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Last Updated: May 11, 2026 This draft is provided as a business privacy policy template for review by qualified counsel before publication.
  1. Introduction
This Privacy Policy explains how HOLOGROW INC, doing business in connection with Hologrow Pulse (‘Hologrow,’ ‘we,’ ‘us,’ or ‘our’), collects, uses, discloses, and protects personal information when individuals visit our websites, use Hologrow Pulse, interact with our sales, marketing, support, or events, or otherwise communicate with us. Hologrow Pulse is a business-to-business AI software-as-a-service product. In many cases, we process personal information on behalf of our business customers under a commercial agreement. In those cases, the customer is responsible for determining the purposes and means of processing, and Hologrow acts as a service provider, processor, or subprocessor as applicable. If you do not agree with this Privacy Policy, do not use our websites or services. If you have questions, contact us at internal@hologrow.ai.
  1. Summary of Key Points
We collect personal information that you provide directly, information collected automatically through our websites and services, and information from customers, business partners, integrations, and third-party platforms when authorized. We use personal information to provide, secure, operate, improve, and support Hologrow Pulse; communicate with customers and users; administer accounts and billing; conduct sales and marketing; comply with law; and protect rights, safety, and security. Hologrow Pulse may process data from business systems, ecommerce tools, advertising platforms, analytics tools, customer support tools, CRM systems, email platforms, warehouses, spreadsheets, and other integrations configured by our customers. We do not knowingly collect personal information from children under 18, and Hologrow Pulse is not directed to children. We may share personal information with service providers, subprocessors, affiliates, professional advisors, business transfer parties, authorities where legally required, and third-party integrations selected or authorized by customers. Depending on where you live, you may have rights to access, correct, delete, restrict, object to, or port your personal information, and rights relating to marketing communications and certain automated processing.
  1. Personal Information We Collect
Account and contact information, such as name, business email address, phone number, company name, job title, account credentials, profile information, workspace membership, and communication preferences. Commercial and billing information, such as subscription plan, invoices, payment status, billing address, tax information, purchase history, contract records, and payment processing references. We do not intentionally store full payment card numbers unless expressly disclosed and supported by an approved payment processor. Customer Content and business data, such as prompts, instructions, uploaded files, reports, dashboards, workflow configurations, alerts, connected data source content, notes, generated outputs, and other information submitted to or processed through Hologrow Pulse by or on behalf of a customer. Integration data, such as metadata, records, events, metrics, campaign information, product data, order data, customer support data, analytics data, advertising data, CRM data, email engagement data, access tokens, API keys, scopes, and permissions from third-party services connected by a customer or user. Usage, device, and log information, such as IP address, browser type, device identifiers, operating system, pages viewed, features used, actions taken, timestamps, referring URLs, error logs, session activity, approximate location derived from IP address, and diagnostic information. Communications information, such as emails, chat messages, support tickets, meeting notes, call recordings where disclosed, survey responses, event registrations, demo requests, and feedback. Marketing information, such as preferences, campaign interactions, website activity, webinar attendance, lead source, and information from public sources, business directories, or marketing partners. We generally do not seek to collect sensitive personal information, such as government identification numbers, precise geolocation, biometric information, health information, payment card data, children’s data, or protected class information. Customers should not submit sensitive personal information to Hologrow Pulse unless expressly authorized in writing and supported by an applicable data processing agreement.
  1. Sources of Personal Information
We collect personal information directly from you when you create an account, request a demo, contact us, subscribe to communications, participate in events, submit support requests, or use Hologrow Pulse. We collect information automatically when you visit our websites or use our services, including through cookies, pixels, SDKs, logs, analytics tools, and similar technologies. We collect information from our business customers when they invite users, configure workspaces, upload data, connect integrations, or otherwise use Hologrow Pulse. We may receive information from third-party services that a customer or user connects to Hologrow Pulse, such as ecommerce platforms, advertising networks, analytics platforms, CRM systems, helpdesk systems, email platforms, data warehouses, cloud storage providers, spreadsheets, and collaboration tools. We may receive business contact information from public sources, referrals, events, partners, lead providers, and other lawful business sources.
  1. How We Use Personal Information
To provide, operate, maintain, administer, and support Hologrow Pulse and related services. To authenticate users, manage accounts, configure workspaces, enable integrations, process subscriptions, issue invoices, and provide customer support. To generate, display, and deliver analyses, summaries, recommendations, alerts, automations, reports, dashboards, and other AI-assisted outputs requested or configured by customers. To monitor, secure, debug, troubleshoot, and improve the performance, reliability, safety, and integrity of our services. To communicate about product updates, security notices, support matters, billing, contract administration, events, surveys, and marketing communications. To personalize and improve the user experience, understand feature adoption, measure engagement, conduct analytics, and develop new features. To comply with legal obligations, respond to lawful requests, enforce our agreements, prevent fraud, protect rights and safety, and defend against claims. To carry out any other purpose disclosed at the time of collection or with your consent.
  1. AI Processing and Product Improvement
Hologrow Pulse may use artificial intelligence, machine learning, retrieval systems, rules-based automation, and third-party or Hologrow-operated models to process customer-configured data and generate outputs. We may use prompts, instructions, Customer Content, usage data, logs, metadata, and outputs as necessary to provide, secure, troubleshoot, and support the services for the relevant customer. We may use aggregated, anonymized, or de-identified information to understand usage, improve our services, develop features, measure performance, and maintain security, provided such information does not identify a customer or individual. We will not use Customer Content to train generally available foundation models except where expressly permitted by a written agreement, customer-controlled setting, or applicable data processing terms. Customers are responsible for ensuring that their use of Hologrow Pulse, including AI-generated outputs and connected data sources, complies with applicable privacy, data protection, advertising, employment, consumer protection, and platform laws and policies.
  1. Cookies and Similar Technologies
We and our service providers may use cookies, pixels, web beacons, local storage, session replay where disclosed, analytics tools, and similar technologies to operate our websites and services, remember preferences, authenticate users, improve performance, understand usage, and support marketing. You can usually configure your browser to reject or delete cookies. Some parts of our websites or services may not function properly if cookies are disabled. Where required by law, we will provide cookie choices or obtain consent for non-essential cookies.
  1. How We Share Personal Information
Service providers and subprocessors. We share information with vendors that provide hosting, cloud infrastructure, security, analytics, email delivery, payment processing, customer support, CRM, data processing, AI model, monitoring, logging, and other services for us. Customer administrators. If you use Hologrow Pulse through a customer account, administrators and authorized personnel of that customer may access information about your account, activity, content, permissions, and use of the services. Third-party integrations. We share information with third-party services selected, connected, or authorized by a customer or user, as necessary to provide the integration or workflow. Affiliates and business partners. We may share information with affiliates and business partners where appropriate for operating, selling, supporting, or improving our services. Professional advisors. We may share information with lawyers, auditors, accountants, insurers, bankers, and other professional advisors. Legal and safety purposes. We may disclose information to comply with law, legal process, government requests, enforce agreements, prevent fraud or abuse, protect rights and safety, or investigate security incidents. Business transfers. We may disclose or transfer information in connection with a merger, acquisition, financing, reorganization, bankruptcy, sale of assets, or similar business transaction. Consent or direction. We may share information with your consent or at the direction of you or the relevant customer.
  1. International Transfers
Hologrow is based in the United States, and we and our service providers may process personal information in the United States and other countries where we or they operate. If personal information is transferred from the European Economic Area, the United Kingdom, Switzerland, or other regions with transfer restrictions, we will use appropriate safeguards where required, such as Standard Contractual Clauses, a data processing addendum, or other lawful transfer mechanisms.
  1. Data Retention
We retain personal information for as long as reasonably necessary to provide the services, maintain accounts, comply with legal obligations, resolve disputes, enforce agreements, maintain security, prevent fraud, and fulfill the purposes described in this Privacy Policy. Customer Content is retained according to the applicable customer agreement, product settings, backup practices, legal requirements, and deletion workflows. We may retain de-identified, anonymized, or aggregated information for legitimate business purposes where permitted by law.
  1. Security
We use commercially reasonable administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, loss, misuse, alteration, and disclosure. No system, transmission, or storage method is completely secure. We cannot guarantee absolute security of information, and customers and users are responsible for maintaining secure credentials, limiting permissions, and using appropriate account security controls.
  1. Your Privacy Rights and Choices
Depending on your location and applicable law, you may have the right to request access to, correction of, deletion of, restriction of, or portability of your personal information. You may also have the right to object to certain processing or withdraw consent where processing is based on consent. If your personal information is processed by Hologrow on behalf of a business customer, we may refer your request to that customer or require you to contact that customer directly. You may opt out of marketing emails by using the unsubscribe link in the email or by contacting us. We may still send transactional or service-related communications. You may control cookies through browser settings and, where available, cookie preference tools. To exercise privacy rights, contact us at internal@hologrow.ai. We may need to verify your identity and authority before responding.
  1. EEA, UK, and Switzerland Notice
Where the General Data Protection Regulation, UK GDPR, Swiss data protection law, or similar laws apply, our legal bases for processing may include performance of a contract, legitimate interests, consent, compliance with legal obligations, and protection of vital interests. Our legitimate interests include providing and improving our services, securing our systems, communicating with business contacts, conducting business-to-business marketing, preventing fraud, enforcing agreements, and managing business operations. Individuals in the EEA, UK, and Switzerland may have rights to access, rectify, erase, restrict, object to processing, data portability, withdraw consent, and lodge a complaint with a supervisory authority.
  1. California Privacy Notice
This section applies to California residents and is intended to supplement the rest of this Privacy Policy. In the past twelve months, we may have collected identifiers; California customer records information; commercial information; internet or other electronic network activity information; geolocation information derived from IP address; professional or employment-related information; audio, electronic, or visual information where calls or events are recorded with notice; and inferences derived from the foregoing. We collect these categories from the sources described in Section 4 and use them for the purposes described in Section 5. We may disclose these categories to the categories of recipients described in Section 8. We do not knowingly sell personal information in the traditional sense. We also do not knowingly sell or share personal information of individuals under 16. If our use of advertising or analytics technologies is considered a ‘sale’ or ‘sharing’ under California law, California residents may opt out by contacting us or using available cookie controls. California residents may have the right to know, access, correct, delete, opt out of sale or sharing, limit use of sensitive personal information where applicable, and not be discriminated against for exercising privacy rights.
  1. Other U.S. State Privacy Rights
Residents of certain U.S. states, such as Colorado, Connecticut, Virginia, Utah, Oregon, Texas, and others, may have additional privacy rights under applicable state privacy laws. Depending on the state, these rights may include access, correction, deletion, portability, opt-out of targeted advertising, opt-out of sale, opt-out of certain profiling, and appeal of a denied request. To exercise these rights, contact us at internal@hologrow.ai. We will respond in accordance with applicable law.
  1. Children
Our websites and services are intended for business users and are not directed to children under 18. We do not knowingly collect personal information from children under 18. If you believe a child has provided personal information to us, contact us at internal@hologrow.ai, and we will take appropriate steps to delete the information where required.
  1. Third-Party Links and Services
Our websites and services may link to or integrate with third-party websites, platforms, applications, and services. Their privacy practices are governed by their own privacy policies, not this Privacy Policy. Customers and users are responsible for reviewing the privacy and security terms of third-party services they connect to Hologrow Pulse.
  1. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. If we make material changes, we will provide notice by posting the updated policy, sending an email, providing an in-product notice, or using other reasonable means. The updated Privacy Policy will be effective as of the date stated at the top of the policy unless a different effective date is specified.