intelligence

Personalized Guidance

where available.

4.26 Voice Technologies

Future Holora services may utilize voice technologies supporting:

  • Voice commands
  • Voice interactions
  • Voice coaching
  • Voice guidance

Additional disclosures may apply to such services.

4.27 Wearable Synchronization Technologies

Mobile applications may communicate with:

Smart Rings

Smart Bands

Smart Watches

Fitness Trackers

Recovery Devices

Future Wearable Technologies

to facilitate data synchronization and service delivery.

4.28 Enterprise Mobile Services

Enterprise clients may utilize mobile technologies supporting:

  • Reporting
  • Program administration
  • Service delivery
  • Security controls

subject to applicable agreements.

4.29 Future Mobile Technologies

This section applies to future mobile technologies supporting:

AI Assistants

Human Performance Intelligence

Wearable Intelligence

Advanced Personalization Systems

Future Platform Services

unless superseded by future disclosures.

4.30 Transparency Commitment

Holora is committed to maintaining transparency regarding mobile technologies, SDKs, identifiers, notifications, and application-level technologies used to operate, secure, and improve Platform services.

5. WEARABLE TECHNOLOGIES, BLUETOOTH COMMUNICATIONS, SENSOR DATA SYNCHRONIZATION, DEVICE PAIRING, SMART RINGS, SMART BANDS & HUMAN PERFORMANCE INTELLIGENCE SYSTEMS

5.1 Overview

Holora may integrate with wearable devices and connected technologies designed to support:

  • Recovery tracking
  • Sleep tracking
  • Activity tracking
  • Performance tracking
  • Wellness tracking
  • Human Performance Intelligence

Such integrations may involve technologies that operate differently from traditional website cookies and mobile application technologies.

This section explains how wearable-related technologies may function within the Holora ecosystem.

5.2 Wearable Technologies

Holora may support wearable technologies including:

Smart Rings

Smart Bands

Smart Watches

Fitness Trackers

Recovery Devices

Sensor-Based Devices

Future Wearable Technologies

Wearable technologies may interact with Holora applications through secure communication systems.

5.3 Holora Devices

Future Holora wearable products may include:

Holora Halo™

Holora Core™

Future Holora Wearable Devices

Such devices may utilize technologies necessary to provide functionality and service delivery.

5.4 Third-Party Wearables

Holora may support integration with third-party devices manufactured by independent companies.

Examples may include:

  • Smart watches
  • Smart rings
  • Fitness trackers
  • Health monitoring devices
  • Recovery technologies

Third-party devices remain subject to the policies and practices of their manufacturers.

5.5 Device Pairing Technologies

Wearable devices may utilize pairing technologies allowing secure communication between:

Device

and

Mobile Application

and

Cloud Infrastructure

Pairing technologies help establish secure connections.

5.6 Bluetooth Technologies

Wearable devices may communicate using:

Bluetooth

Bluetooth Low Energy (BLE)

Future Wireless Standards

These technologies facilitate synchronization between devices and applications.

5.7 Purpose Of Bluetooth Technologies

Bluetooth communications may be used to:

  • Synchronize information
  • Connect devices
  • Verify device identity
  • Deliver functionality
  • Support User experiences

5.8 Device Identification Technologies

Wearable systems may utilize identifiers including:

Device IDs

Hardware IDs

Firmware IDs

Bluetooth Identifiers

Service Identifiers

Synchronization Identifiers

These identifiers support functionality and security.

5.9 Synchronization Technologies

Synchronization technologies may be used to:

Transfer Activity Information

Transfer Recovery Information

Transfer Sleep Information

Transfer Sensor Information

Transfer Device Settings

Transfer Performance Information

between authorized systems.

5.10 Sensor Technologies

Wearable devices may utilize sensors including:

Motion Sensors

Optical Sensors

Temperature Sensors

Heart Rate Sensors

Recovery Sensors

Future Sensor Technologies

Sensor technologies support wellness and performance-related features.

5.11 Sensor Data Processing

Holora may process wearable information for purposes including:

  • Service delivery
  • User insights
  • Reporting
  • AI recommendations
  • Human Performance Intelligence

Additional information is provided in the Privacy Policy and AI Policy.

5.12 Recovery Technologies

Recovery systems may utilize technologies supporting:

Recovery Monitoring

Recovery Scoring

Recovery Trend Analysis

Recovery Recommendations

The purpose is to help Users better understand recovery-related patterns.

5.13 Sleep Technologies

Wearable systems may support:

Sleep Tracking

Sleep Trend Analysis

Sleep Consistency Monitoring

Sleep Reporting

Such information is intended for informational and wellness purposes.

5.14 Activity Technologies

Wearable technologies may assist with:

Activity Tracking

Movement Tracking

Exercise Tracking

Training Monitoring

Consistency Monitoring

5.15 Human Performance Intelligence Technologies

Future Holora systems may combine information from:

Wearables

Recovery Systems

Training Systems

Nutrition Systems

AI Systems

Behavioral Systems

to support Human Performance Intelligence services.

5.16 Device Authentication Technologies

Holora may utilize technologies designed to:

  • Authenticate wearable devices
  • Verify authorized connections
  • Prevent unauthorized device access

These technologies help improve security.

5.17 Firmware Technologies

Wearable devices may utilize firmware technologies supporting:

Device Functionality

Security Updates

Feature Enhancements

Device Stability

Firmware updates may be delivered periodically.

5.18 Device Diagnostics

Diagnostic technologies may be used to:

  • Identify technical issues
  • Improve device reliability
  • Investigate failures
  • Improve User experiences

5.19 Device Performance Monitoring

Holora may utilize technologies that evaluate:

  • Device connectivity
  • Device synchronization
  • Device stability
  • Technical performance

for operational purposes.

5.20 Wearable Notifications

Wearable devices may support notifications including:

Goal Reminders

Recovery Alerts

Activity Reminders

Educational Notifications

System Messages

where available.

5.21 Wearable Preferences

Technologies may remember:

  • Device preferences
  • Synchronization preferences
  • Notification preferences
  • User settings

to improve User experiences.

5.22 Cross-Device Functionality

Holora may support experiences that operate across:

Wearables

Smartphones

Tablets

Computers

Enterprise Dashboards

where functionality permits.

5.23 Third-Party Device Services

Third-party wearable integrations may require communication with services operated by device manufacturers.

Such services are governed by the policies of the applicable provider.

5.24 Device Security Technologies

Security technologies may be used to:

Prevent Unauthorized Access

Protect Device Connections

Secure Data Transfers

Protect User Information

5.25 Device Retention Technologies

Certain wearable-related technologies may remain active for periods necessary to:

  • Maintain device functionality
  • Support synchronization
  • Support User preferences
  • Support security requirements

5.26 User Controls

Users may be able to control wearable functionality through:

  • Device settings
  • Application settings
  • Operating system settings

Certain functionality may become unavailable if synchronization is disabled.

5.27 Future Wearable Technologies

This section applies to future wearable systems including:

Smart Glasses

Smart Clothing

Biometric Devices

Performance Sensors

Recovery Sensors

Future Human Performance Technologies

unless superseded by future disclosures.

5.28 No Sale Of Wearable Information

Technologies supporting wearable integrations are not used to sell:

Recovery Information

Wearable Information

Sleep Information

Activity Information

Biometric Information

to advertisers, data brokers, or unrelated third parties.

5.29 Transparency Principle

Holora seeks to maintain transparency regarding technologies supporting wearable functionality and Human Performance Intelligence systems.

5.30 Core Principle

Wearable technologies exist to help Users better understand themselves through greater visibility into recovery, activity, sleep, consistency, and performance-related information.

These technologies are intended to support understanding, education, and informed decision-making.

6. CONSENT MANAGEMENT, COOKIE BANNERS, USER CHOICE, WITHDRAWAL OF CONSENT, GDPR, UK GDPR, CCPA & PRIVACY RIGHTS

6.1 Overview

Holora is committed to respecting User privacy and providing meaningful control over the use of cookies and similar technologies.

Where required by applicable law, Holora seeks to obtain, manage, document, and honor User consent regarding the use of non-essential technologies.

This section explains how Users may exercise control over technology preferences and how Holora manages consent.

6.2 Consent Principles

Holora’s consent framework is guided by the principles of:

Transparency

User Choice

Privacy Protection

Regulatory Compliance

Accountability

User Control

These principles help ensure that Users remain informed about technology usage.

6.3 Cookie Banner Technologies

Where required by applicable law, Holora may display cookie or consent banners allowing Users to:

Accept All Technologies

Reject Non-Essential Technologies

Customize Preferences

Review Technology Categories

Modify Existing Choices

Consent interfaces may vary depending on jurisdiction and service.

6.4 Prior Consent Requirements

In jurisdictions where consent is legally required, Holora seeks to obtain consent before activating certain categories of non-essential technologies.

Examples may include:

Analytics Technologies

Personalization Technologies

Advertising Technologies (if introduced)

Certain Third-Party Technologies

6.5 Essential Technologies

Certain technologies are necessary for Platform operation and generally do not require consent where permitted by law.

Examples include:

Authentication Technologies

Security Technologies

Fraud Prevention Technologies

Session Technologies

Account Protection Technologies

Disabling such technologies may impair Platform functionality.

6.6 Granular Consent

Where appropriate, Users may be offered the ability to provide consent separately for different categories of technologies.

Examples may include:

Analytics

Personalization

Functional Technologies

Future Optional Technologies

This approach helps Users make informed choices.

6.7 Consent Records

Holora may maintain records of User consent decisions including:

  • Date of consent
  • Time of consent
  • Technology categories selected
  • Consent version
  • Preference updates

The purpose is to demonstrate compliance and respect User choices.

6.8 Withdrawal Of Consent

Users may withdraw consent for non-essential technologies at any time.

Withdrawal methods may include:

Consent Management Tools

Application Settings

Website Preferences

Device Controls

Browser Controls

Withdrawal of consent does not affect prior processing that occurred lawfully before withdrawal.

6.9 Updating Preferences

Users may modify technology preferences at any time through available preference management tools.

Preference updates may take effect immediately or within a reasonable technical timeframe.

6.10 Browser Controls

Many browsers allow Users to:

  • Delete cookies
  • Block cookies
  • Restrict cookies
  • Manage technology preferences

Browser settings vary depending on software providers.

6.11 Mobile Device Controls

Mobile devices may provide controls allowing Users to manage:

Application Permissions

Notification Permissions

Tracking Preferences

Device Identifiers

Advertising Preferences

Availability varies by operating system and device.

6.12 App-Level Controls

Holora may provide in-app controls allowing Users to manage certain technology preferences directly through the Platform.

Availability may vary depending on service functionality.

6.13 Impact Of Disabling Technologies

Disabling certain technologies may affect:

  • Authentication
  • Personalization
  • Recommendations
  • Performance
  • User experience
  • Marketplace functionality

Some features may become unavailable.

6.14 GDPR Rights

Users located within jurisdictions governed by the General Data Protection Regulation („GDPR“) may possess rights including:

Access Rights

Rectification Rights

Erasure Rights

Restriction Rights

Portability Rights

Objection Rights

Consent Withdrawal Rights

Additional details are available in the Privacy Policy.

6.15 UK GDPR Rights

Users located within the United Kingdom may possess rights under:

UK GDPR

Data Protection Act 2018

and related legislation.

6.16 European Economic Area Rights

Users located within the European Economic Area may exercise applicable privacy rights in accordance with relevant data protection laws.

6.17 California Privacy Rights

Eligible California residents may possess rights under applicable California privacy laws including:

Right To Know

Right To Access

Right To Correct

Right To Delete

Right To Opt-Out Where Applicable

Right To Non-Discrimination

Additional information is available in the Privacy Policy.

6.18 Global Privacy Rights

Depending upon location, Users may possess additional rights under applicable privacy laws.

Holora seeks to respect such rights where required by law.

6.19 Consent Renewal

Where required by law or appropriate for transparency purposes, Holora may periodically request Users to review or renew consent preferences.

6.20 Changes To Technology Categories

If Holora introduces materially new categories of non-essential technologies, additional consent may be requested where legally required.

6.21 Children’s Privacy

Holora is intended for individuals aged eighteen (18) years or older.

Holora does not knowingly seek consent from children.

6.22 Cross-Device Consent Management

Where technically feasible, Holora may attempt to synchronize technology preferences across multiple devices associated with the same account.

Availability may vary.

6.23 Enterprise User Preferences

Enterprise Users may have additional technology controls available through enterprise administration tools where applicable.

6.24 Do Not Track Signals

Certain browsers support „Do Not Track“ signals.

Because no universally accepted standard currently exists, Holora may not respond uniformly to such signals unless required by applicable law.

6.25 Global Privacy Control Signals

Where legally required and technically supported, Holora may recognize applicable privacy preference signals such as Global Privacy Control (GPC).

Implementation may vary by jurisdiction and technology environment.

6.26 Consent Management Providers

Holora may utilize trusted technologies to support:

  • Consent collection
  • Consent storage
  • Preference management
  • Compliance documentation

Such providers remain subject to applicable contractual and privacy obligations.

6.27 Regulatory Compliance

Holora seeks to manage consent practices in accordance with:

GDPR

UK GDPR

ePrivacy Requirements

CCPA

CPRA

Future Privacy Regulations

where applicable.

6.28 Transparency Commitment

Holora seeks to provide clear information regarding:

  • Technology usage
  • Consent choices
  • Privacy rights
  • User controls

to support informed decision-making.

6.29 User Empowerment Principle

Users should be able to make meaningful choices regarding non-essential technologies while maintaining access to essential Platform services.

6.30 Core Principle

Consent management exists to ensure that Users remain informed, empowered, and in control of technology preferences while allowing Holora to operate secure, functional, and privacy-conscious services.

7. THIRD-PARTY TECHNOLOGY PROVIDERS, CLOUD SERVICES, AI PROVIDERS, PAYMENT PROVIDERS, ANALYTICS PROVIDERS & INFRASTRUCTURE PARTNERS

7.1 Overview

Holora utilizes a variety of third-party service providers, infrastructure partners, technology vendors, and platform services to operate, secure, improve, and deliver Platform functionality.

These providers may utilize cookies and similar technologies in connection with the services they perform on behalf of Holora.

This section explains the categories of providers that may support Holora services.

7.2 Purpose Of Third-Party Technologies

Third-party technologies may support:

Cloud Infrastructure

Security

Authentication

Artificial Intelligence

Analytics

Payments

Notifications

Communications

Customer Support

Marketplace Operations

Wearable Integrations

Enterprise Services

7.3 Service Provider Principle

Holora seeks to engage providers that support:

  • Security
  • Reliability
  • Compliance
  • Scalability
  • Operational efficiency

Provider relationships may evolve over time as services develop.

7.4 Cloud Infrastructure Providers

Holora may utilize cloud infrastructure providers to support:

Data Storage

Application Hosting

Database Services

Content Delivery

Backup Systems

Disaster Recovery

Infrastructure Security

Cloud providers may use technologies necessary to operate and secure their services.

7.5 Data Hosting Technologies

Infrastructure providers may utilize technologies supporting:

  • Authentication
  • Monitoring
  • Security
  • Load balancing
  • Service reliability

These technologies help ensure stable service delivery.

7.6 Artificial Intelligence Providers

Holora may utilize AI-related providers supporting:

Large Language Models

Machine Learning Systems

Recommendation Engines

Natural Language Processing

Voice Technologies

Future AI Services

AI providers may process information necessary to provide AI functionality.

Additional information is available in the Privacy Policy and AI Policy.

7.7 AI Technology Partners

AI-related technologies may support:

  • AI conversations
  • AI recommendations
  • AI summaries
  • AI personalization
  • Human Performance Intelligence

Such technologies may evolve over time.

7.8 Analytics Providers

Holora may utilize analytics providers supporting:

Usage Analytics

Performance Analytics

Stability Monitoring

Error Tracking

Product Improvement

Analytics technologies help improve Platform functionality.

7.9 Performance Monitoring Providers

Performance monitoring technologies may be used to evaluate:

  • Service availability
  • Infrastructure performance
  • Application performance
  • Technical reliability

The objective is continuous improvement.

7.10 Error Reporting Providers

Holora may utilize technologies that identify:

Application Errors

System Failures

Connectivity Problems

Performance Issues

Error reporting helps improve service quality.

7.11 Payment Providers

Holora may utilize authorized payment providers supporting:

Subscription Payments

Marketplace Transactions

Digital Purchases

Future Commerce Services

Payment providers may use technologies necessary to:

  • Process transactions
  • Prevent fraud
  • Maintain compliance
  • Protect payment systems

7.12 Stripe Technologies

Where Stripe is utilized, Stripe may use technologies necessary to:

  • Process payments
  • Detect fraud
  • Verify transactions
  • Maintain payment security

Holora generally does not store full payment card information processed by Stripe.

Additional information is available within the Privacy Policy and Payment & Refund Policy.

7.13 Authentication Providers

Holora may utilize authentication providers supporting:

Account Verification

Login Services

Identity Management

Security Controls

Authentication technologies help protect User accounts.

7.14 Communication Providers

Holora may utilize providers supporting:

Email Communications

Notifications

Messaging

Security Alerts

Service Communications

These providers may use technologies necessary to deliver communications.

7.15 Push Notification Providers

Notification providers may support delivery of:

  • Security notifications
  • Marketplace notifications
  • Service messages
  • Goal reminders
  • Educational notifications

subject to User preferences.

7.16 Customer Support Providers

Holora may utilize technologies supporting:

Support Requests

Technical Assistance

Service Management

Customer Communications

These technologies help facilitate User support.

7.17 Security Providers

Holora may utilize security providers supporting:

Fraud Prevention

Threat Detection

Security Monitoring

Infrastructure Protection

Account Protection

Security technologies are essential to Platform operation.

7.18 Content Delivery Providers

Holora may utilize content delivery technologies supporting:

  • Images
  • Videos
  • Educational content
  • Application assets
  • Global performance optimization

These technologies help improve speed and reliability.

7.19 Marketplace Providers

Marketplace functionality may rely upon technologies supporting:

Professional Accounts

Messaging

Transactions

Service Delivery

Scheduling

Program Distribution

7.20 Wearable Technology Partners

Holora may integrate with providers supporting:

Smart Rings

Smart Bands

Smart Watches

Fitness Devices

Recovery Technologies

Future Wearable Systems

Such providers may operate their own technologies and privacy practices.

7.21 Enterprise Technology Providers

Enterprise services may utilize providers supporting:

Reporting

Administration

Security

Compliance

Access Management

Enterprise Integrations

7.22 Vendor Due Diligence

Holora may evaluate providers based on factors including:

Security

Privacy

Compliance

Reliability

Operational Suitability

Selection criteria may evolve over time.

7.23 Provider Access Limitations

Providers generally receive only the information reasonably necessary to perform contracted services.

Access may be limited through:

  • Contractual controls
  • Technical controls
  • Security controls

where appropriate.

7.24 Contractual Protections

Holora may require service providers to comply with contractual obligations relating to:

Confidentiality

Privacy

Security

Compliance

Data Protection

where appropriate.

7.25 International Service Providers

Certain providers may operate internationally.

As a result, technologies may function across multiple jurisdictions and legal frameworks.

Additional information is available in the Privacy Policy.

7.26 Future Technology Providers

As Holora evolves, new providers may be engaged to support:

Artificial Intelligence

Human Performance Intelligence

Wearables

Marketplace Services

Enterprise Services

Future Platform Features

7.27 Provider Changes

Holora reserves the right to:

  • Add providers
  • Replace providers
  • Remove providers
  • Modify provider relationships

as business and operational needs evolve.

7.28 Transparency Commitment

Holora seeks to maintain transparency regarding categories of third-party technologies supporting the Platform.

Specific providers may change periodically without requiring updates to this Cookie Policy.

7.29 No Sale Principle

Holora does not engage third-party providers for the purpose of selling:

Health Information

Recovery Information

Nutrition Information

Wearable Information

Biometric Information

Human Performance Information

to advertisers, data brokers, or unrelated third parties.

7.30 Core Principle

Third-party providers are engaged to help operate, secure, improve, and scale Holora services.

Such providers are intended to support service delivery, not to diminish User privacy protections.

8. COOKIE RETENTION PERIODS, STORAGE DURATIONS, DELETION PRACTICES, CONSENT RECORDS & DATA LIFECYCLE MANAGEMENT

8.1 Overview

Holora utilizes technologies that may remain active for varying periods of time depending upon their purpose, functionality, legal requirements, security requirements, and operational necessity.

This section explains how Holora manages:

  • Technology retention
  • Storage periods
  • Consent records
  • Deletion practices
  • Lifecycle management

for cookies and similar technologies.

8.2 Retention Principle

Holora seeks to retain technologies only for as long as reasonably necessary to:

Deliver Services

Protect Users

Maintain Security

Comply With Legal Obligations

Improve Platform Functionality

Support User Preferences

Retention periods may vary according to the purpose of the technology.

8.3 Session Technologies

Session technologies generally remain active only while a User is actively using the Platform.

Examples include:

Session Cookies

Session Tokens

Temporary Authentication Tokens

Temporary Security Tokens

Session technologies typically expire automatically when:

  • The session ends
  • The User logs out
  • The application closes
  • Inactivity thresholds are reached

8.4 Persistent Technologies

Certain technologies may remain active after a session ends.

Examples may include:

Login Preferences

Language Preferences

User Settings

Consent Preferences

Device Recognition Technologies

Persistent technologies may remain active until expiration, deletion, or modification.

8.5 Authentication Technologies

Authentication technologies may remain active for periods reasonably necessary to:

  • Maintain account security
  • Support account access
  • Prevent fraud
  • Support login continuity

Retention periods may vary depending on security requirements.

8.6 Security Technologies

Security technologies may be retained for longer periods where reasonably necessary to:

Detect Fraud

Investigate Abuse

Maintain Platform Security

Protect Infrastructure

Protect User Accounts

Security-related retention periods may exceed standard operational retention periods.

8.7 Consent Records

Holora may retain records relating to:

Consent Decisions

Preference Selections

Consent Modifications

Consent Withdrawals

Consent Versions

Such records help demonstrate compliance with applicable legal obligations.

8.8 Consent Record Retention

Consent records may be retained for periods reasonably necessary to:

  • Demonstrate compliance
  • Resolve disputes
  • Respond to regulatory inquiries
  • Maintain audit trails

where permitted by law.

8.9 Analytics Technologies

Analytics technologies may remain active for periods reasonably necessary to:

Evaluate Usage Patterns

Improve Services

Improve User Experiences

Improve Platform Performance

Retention periods may vary depending upon provider settings and legal requirements.

8.10 Performance Technologies

Performance-related technologies may be retained for periods necessary to:

  • Diagnose issues
  • Improve stability
  • Improve reliability
  • Support service operations

8.11 Personalization Technologies

Personalization technologies may remain active for periods necessary to remember:

User Preferences

Interface Settings

Platform Selections

Personalization Settings

Users may modify such preferences through available controls.

8.12 AI Personalization Technologies

AI-related technologies may remain active for periods reasonably necessary to support:

AI Memory Systems

AI Personalization

Recommendation Systems

Human Performance Intelligence

subject to applicable privacy obligations and User controls.

8.13 Marketplace Technologies

Marketplace-related technologies may be retained for periods necessary to support:

Service Delivery

Communications

Scheduling

Transactions

Account Management

8.14 Enterprise Technologies

Enterprise technologies may be retained according to:

  • Enterprise requirements
  • Contractual obligations
  • Security requirements
  • Compliance obligations

where applicable.

8.15 Wearable Technologies

Wearable-related technologies may remain active for periods necessary to support:

Device Pairing

Synchronization

User Preferences

Device Functionality

Human Performance Intelligence

8.16 Mobile Application Technologies

Mobile application technologies may remain active according to:

  • Application settings
  • Device settings
  • Operating system controls
  • Security requirements

8.17 Retention Schedule Examples

The following table provides general examples only:

Technology CategoryTypical Retention
Session TechnologiesSession Duration
Authentication TechnologiesUp to 12 Months
Security TechnologiesUp to 24 Months
Preference TechnologiesUp to 24 Months
Analytics TechnologiesUp to 26 Months
Consent RecordsUp to 5 Years
Enterprise TechnologiesContract Dependent

Actual retention periods may vary.

8.18 Automatic Expiration

Certain technologies automatically expire once predefined retention periods are reached.

Expiration periods may vary according to the technology category.

8.19 User Deletion Controls

Users may be able to delete technologies through:

Browser Controls

Device Controls

Application Controls

Privacy Settings

Availability may vary depending on technology type.

8.20 Clearing Browser Technologies

Users may generally delete browser-based technologies through browser settings.

Deleting technologies may affect:

  • Login status
  • Preferences
  • Personalization
  • Platform functionality

8.21 Mobile Technology Removal

Certain mobile technologies may be removed through:

  • Application deletion
  • Device resets
  • Operating system settings

Some information may remain associated with backend systems where legally permitted.

8.22 Account Closure

Following account closure, certain technologies may be removed, anonymized, or retained as required for:

Security

Compliance

Legal Obligations

Fraud Prevention

Dispute Resolution

Audit Requirements

8.23 Legal Retention Requirements

Certain information may be retained beyond standard periods where necessary to:

  • Comply with legal obligations
  • Enforce agreements
  • Resolve disputes
  • Protect Platform integrity

8.24 Regulatory Retention Requirements

Retention periods may be adjusted where required by:

GDPR

UK GDPR

CCPA

CPRA

Tax Regulations

Consumer Protection Laws

Future Legal Requirements

8.25 Data Minimization Principle

Holora seeks to retain technologies and associated records only for periods reasonably necessary to achieve legitimate purposes.

8.26 Lifecycle Management

Holora may maintain processes supporting:

Creation

Storage

Review

Retention

Deletion

Destruction

of technologies and related records.

8.27 Technology Audits

Holora may periodically review active technologies to:

  • Verify necessity
  • Verify compliance
  • Improve transparency
  • Improve lifecycle management

8.28 Future Technologies

This section applies to future technologies supporting:

AI Systems

Human Performance Intelligence

Wearables

Marketplace Services

Enterprise Services

unless superseded by future disclosures.

8.29 Transparency Commitment

Holora seeks to maintain transparency regarding retention periods and technology lifecycle practices.

8.30 Core Principle

Retention periods exist to balance:

  • User privacy
  • Security
  • Service functionality
  • Compliance obligations
  • Operational requirements

while supporting responsible management of technologies throughout their lifecycle.

9. INTERNATIONAL DATA TRANSFERS, CROSS-BORDER TECHNOLOGIES, GLOBAL OPERATIONS, CLOUD PROCESSING & INTERNATIONAL COMPLIANCE

9.1 Overview

Holora is a global technology platform that may provide services to Users, Professionals, Enterprise Clients, and other participants located in multiple countries and regions.

As a result, cookies and similar technologies may operate across international infrastructure, networks, systems, and service providers.

This section explains how cross-border technologies may function within the Holora ecosystem.

9.2 Global Operations

Holora may provide services internationally including through:

Mobile Applications

Web Applications

Marketplace Services

Artificial Intelligence Services

Wearable Services

Enterprise Services

Human Performance Intelligence Systems

Global operations may require information to move across national borders.

9.3 International Infrastructure

Holora may utilize infrastructure located in multiple jurisdictions to support:

Hosting

Security

Analytics

Artificial Intelligence

Communications

Marketplace Services

Enterprise Services

Infrastructure locations may change as services evolve.

9.4 Cross-Border Technologies

Cookies and similar technologies may support:

  • International authentication
  • Global service delivery
  • Global security monitoring
  • Global infrastructure management
  • Cross-device functionality
  • Global user experiences

These technologies may interact with systems operating in multiple jurisdictions.

9.5 Cloud Processing

Holora may utilize cloud service providers that process information internationally.

Cloud infrastructure may support:

Data Storage

Security Services

AI Services

Analytics Services

Content Delivery

Disaster Recovery

Business Continuity

9.6 International Marketplace Operations

Holora’s Marketplace may facilitate interactions between:

Users

Trainers

Nutritionists

Recovery Specialists

Educators

Enterprise Clients

located in different countries.

Technologies supporting these services may operate internationally.

9.7 International AI Services

Artificial Intelligence systems may utilize infrastructure located in jurisdictions different from the User’s location.

Such processing may be necessary to provide:

AI Conversations

AI Recommendations

AI Personalization

AI Memory Systems

Human Performance Intelligence

9.8 International Authentication Systems

Authentication technologies may utilize globally distributed systems designed to:

  • Improve security
  • Improve reliability
  • Improve availability

These systems may operate across multiple countries.

9.9 International Analytics Processing

Analytics technologies may process information through international infrastructure to support:

Platform Improvement

Product Development

Service Reliability

Security Monitoring

User Experience Improvements

9.10 International Notification Services

Communication and notification technologies may operate through globally distributed networks supporting:

Email Delivery

Push Notifications

Security Alerts

Marketplace Communications

Service Messages

9.11 International Wearable Services

Wearable integrations may involve internationally distributed systems supporting:

Device Synchronization

Recovery Analytics

Sleep Analytics

Human Performance Intelligence

Future Wearable Services

9.12 Enterprise Services

Enterprise services may involve international technologies supporting:

Reporting

Security

Administration

Compliance

Service Delivery

where permitted by applicable law.

9.13 Data Protection Principle

Holora seeks to implement safeguards intended to protect information regardless of where technologies operate.

Such safeguards may include:

Contractual Controls

Technical Controls

Security Controls

Organizational Controls

where appropriate.

9.14 International Transfer Safeguards

Where legally required, Holora may utilize safeguards including:

Standard Contractual Clauses

Contractual Commitments

Adequacy Mechanisms

Regulatory Safeguards

Future Approved Transfer Mechanisms

9.15 European Economic Area Transfers

Where information originating from the European Economic Area is transferred internationally, Holora intends to implement safeguards required by applicable law.

9.16 United Kingdom Transfers

Where information originating from the United Kingdom is transferred internationally, Holora intends to implement safeguards required under applicable UK laws.

9.17 Switzerland Transfers

Where applicable, transfers involving Swiss residents may be subject to additional safeguards required under Swiss privacy laws.

9.18 United States Processing

Certain technologies may operate through infrastructure located within the United States.

Users acknowledge that information may be processed within such jurisdictions where necessary to provide services.

9.19 Global User Base

Because Holora serves a global audience, technologies may support interactions between participants located in different countries.

Examples may include:

User-To-Trainer Relationships

User-To-Nutritionist Relationships

User-To-Recovery Specialist Relationships

Marketplace Transactions

Enterprise Programs

9.20 International Service Providers

Certain service providers supporting Holora may operate internationally.

These providers may process information necessary to deliver contracted services.

9.21 Regulatory Variations

Privacy, cookie, and technology regulations vary between jurisdictions.

Holora seeks to comply with applicable requirements relevant to Users and services.

9.22 Data Localization

Certain jurisdictions may require localized processing or storage.

Where required by law, Holora may implement localized solutions to support compliance.

9.23 Government Requests

Where legally required, information may be disclosed in response to valid legal requests from competent authorities.

Such disclosures remain subject to applicable laws.

9.24 Security Monitoring Across Borders

Security technologies may operate globally to help:

Detect Threats

Detect Fraud

Protect Infrastructure

Protect Users

Protect Marketplace Services

Global security monitoring may require international processing.

9.25 Future Global Services

As Holora expands internationally, additional technologies may be introduced supporting:

New Markets

New Services

New Infrastructure

Human Performance Intelligence

Enterprise Programs

Future Technologies

9.26 Transparency Commitment

Holora seeks to provide transparency regarding the international nature of technology operations and service delivery.

9.27 Compliance Commitment

Holora intends to monitor developments relating to:

GDPR

UK GDPR

CCPA

CPRA

International Privacy Laws

Future Regulatory Frameworks

and adapt practices where appropriate.

9.28 User Awareness

By using Holora services, Users acknowledge that technology systems supporting the Platform may operate internationally and may involve cross-border processing necessary to provide services.

9.29 Future Regulatory Adaptation

As international regulations evolve, Holora may modify technology practices, safeguards, and disclosures to support continued compliance.

9.30 Core Principle

Holora’s global infrastructure exists to provide secure, scalable, reliable, and accessible services to Users around the world while striving to maintain appropriate privacy, security, and compliance protections across international operations.

10.REGULATORY COMPLIANCE, GDPR, UK GDPR, ePRIVACY, CCPA, CPRA, AUDITS, ACCOUNTABILITY & GOVERNANCE

10.1 Overview

Holora is committed to operating its cookie and technology practices in a manner intended to support applicable legal, regulatory, privacy, security, and compliance requirements.

This section explains Holora’s approach to:

  • Regulatory compliance
  • Privacy governance
  • Accountability
  • Auditing
  • Consent management
  • Technology oversight
  • Future compliance obligations

10.2 Compliance Philosophy

Holora seeks to manage cookies and similar technologies according to the principles of:

Transparency

Accountability

Privacy Protection

Security

User Choice

Regulatory Compliance

Responsible Innovation

These principles guide the development and operation of technology-related practices.

10.3 GDPR Compliance

Where applicable, Holora seeks to operate technology and consent practices in accordance with the:

General Data Protection Regulation (GDPR)

including future amendments, guidance, and regulatory interpretations.

10.4 UK GDPR Compliance

Where applicable, Holora seeks to operate technology and consent practices in accordance with:

UK GDPR

Data Protection Act 2018

and related UK privacy requirements.

10.5 ePrivacy Compliance

Where applicable, Holora seeks to comply with:

ePrivacy Directive

National ePrivacy Implementations

Future ePrivacy Regulations

relating to cookies and similar technologies.

10.6 California Privacy Compliance

Where applicable, Holora seeks to comply with:

California Consumer Privacy Act (CCPA)

California Privacy Rights Act (CPRA)

including future amendments and implementing regulations.

10.7 International Privacy Compliance

Holora may seek compliance with applicable requirements arising under:

European Union Laws

United Kingdom Laws

United States Laws

Canadian Privacy Laws

Australian Privacy Laws

Middle East Privacy Laws

Future International Privacy Frameworks

where applicable.

10.8 Privacy By Design

Holora seeks to incorporate privacy considerations into:

Product Development

Platform Design

AI Systems

Wearable Systems

Marketplace Systems

Enterprise Services

where reasonably appropriate.

10.9 Security By Design

Holora seeks to incorporate security considerations into:

Authentication Systems

Infrastructure Systems

AI Systems

Mobile Applications

Wearable Integrations

Enterprise Services

to help protect Users and Platform operations.

10.10 Governance Framework

Holora may maintain governance processes relating to:

Cookie Management

Technology Management

Consent Management

Privacy Compliance

Security Oversight

Regulatory Monitoring

Such processes may evolve over time.

10.11 Accountability Principle

Holora seeks to maintain accountability for technology practices through:

  • Internal oversight
  • Documentation
  • Reviews
  • Compliance processes

where appropriate.

10.12 Technology Reviews

Holora may periodically review technologies used throughout the Platform to evaluate:

Necessity

Functionality

Compliance

Security

User Impact

Privacy Impact

10.13 Cookie Audits

Holora may conduct periodic reviews or audits of technologies to:

  • Verify technology usage
  • Verify retention periods
  • Verify consent requirements
  • Improve transparency

10.14 Consent Audits

Holora may periodically review:

Consent Mechanisms

Consent Records

User Controls

Preference Systems

to support compliance objectives.

10.15 Regulatory Monitoring

Holora may monitor developments relating to:

Privacy Laws

Cookie Laws

AI Regulations

Digital Platform Regulations

Consumer Protection Requirements

to support ongoing compliance efforts.

10.16 Vendor Oversight

Holora may review service providers supporting:

Analytics

AI

Infrastructure

Payments

Security

Communications

to assess suitability and compliance.

10.17 Documentation

Holora may maintain documentation relating to:

Technology Categories

Consent Systems

Retention Practices

Governance Activities

Compliance Reviews

where appropriate.

10.18 Employee Awareness

Holora may provide internal awareness and governance processes relating to:

Privacy

Security

Technology Management

Regulatory Compliance

where appropriate.

10.19 User Complaints

Users may raise concerns regarding:

  • Cookie usage
  • Technology practices
  • Consent management
  • Privacy controls

through available support channels.

10.20 Investigation Procedures

Holora may investigate concerns relating to:

Technology Usage

Consent Practices

Security Issues

Compliance Concerns

Privacy Complaints

where reasonably necessary.

10.21 Corrective Actions

Where issues are identified, Holora may implement corrective measures including:

Technology Adjustments

Consent Updates

Policy Updates

Security Improvements

Operational Improvements

10.22 Future AI Governance

As Holora expands its AI ecosystem, governance processes may be extended to technologies supporting:

AI Personalization

AI Memory Systems

AI Recommendations

Human Performance Intelligence

Voice AI

Future AI Services

10.23 Human Performance Intelligence Governance

Future Human Performance Intelligence systems may be subject to:

Privacy Reviews

Security Reviews

Compliance Reviews

Technology Assessments

where appropriate.

10.24 Enterprise Compliance Support

Enterprise customers may request information relating to:

Privacy Practices

Technology Practices

Governance Practices

Compliance Programs

subject to confidentiality and operational considerations.

10.25 Regulatory Cooperation

Holora may cooperate with:

Data Protection Authorities

Consumer Protection Authorities

Regulatory Bodies

Law Enforcement Agencies

where legally required.

10.26 Legal Updates

Technology laws continue to evolve globally.

Holora reserves the right to:

  • Update policies
  • Modify practices
  • Implement new controls
  • Introduce additional safeguards

to address future legal requirements.

10.27 Transparency Commitment

Holora seeks to provide transparent information regarding:

Cookie Usage

Technology Usage

Consent Practices

Privacy Rights

Governance Activities

10.28 Continuous Improvement

Holora is committed to continuously evaluating and improving:

  • Technology governance
  • Consent management
  • User controls
  • Privacy protections
  • Compliance programs

as services evolve.

10.29 Responsible Technology Commitment

Holora believes technology should support:

User Understanding

User Choice

User Privacy

User Security

while enabling useful and innovative experiences.

10.30 Core Principle

Holora’s technology governance framework is intended to balance:

  • Functionality
  • Personalization
  • Security
  • Compliance
  • Privacy

while supporting the responsible operation of a global Human Performance platform.

11. POLICY UPDATES, CONTACT INFORMATION, ENFORCEMENT, SEVERABILITY, FINAL PROVISIONS & CLOSING STATEMENTS

11.1 Overview

This Cookie Policy forms part of the Holora legal and compliance framework and should be read together with all applicable Holora policies and agreements.

This Policy applies to all technologies used in connection with Holora services unless superseded by a more specific notice or agreement.

11.2 Relationship To Other Policies

This Cookie Policy should be read together with:

Terms of Service

Privacy Policy

AI Policy

Health Disclaimer

Marketplace Terms

Trainer Agreement

Payment & Refund Policy

Community Guidelines

Data Processing Addendum

Where a conflict exists, the document most directly governing the issue shall prevail.

11.3 User Acceptance

By accessing, browsing, registering for, subscribing to, downloading, installing, or using Holora services, Users acknowledge that:

  • They have been informed of this Cookie Policy.
  • They understand this Cookie Policy.
  • They agree to this Cookie Policy.
  • They understand that technologies described herein may be used in connection with Platform services.

Where consent is legally required, use of non-essential technologies remains subject to applicable consent requirements.

11.4 Continuing Acceptance

Continued use of Holora services following publication of updates may constitute acceptance of revised terms where permitted by applicable law.

Where additional consent is required, Holora will seek such consent through appropriate mechanisms.

11.5 Policy Updates

Holora reserves the right to modify this Cookie Policy periodically.

Updates may occur for reasons including:

Regulatory Changes

Legal Changes

Technology Changes

Security Improvements

Service Enhancements

AI Developments

Wearable Developments

Marketplace Developments

Human Performance Intelligence Developments

11.6 Material Changes

Where changes materially affect User rights or obligations, Holora may provide notice through:

Website Notices

Platform Notifications

Email Communications

In-App Communications

Consent Interfaces

where appropriate and legally required.

11.7 Version Control

Holora may maintain version histories of this Cookie Policy to support:

Transparency

Compliance

Regulatory Requirements

Internal Governance

Audit Requirements

11.8 Contact Information

Questions regarding this Cookie Policy may be directed to Holora through designated support channels made available through:

Website Contact Forms

Platform Support Systems

Enterprise Support Channels

Privacy Requests

Legal Requests

Contact details may be updated periodically.

11.9 Privacy Requests

Users wishing to exercise privacy rights may submit requests relating to:

Access

Correction

Deletion

Restriction

Portability

Objection

Consent Withdrawal

subject to applicable laws.

Additional information is available within the Privacy Policy.

11.10 Technology Complaints

Users may submit concerns relating to:

Cookie Usage

Consent Management

Technology Practices

Privacy Concerns

Security Concerns

AI Personalization Technologies

through designated support channels.

11.11 Investigation Of Concerns

Holora may review and investigate concerns relating to:

  • Technology practices
  • Consent practices
  • Privacy controls
  • Compliance obligations

where reasonably appropriate.

11.12 Enforcement

Holora may take actions necessary to:

Protect Users

Protect Infrastructure

Protect Marketplace Services

Protect Enterprise Services

Protect AI Systems

Maintain Compliance

where reasonably necessary.

11.13 Suspension Of Technologies

Holora reserves the right to:

  • Disable technologies
  • Modify technologies
  • Replace technologies
  • Remove technologies

where operational, security, legal, or compliance considerations require such actions.

11.14 Regulatory Cooperation

Holora may cooperate with:

Data Protection Authorities

Consumer Protection Authorities

Regulatory Agencies

Courts

Law Enforcement Agencies

where legally required.

11.15 Legal Disclosures

Holora may disclose information relating to technologies where necessary to:

Comply With Laws

Respond To Legal Requests

Protect Rights

Protect Users

Protect Infrastructure

Enforce Agreements

subject to applicable laws.

11.16 Severability

If any provision of this Cookie Policy is determined to be invalid, unlawful, or unenforceable, the remaining provisions shall remain in full force and effect.

11.17 No Waiver

Failure by Holora to enforce any provision of this Cookie Policy shall not constitute a waiver of that provision or any other provision.

11.18 Survival

Any provisions that by their nature should survive termination shall continue in effect following:

  • Account closure
  • Service termination
  • Relationship termination

including compliance, audit, and recordkeeping provisions where applicable.

11.19 Future Technologies

This Cookie Policy applies to future technologies including:

Artificial Intelligence Systems

AI Memory Systems

Voice Technologies

Human Performance Intelligence Systems

Wearable Technologies

Future Marketplace Technologies

Future Enterprise Technologies

unless superseded by future policies.

11.20 Future Regulatory Developments

As privacy, AI, wearable, and digital platform regulations evolve, Holora may modify technology practices and disclosures to support compliance and responsible innovation.

11.21 User Awareness

Users acknowledge that modern digital services require technologies supporting:

Security

Authentication

Personalization

Service Delivery

Platform Functionality

and that certain technologies are essential for operation of the Platform.

11.22 Transparency Commitment

Holora seeks to maintain transparency regarding:

  • Technology usage
  • Cookie usage
  • Personalization technologies
  • AI technologies
  • Consent practices
  • User rights

through ongoing disclosures and policy updates.

11.23 Privacy Commitment

Holora is committed to protecting User privacy and seeks to use technologies responsibly, lawfully, and transparently.

11.24 Security Commitment

Holora is committed to implementing reasonable technical and organizational measures intended to support:

Security

Integrity

Availability

Confidentiality

of Platform services.

11.25 Innovation Commitment

Holora believes technology should enhance human understanding and access to knowledge while respecting privacy and user choice.

11.26 Human Performance Philosophy

Holora’s long-term vision combines:

Artificial Intelligence

Human Expertise

Wearable Technologies

Recovery Intelligence

Global Knowledge

to help individuals better understand themselves and move closer to their goals.

11.27 Responsible Technology Principle

Technology should support Users.

Technology should not replace personal responsibility.

Technology should provide information, understanding, and access while respecting privacy and autonomy.

11.28 Final User Acknowledgement

By using Holora services, Users acknowledge that technologies described within this Policy may be used to:

  • Operate services
  • Secure services
  • Improve services
  • Personalize experiences
  • Support Artificial Intelligence
  • Support Human Performance Intelligence
  • Facilitate Marketplace services

in accordance with applicable laws and Platform policies.

11.29 Final Compliance Statement

Holora intends to operate its cookie and technology practices in a manner consistent with applicable privacy, security, consumer protection, and technology regulations while supporting innovation and service quality.

11.30 Final Statement

Holora was created to help people better understand themselves through technology, education, artificial intelligence, wearable intelligence, and access to global expertise. The technologies described in this Cookie Policy exist to support that mission while striving to respect privacy, transparency, security, and user choice.

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