Privacy Policy — Hirly Partners

This Privacy Policy explains how Holdcrest Inc. ("Hirly", "we", "us") collects, uses, and shares information when you use the Hirly Partner Portal (the "Portal"). By using the Portal you agree to the practices described here.

1. Information we collect

Account information — your name, email address, and password (hashed).
Onboarding information — company or personal details, address, country, phone, contract type, tax form details, and payment information you provide to complete onboarding.
Signed documents — tax forms and the Partner Agreement you sign inside the Portal, along with metadata such as timestamp and browser/IP for signature integrity.
Program activity — companies you introduce, protection windows, payments recorded against those companies, and commissions and payouts owed to you.
Technical data — device, browser, IP address, and basic usage information collected when you access the Portal.

2. How we use your information

To operate the partner program: review applications, snapshot commission terms, calculate commissions, and issue payouts.
To communicate with you about your account, program updates, and legal or tax notices.
To secure the Portal, prevent fraud, and comply with our legal obligations.
To improve the Portal by analyzing aggregated usage.

3. Legal bases (where applicable)

Where required by law (e.g. GDPR), we rely on: (a) performance of a contract with you; (b) our legitimate interests in operating and improving the Portal; (c) your consent for optional processing; and (d) compliance with legal obligations.

4. Sharing

We share information only with:

Service providers we use to run the Portal (hosting, authentication, email delivery), under confidentiality obligations.
Professional advisors, auditors, or tax authorities, where required.
A successor entity in the case of a merger, acquisition, or asset sale.
Anyone else, with your consent.

We do not sell your personal information.

5. Cookies

The Portal uses strictly necessary cookies and local storage to keep you signed in and to remember your preferences. We do not use advertising cookies.

6. Data retention

We retain your information for as long as your account is active and for a reasonable period afterward to comply with tax, accounting, and legal requirements. Signed documents are retained for the duration required by applicable law.

7. Security

We use reasonable technical and organizational measures to protect your information, including encryption in transit and role-based access controls. No system is perfectly secure, so we cannot guarantee absolute security.

8. Your rights

Depending on where you live, you may have the right to access, correct, delete, or export your personal information, or to object to or restrict certain processing. Contact us at privacy@hirly.com to exercise these rights.

9. International transfers

Your information may be processed in countries other than your own. Where required, we implement appropriate safeguards for international transfers.

10. Children

The Portal is not directed at children under 16, and we do not knowingly collect their information.

11. Changes to this Policy

We will notify you of material changes to this Policy through the Portal or by email.

12. Contact

Questions about privacy? Contact privacy@hirly.com.