Holgo Privacy Policy
September 26, 2026
Introduction
This Privacy Policy explains how Holgo ("Holgo", "holgo.com", "we", "our", or "us") collects, uses, shares, and protects your information when you use our website and services (the "Service"). Holgo is the controller of the personal information described here. By using the Service, you agree to this Privacy Policy.
Information We Collect
- Account information: Your name and email address, provided when you register or when you sign in with a third-party provider such as Google.
- Product content: The photos, product details, and listing information you upload or generate to create listings.
- Marketplace connection data: When you connect a marketplace account (such as Etsy), we store the authorization tokens needed to publish on your behalf. We do not receive or store your marketplace password.
- Billing information: Records of your subscriptions, credit purchases, and transactions. Payments are processed by Stripe; we do not store your full card details.
- Communications: Messages you send us for support or other inquiries.
- Usage and device data: Information about how you interact with the Service, such as pages visited, actions taken, IP address, browser type, and operating system, collected in part through cookies and similar technologies.
How We Use Your Information
We use your information to:
- Provide the Service, including AI recognition of your product photos and generation of listing content;
- Publish listings to the marketplaces you connect and authorize;
- Process payments, allocate credits, and manage your subscription;
- Provide customer support and send transactional or account-related emails;
- Send product updates or newsletters where permitted, which you can opt out of at any time;
- Monitor, secure, and improve the Service, and detect and prevent fraud and abuse;
- Comply with legal obligations and enforce our terms.
Free Credits and Abuse Prevention
Free credits are limited to one account per person. To enforce this, when you create an account we record keyed, one-way hashes of your email address (normalized, so that variations of the same mailbox match), a random identifier stored in a cookie on your device, a device fingerprint generated by your browser, and the network block of your IP address. We store only these hashes, not the underlying values, and compare them with other accounts to decide whether a new account receives free credits. An account that matches one that already received them can still be used, and credits can be purchased; it simply does not receive free credits again. We process this data on the basis of our legitimate interest in preventing fraud and abuse of the Service. If you believe a decision about your account is wrong, contact us and a person will review it.
Legal Bases for Processing (EEA/UK)
Where the GDPR or UK GDPR applies, we process personal information on the following bases: performance of our contract with you (to provide the Service); our legitimate interests (to secure, maintain, and improve the Service and prevent fraud); your consent (for example, for marketing emails, which you may withdraw at any time); and compliance with legal obligations.
AI Processing of Your Photos
To recognize your items and generate listings, we send your product images and related data to third-party AI providers (such as Anthropic, OpenAI, and Google) that process them on our behalf. Uploaded images are stored using a third-party cloud storage provider (Cloudflare R2). Images that are not attached to a saved listing are automatically removed by routine cleanup processes. The AI generates draft content for your review; we do not use it to make decisions that produce legal or similarly significant effects about you without human involvement.
How We Share Information
We do not sell your personal information, and we do not "share" it for cross-context behavioral advertising as those terms are defined under California law. We share information only as needed to provide the Service, including with:
- AI providers, to recognize products and generate listing content;
- Marketplaces (e.g., Etsy), when you choose to publish a listing to a connected account;
- Payment processor (Stripe), to handle billing;
- Email and infrastructure providers, to deliver messages, host content, provide security (such as bot protection), and operate the Service;
- Authorities or others, where required by law or to protect our rights, users, and the public;
- A successor, in connection with a merger, acquisition, or sale of assets, subject to this Privacy Policy.
Cookies
We use cookies and similar technologies as described in our Cookie Policy.
Data Retention
We retain your account and listing data while your account is active. Uploaded images not referenced by a saved listing are cleaned up automatically. We retain billing and transaction records for as long as required for legal, tax, and accounting purposes. The hashed network block and browser details recorded at sign-up are deleted after 30 days. When you delete your account, we keep the hashed email and device identifiers described under "Free Credits and Abuse Prevention" for three years, solely to prevent the same person from claiming free credits again, and then delete them. When data is no longer needed, we delete or anonymize it.
International Data Transfers
We and our service providers may process and store your information in the United States and other countries whose data-protection laws may differ from those in your country. Where required, we use appropriate safeguards (such as the European Commission's Standard Contractual Clauses) for such transfers.
Data Security
We implement appropriate technical and organizational measures to protect your information from unauthorized access, alteration, disclosure, or destruction. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. Where required by law, we will notify you of a data breach that affects your personal information.
Your Privacy Rights
California residents (CCPA/CPRA): You have the right to know the personal information we collect and how we use and disclose it; to request access to and a copy of that information; to request correction or deletion; and to be free from discrimination for exercising your rights. We do not sell or share your personal information, so no opt-out is required, and we do not use sensitive personal information for purposes that would trigger a right to limit its use.
EEA/UK residents (GDPR): You have the right to access, correct, delete, restrict, or object to the processing of your personal information; to data portability; to withdraw consent at any time (without affecting prior processing); and to lodge a complaint with your local supervisory authority.
To exercise any of these rights, contact us using the details below. We will respond within the timeframe required by applicable law and may need to verify your identity before acting on your request.
Marketing Communications
You can opt out of marketing emails at any time by using the unsubscribe link in those messages or by contacting us. We may still send you transactional or account-related messages that are necessary to operate the Service.
Children's Privacy
The Service is not directed to individuals under 18, and we do not knowingly collect personal information from them. If you believe a minor has provided us personal information, contact us and we will delete it.
Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will post any changes on this page and revise the date above, and will provide additional notice where required by law.
Contact Us
If you have any questions about this Privacy Policy or wish to exercise your rights, please contact us or email us at ceo@holgo.com.