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Privacy Policy

Last Updated: April 2026

This Privacy Policy explains how your personal information is collected, used, and shared when you use the Holdr website located at https://www.holdr.com/ (the "Site") and any services and technology platforms available thereon, including the services that enable you to engage with, support, and obtain memberships to modernized fan clubs ("Holdr Clubs") and communities for various artists and creatives (the "Services").

1. Important Information

The Site is owned and operated by Chaotic Technologies Inc., dba Holdr ("Holdr", "Holdr Club", "we", "our" or "us"). Holdr is a software platform that facilitates the connection between musical artists and their fans through Holdr Clubs. This Privacy Policy describes what information we collect, how we use that information, and how we handle and protect your personal information in accordance with this Privacy Policy and Holdr's Terms of Service. Please review this privacy policy carefully. By submitting your personal information to us, by using our Site, or by otherwise accessing or engaging in the Services, you consent to our collecting, using and disclosing your personal information as set out in this privacy policy. If you do not agree, you should not use the Site or Services.

2. What Personal Information Do We Collect About You?

Personal information is any information that identifies or is capable of being associated with an identifiable individual.

Personal information does not include information where there is no serious possibility that it can be used to identify an individual, whether on its own or in combination with other information, or personal information that has been anonymized or aggregated such as to be considered anonymized information or no longer personal information under applicable laws.

The primary basis on which we collect, use and disclose your personal information is with your consent unless otherwise permitted or required by law. How we obtain your consent will depend on the circumstances, as well as the sensitivity of the information collected. Typically, we will seek your consent at the time your personal information is collected.

You may withdraw your consent to our collection, use or disclosure of your personal information at any time by contacting us using the contact information within our Site. However, before we implement the withdrawal of consent, we may require proof of your identity. In some cases, withdrawal of your consent may mean that we will no longer be able to provide certain products or services.

If you provide personal information about another individual to us, it is your responsibility to obtain the consent of that individual to enable us to collect such information from you, and to use and disclose his or her information as described in this privacy policy.

We collect personal information from you in the following ways:

Information You Provide Directly to Us:

  • User information: When you create an account, we may collect identifiers such as your name, username, email address, photograph or other likeness, settings, associations with artists and fans, purchase history, blockchain address, and any other information you provide in connection with your user account.
  • Preferences and Feedback: We collect information about your preferences and any feedback you provide.
  • User financial information: Your credit or debit card number, bank account number, and billing and shipping address. This information is collected and processed by our payment provider, as necessary to complete your purchase. We do not receive your credit card information directly, but we may receive information about the transaction, such as the date, amount, and time it occurred.
  • Artist information: user-provided biography, and location.
  • Fan information: user-provided name, email address, country of residence, zip/postal code, picture, location, and biography.

Information from Third Parties: If you authorize third parties like Google or Spotify to share your personal information with us, we may collect identifiers from them, such as your name, email address, profile image, account ID, preferences, and other login/account details.

Information Collected Automatically: We collect usage information relating to your use of our Site. Such information may include your Internet protocol (IP) address, information about your device, browser and operating system information, how you are using our Site, and the date and time of your visit.

Cookie Policy

We use "cookies" and enlist third-party services which use cookies to track your preferences and activities on our Site. Cookies are small data files transferred to your computer's hard drive by a website. They keep a record of your preferences and login information, making your subsequent visits to the Site more efficient and secure. Cookies may store a variety of information, including the number of times that you access a website, your login information, your device information, IP address, and the number of times that you view a particular page or other item on the Site. The use of cookies is a common practice adopted by most major websites to better serve their users. You have a variety of tools to control the information collected by cookies, web beacons, and similar technologies when you use our Site. For example, you can use controls in your internet browser to limit how the websites you visit are able to use cookies and to withdraw your consent by clearing or blocking cookies. You should note, however, that without cookies some of our Site's functions may not be available.

3. How Do We Use the Personal Information We Collect?

We use the personal information collected to deliver our Services pursuant to the Terms of Service. Specifically, we use your information to:

  • Verify your identity so you can join and exit Holdr Clubs.
  • To manage your use.
  • Communicate with you about changes to the Site, Services, or policies.
  • Detect and prevent fraudulent and impermissible uses of the Site and Services.
  • Maintain, operate, and improve the Site and Services.
  • Send you emails about Holdr if you provide your email address and consent.
  • Conduct internal research and support internal business operations.
  • To comply with legal and regulatory requirements, where applicable.

We may use your personal information and other information for purposes for which we have obtained your consent, and for such other purposes as may be permitted or required by applicable law.

4. Do We Share the Personal Information We Collect?

Sharing with Artists: To enable you to participate in Holdr Clubs, we will share your personal information with the relevant artists.

Sharing with Third Parties: We share your personal information with third-party service providers who perform some functionality within the Site and Services on our behalf, such as customer service, technical support, hosting, data storage and processing, and research and analytics. We also share your information with third-party service providers who provide products and services that we use to operate our business, such as payment processing, email services, marketing campaigns, surveys and contests.

If we provide your information to service providers for our provision of the Services and Site, then we require those service providers to maintain the confidentiality of your personal information and to keep your personal information secure. We also require that they only use your personal information for the limited purposes for which it is provided. When our service providers no longer need your personal information for those limited purposes, we require that they dispose of the personal information. In some circumstances, we may permit our service providers to retain anonymized or statistical information that does not identify you. We do not authorize the service providers to disclose your personal information to unauthorized parties or to use your personal information for their direct marketing purposes.

Other Disclosures: Additionally, we may disclose your information when we believe such disclosure is permitted, necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce the terms of the agreements for our products and services; (e) to protect our operations or those of any of our affiliates or subsidiaries; (f) to protect our rights, privacy, safety or property, and/or those of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain. In addition, we may transfer your personal information and other information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, brands, affiliates, subsidiaries or other assets.

If we otherwise intend to disclose your personal information to a third party, we will identify that third party and the purpose for the disclosure, and obtain your consent.

5. Do We Collect and/or Share the Personal Information of Children?

Our Services are not intended for children under 13. We do not knowingly collect personal information from children under 13. If we learn that we have collected such information, we will delete it promptly. If you are a parent or guardian and believe we have collected personal information from your child, please contact us at support@holdr.com.

6. Where Do We Process Your Personal Information?

Our Site and Services are operated from Canada. If you are located outside of Canada, your information will be transferred to, processed in, and stored in Canada. By using the Site and Services, you consent to this transfer, processing, and storage of your information in Canada.

7. How Do We Keep Your Personal Information Safe?

Holdr aims to protect user information to ensure that your Personal Data is kept private. We take reasonable steps (including appropriate technical and organizational security measures) in an effort to ensure your Personal Data is processed securely and to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access. However, no measures are 100% secure, and unauthorized entry or use, hardware or software failure, and other factors may compromise the security of your Personal Data. As such, we cannot guarantee or warrant the security of any information you transmit to us via the internet and any transmission is at your own risk. To protect the security of your data, it is your responsibility to select and protect your password appropriately and limit access to your computer and browser by signing off after you have finished accessing your account.

8. How Long Do We Hold Your Personal Information?

We retain personal information for as long as necessary to fulfill legitimate business purposes, or as required by applicable laws, regulations, or government orders. After the relevant amount of time has passed, we will delete your information. You may request deletion of your information as described in the "What Rights Do I Have?" section below.

9. What Rights Do I Have in Relation to My Personal Information?

  • Right of Access: You can request copies of your personal information.
  • Right to Rectification: You can request correction of inaccurate or incomplete information.
  • Right to Erasure: You can request deletion of your personal information in certain circumstances.
  • Right to Restrict Processing: You can request restriction of processing in certain circumstances.
  • Right to Object: You can object to the processing of your personal information in certain circumstances.
  • Right to Withdraw Consent: You can withdraw your consent for future processing.

To exercise these rights, contact us at support@holdr.com. We will respond to your request in accordance with applicable laws.

Please note that such rights are not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal data that we hold about you. In the event that we cannot accommodate your request, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

When you exercise your right to deletion of your personal information, we will delete your personal information, subject to some instances where your personal information will be maintained for us to fulfill our obligations under contract.

10. How Do I Contact Holdr?

Email: support@holdr.com. Phone: +1 604-631-3131. Mail: Chaotic Technologies Inc., dba. Holdr, 550 Burrard Street, Suite 2900, Vancouver, BC, V6C 0A3.

11. Complaints

If you have a complaint about our handling of your personal information, please contact us at support@holdr.com. If we cannot resolve your complaint, you may contact your relevant supervisory authority.

12. Third-Party Websites and Services

This privacy policy applies only to our Site and Services. This privacy policy does not extend to any websites or products or services provided by third parties. We do not assume responsibility for the privacy practices of such third parties, and we encourage you to review all third-party privacy policies prior to using third-party websites or products or services.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The latest version will always be available on our Site. Any changes will be effective immediately upon posting. Your continued use of the Site and Services after the changes take effect will constitute your acceptance of the revised policy.