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Privacy Policy

Last updated 12 May 2026

HOOLAN LTD (‘Hoolan’, 'we', 'us', or 'our') is committed to protecting your privacy and we take the issue of security of your personal information very seriously. This privacy policy describes how and why we might collect, store, use, and/or share ('process') your information when you use our services ('Services'), such as when you:
 

  • Use our website www.hoolan.app

  • Download and use our mobile and smartwatch applications

  • Engage with us in other related ways, including any sales, marketing, or events
     

This privacy policy does not apply to any third-party websites, products or services that you may link to, or interact with, whilst using our Services.


Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at contact@hoolan.app.

Your Data Stays Yours 


At Hoolan, your wind and watersports sessions, performance stats, health data and location data are yours. We only use this information to power the app experience - tracking your sessions, generating insights, and helping you improve in your sport.


Hoolan is completely free to use, and we do not make money by selling your data. 

 

That means:

  • We do not sell your personal data

  • We do not share your data with advertising companies

  • We do not use ad networks or third-party profiling

  • We do not track you across other apps or websites

  • We do not monetize your riding sessions, GPS tracks, or performance statistics
     

Your data is only used to provide the Hoolan experience - such as tracking sessions, generating statistics, syncing with your watch, and improving app performance. 

 

Our goal is to create the best tracking experience for kitesurfers, wing foilers and windsurfers - not to exploit user data.

How Hoolan Is Funded

Hoolan is currently funded by its founders while we continue building the platform and growing the community.

 

Hoolan is also supported by community donations, which help us cover infrastructure costs and continue improving the service for everyone.

SUMMARY OF KEY POINTS

 

COLLECTION OF INFORMATION:

How do we process personal information? 

Hoolan processes your personal information for the purposes of providing, improving, and administering our Services, to communicate with you, for security and fraud prevention, and to comply with law. We process your information only when we have a valid legal reason to do so.
Learn more
 

Do we process any sensitive personal information?
Yes - but only with your explicit consent. Health data is used solely to provide features such as heart rate and calorie tracking.
Learn more

 

Do we process your location data?
Yes - only while using the app and only with your consent. Location tracking is essential to provide session tracking and statistics.
Learn more


Do we collect technical information?
Yes. We collect limited technical and analytics information to improve reliability, security, functionality, and performance.
Learn more

 

Do we use Cookies?

Yes. Cookies help improve your experience and allow us to understand how our Services are used. You can control cookies through your browser settings.
Learn more

 

Do we track how you use other websites or applications?
No

 

Do we use your personal information for marketing communications?

Yes - but only if you have opted in or signed up to the Hoolan app and accepted our Terms & Conditions. You can unsubscribe at any time.
Learn more

​SHARING YOUR INFORMATION:

Do we sell your personal information? 
No. Never

 

Do we share your personal information with third parties? 
Only where necessary to operate the Services, such as secure cloud hosting, authentication, analytics, or infrastructure providers.
Learn more

​CONTROL OF DATA:

 

Do we only hold your data for as long as necessary to perform our services?
Yes.
Learn more

 

Do we keep your information safe? 
Yes, we have organisational and technical processes and procedures in place to protect your personal information.
Learn more

 

Can you request access, correction, or deletion of your data?
Yes. Please email contact@hoolan.app and we will action your request within 30 days.

 

Will we notify you of important policy changes?
Yes, we will notify you by email and publish it on our website and mobile app.

Learn more

Health Data

1. WHAT INFORMATION DO WE PROCESS?

 

Personal information You Disclose to Us:

We collect personal information that you voluntarily provide to us when you create a Hoolan account and set up your profile, when you use our Services, when you respond to our communications, or otherwise when you contact us. This includes:

 

  • Account data. In order to use our Services, we require you to sign up and create a Hoolan account where you provide us with your name, username and email address.

  • Profile data & kit data. To be able to fully benefit from the Services, you can choose to add profile information, such as profile pictures, profile intro, home spot, gender, nationality and date of birth, as well as kit information such as the category, size and brand of sports equipment you use.

  • User generated data. For example, photos and notes from your session, questions, messages and any other content or information that you generate, transmit, or otherwise make available on the Service.
     

  • Social & connection data. If you choose to use Hoolan’s social features, such as following other users or accepting follow requests, we process information relating to those connections. This may include your followers, users you follow, shared profile information, shared sessions, activity feed interactions and connection requests. Depending on your privacy settings, your profile information and sessions may be visible to other users of the Service.

  • Social media data. We have pages on social media sites like Facebook, Instagram, and Twitter. The companies that host our Social Media Pages may also provide us with aggregate information and analytics regarding the use of our Social Media Pages.

  • Surveys, competitions, giveaways. Any information that you submit in relation to any surveys, competitions, giveaways or other promotions that we may run, will be treated in accordance with the terms of this Privacy Policy, except if expressly noted in the rules.

Health Data

Only with your explicit consent will we process health-related information.
This may include:

  • Heart rate

  • Calories burned

This information is used solely to provide activity tracking features and is never used for advertising or sold to third parties.

 

Activity Data

We process your activity data and store it in your user account. This includes data such as speed, date and time of session, duration, distance, GPS location and movement data such as jump height, jump distance, airtime, rotations and G-force on landing.

Session Visibility & Sharing
You can control who can view your sessions using your privacy settings within the Hoolan App. Depending on your selected settings, your sessions may be visible to:

  • Only you

  • Users who follow you

  • All users of the Service (if your profile is set to Public) 

You may also choose to change the visibility of individual sessions at any time.

 

Location Data

We process your location data only:

  • With your consent

  • While actively using the Hoolan App

Location tracking is required to provide session tracking and statistics.

You may disable location permissions at any time through your device settings, although some features may stop functioning correctly.

Anonymous Aggregated Data

We may aggregate anonymous usage and activity data to:

  • Improve the Services

  • Understand trends

  • Develop features

  • Support business analysis

  • Improve marketing effectiveness

This data does not identify individual users.

 

Technical Information

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes. The information we collect includes:

  • Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. This log data includes your IP address (so we can understand which country you are connecting from), device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps'), and hardware settings).

  • Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

Cookies

We use cookies and similar technologies to:

  • Keep users signed in

  • Improve functionality

  • Analyse usage Improve the user experience

You may disable cookies through your browser settings, although some features may not function correctly.

Location Data
Technical Data
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Cookies
How we process information

2. HOW DO WE PROCESS YOUR INFORMATION?

 

We process your personal information for a variety of reasons, including:

  • To process account creation and authentication and otherwise manage user accounts. 

  • To provide our Services, for example enabling you to track your activities and analyse your performance.
     

  • To provide social and community features. This includes allowing users to follow each other, view shared sessions and profiles, and interact with activity feeds in accordance with individual privacy settings.

    Depending on your privacy settings, this may include visibility of:
    - Your profile information
    - Your sessions and activity data
    - Your followers and following connections
    - Photos, notes and other content you choose to share

    By default, your profile and sessions are not publicly visible. You can manage who can view your profile and sessions at any time within the Hoolan App.

    If you choose to make your profile Public, your profile information and sessions may be visible to any user of the Service, and other users may be able to follow you without sending a follow request.

    Your health data is never visible to other users.

     

  • To respond to your enquiries, support requests and comments.

  • To send administrative information to you. We may process your information to send you details about our products and services, important company news, changes to our terms and policies, and other similar information.

  • To market and promote our Services and activities.  This includes marketing communications (if you opt in or have signed up to our app and have accepted our T&Cs) and push notifications (if you consent).​

  • To improve and protect our Services – analysis of the data we collect helps us to improve and develop our service, and quickly detect crashes and bugs so that we can fix them.

  • To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

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3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law.

If you are located in the EU or UK, this section applies to you:

 

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

  • Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.

  • Performance of a Contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services. For example we can’t provide the Service unless we collect and use your location data.

  • Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

  • Vital Interests. We may process your information where we believe it is necessary to protect your vital interests, the vital interests of a third party, such as situations involving potential threats to the safety of any person, or our commercial interests in ensuring the sustainability of the Services.

  • Legitimate Interests. We may process your data where it is necessary for the purposes of our legitimate interest, and where it does not unduly impact your rights and freedoms. For example, to analyse our marketing activities or to conduct internal testing or reporting to improve our products and services.

 

Under European data protection laws, Hoolan is the 'data controller' of the personal information described in this privacy notice, since we determine the means and/or purposes of the data processing we perform. 

 

 

If you are located in Canada, this section applies to you:

 

We may process your information if you have given us specific permission (i.e. express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e. implied consent). You can withdraw your consent at any time.  In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

  • If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way.

  • For investigations and fraud detection and prevention.

  • For business transactions provided certain conditions are met.

  • If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim.

  • For identifying injured, ill, or deceased persons and communicating with next of kin.

  • If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse.

  • If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province.

  • If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records.

  • If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced.

  • If the collection is solely for journalistic, artistic, or literary purposes.

  • If the information is publicly available and is specified by the regulations.
     

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4. WHAT INFORMATION DO WE SHARE?

PERSONAL INFORMATION
 

We do not sell or share your personal information with advertisers or data brokers.

 

We may share limited personal information with trusted service providers where necessary to operate the Services, including:

  • Cloud hosting providers

  • Authentication providers

  • Analytics providers

  • Infrastructure providers

  • Communication and collaboration tools

  • Data storage providers

 

These providers are contractually required to protect your information and may only use it to provide services on our behalf.

 

Business Transfers
If Hoolan is involved in a merger, acquisition, financing, or sale of assets, your information may be transferred as part of that transaction. You acknowledge and consent that such transfers may occur and are permitted by this Privacy Policy, and that any acquirer of our assets may continue to process your Personal Information as set forth in this Privacy Statement.

Legal Requirements

We may disclose information where required to:

  • Comply with law or legal process

  • Prevent fraud or abuse

  • Protect users or public safety

  • Protect our legal rights.

5. HOW LONG DO WE KEEP YOUR INFORMATION?

We will only keep your personal information for as long as it is necessary for the purposes of providing the Services, unless a longer retention period is required or permitted by law. We delete all your personal information when you request for your account to be deleted and this process may take up to 30 days to fully complete.
​​

6. WHERE IS YOUR DATA HELD?

Hoolan is based in the United Kingdom. If you are accessing our Service from other regions with laws governing data collection and use, please note that your personal data will be transferred to and stored in the United Kingdom as necessary for the purposes described in this Privacy Policy.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

​We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
 

8. DO WE COLLECT INFORMATION FROM MINORS?

Whilst we do not specifically promote the Hoolan Services to minors, children aged 4-18 years are able to download and use Hoolan as long as Hoolan's terms and this Privacy Policy have been reviewed and agreed with a parent or guardian. By using the Services, you represent that your parent or guardian consents to your use of the Services.

9. WHAT ARE YOUR PRIVACY RIGHTS?

Marketing

In some regions (like the EEA, UK, Canada and California), particular rights are available to you under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by emailing dpo@hoolan.app.

 

We will consider and act upon any request in accordance with applicable data protection laws.

 

Requesting to view, update or delete the data we collect from you:
If you would at any time like to review or change the information in your account or terminate your account, please email us at dpo@hoolan.app. Hoolan will process your request within 30 days.

 

Upon your request to terminate your account, we will delete your account and data from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements. Please note we cannot delete any data that you may have publicly shared on social media channels.

 

Withdrawing your consent:

If we are relying on your consent to process your personal information, such as your location data or your health data, you have the right to withdraw your consent at any time. You can do this by emailing dpo@hoolan.app.

 

Please note, however, that this will not affect the lawfulness of the processing before its withdrawal, nor when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

 

Opting out of marketing and promotional communications:

When you subscribe to our newsletter on our website, or when you download the Hoolan App and accept our terms and conditions, you will start receiving Hoolan's marketing and promotional communications. You can unsubscribe from these at any time by clicking on the unsubscribe link in the emails that we send, or by emailing us at contact@hoolan.app. You will then be removed from the marketing lists. However, we may still communicate with you - for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. You may change your push notification settings at any time by accessing your Settings.

Managing your privacy settings:
You can control who can view your profile and sessions at any time within the Hoolan App by going to:

Profile > Settings > Preferences > Privacy Controls

By default, your profile and sessions are not publicly visible. If you do not send or accept follow requests, your profile and activity will remain private to you.

 

Removing or rejecting Cookies and similar technologies:

Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies or reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.

 

Complaints:

If you are located in the EEA or UK and have a serious complaint about the way we are processing your personal information, that cannot be resolved together with us, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

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10. CONTROLS FOR DO-NOT-TRACK FEATURES

Some browsers include Do-Not-Track (“DNT”) settings.

 

Because there is currently no universal standard for DNT signals, Hoolan does not currently respond to them.

 

If standards change in future, we may update this policy accordingly.

Donations

11. DONATIONS AND PAYMENT INFORMATION

When you make a donation to Hoolan via Donorbox, your payment is processed securely by third-party providers (such as Stripe or PayPal). We do not receive or store any of your sensitive payment information, such as credit card or bank details. ​

 

We may receive limited personal information from Donorbox (such as your name, email address, or message, if provided). This information is used only for:

  • Thanking you for your support

  • Tracking donations internally

  • Complying with legal and financial requirements

 

We do not use your information for marketing purposes unless you've explicitly opted in, and we never sell or share your data with third parties. See Donorbox's privacy policy.
 

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12. DO WE MAKE UPDATES TO THIS PRIVACY POLICY?

We may update this privacy notice from time to time. The updated version will be indicated by an updated 'Revised' date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we will notify you by prominently posting a notice of such changes and by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

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13. HOW CAN YOU CONTACT US?

If you have questions or comments about this Privacy Policy, you may contact our Data Protection Officer (DPO), Lucy Jackson, by email at contact@hoolan.app.

 

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