Privacy Policy

1. Introduction and Scope

Holy Space, a computer systems design firm headquartered at Laixi, Qingdao — 266000, China (CN), is committed to protecting the privacy and security of all individuals who interact with our services. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website at https://www.holyspace.surf or engage with our computer systems design, infrastructure architecture, network engineering, cloud solutions, and cybersecurity consulting services.

This policy applies to all users of our website, clients who engage our engineering services, prospective clients who submit inquiries, and any other individuals whose personal data we may process in the course of our business operations. By using our website or services, you acknowledge that you have read and understood the practices described in this Privacy Policy.

Holy Space acts as a data controller for the personal information we collect directly from you. For certain processing activities related to client projects, we may act as a data processor on behalf of our clients. In such cases, the client's privacy policy governs the processing of that data.

The website and all associated systems are designed and maintained by Holy Space as the sole developer and operator of this digital infrastructure. Every component of this site, from its architecture to its security posture, reflects our engineering standards for privacy protection.

2. Information We Collect

We collect several categories of information to provide and improve our computer systems design services. The types of data we gather depend on how you interact with Holy Space and which services you utilize.

Personal Identification Information: When you contact us through our website forms, email, or telephone, we may collect your full name, email address, phone number, company name, job title, and physical address. This information is necessary for us to respond to your inquiries, prepare project proposals, and establish a client relationship.

Technical and Usage Data: When you access our website, our servers automatically collect certain technical information including your Internet Protocol (IP) address, browser type and version, operating system, device type, referral source, pages visited, time and date of visit, time spent on pages, and other diagnostic data. This information helps us maintain the security and performance of our systems.

Communication Data: We retain records of correspondence when you contact us via email at biz@holyspace.surf, through our contact forms, or by phone at +19208768522. This includes the content of your messages, attachments, and our responses.

Project-Related Data: For clients who engage our services, we may collect and process technical specifications, system configurations, network diagrams, infrastructure documentation, and other materials necessary to perform our systems design and engineering work.

Analytics Data: We use privacy-respecting analytics to understand how visitors interact with our website. This data is aggregated and anonymized wherever possible and does not include personally identifiable information unless you have voluntarily provided it through a form submission.

3. How We Collect Information

Holy Space collects information through various methods, each designed to be transparent and purposeful:

Direct Collection: Most personal data we hold is provided directly by you when you fill out our contact form, send us an email, call our office, or engage our services. You are in control of what information you share with us during these interactions.

Automatic Collection: As you navigate our website, certain information is collected automatically through standard web server logs and security monitoring systems. This passive collection is essential for maintaining the operational integrity and security of our platform.

Client Engagement Collection: During the course of our systems design projects, we receive technical data from our clients necessary to perform our engineering services. This may include access credentials, system logs, configuration files, and network topology information.

Third-Party Sources: In limited circumstances, we may receive information about you from third-party service providers, publicly available databases, or business partners. Any such information is handled with the same care as directly collected data.

We do not use any automated decision-making or profiling systems that would produce legal effects concerning you. All significant decisions related to our services involve human engineering judgment.

4. Purpose of Data Processing

Holy Space processes collected information for specific, legitimate purposes directly related to our computer systems design business:

Service Delivery: To provide, maintain, and improve our infrastructure architecture, network engineering, cloud solutions, cybersecurity, database design, and systems integration services. This includes communicating with you about your projects, delivering technical documentation, and providing ongoing support.

Communication: To respond to your inquiries, send you information you have requested, provide project updates, and notify you about changes to our services or policies.

Website Operation: To monitor and analyze usage patterns, detect and prevent security incidents, debug technical issues, and optimize the performance and user experience of our website.

Legal Compliance: To comply with applicable laws, regulations, legal processes, and enforceable governmental requests. This includes maintaining records as required by Chinese law and international regulations applicable to our operations.

Business Operations: To manage our client relationships, process payments, conduct internal audits, and improve our operational efficiency and service quality.

Marketing: With your consent where required, to send you information about our services, industry insights, and relevant updates. You may opt out of marketing communications at any time.

We do not sell, rent, or trade your personal information to third parties for their marketing purposes. Holy Space is an engineering firm, not a data broker.

5. Legal Basis for Processing

The legal basis upon which Holy Space processes your personal data depends on the specific context and purpose of the processing activity:

Contractual Necessity: When you engage our services, processing your data is necessary to perform the contract we have entered into with you, including preparing proposals, delivering services, and managing billing.

Legitimate Interests: We process certain data based on our legitimate business interests, which include improving our services, ensuring network and information security, preventing fraud, and communicating with clients about relevant offerings. We carefully balance these interests against your data protection rights.

Consent: Where required by applicable law, we obtain your explicit consent before processing your data for specific purposes, such as sending marketing communications or placing non-essential cookies on your device.

Legal Obligation: We may process your data to comply with legal obligations, such as tax reporting requirements, responding to lawful requests from public authorities, or maintaining records as mandated by Chinese law and applicable international regulations.

If you have questions about the specific legal basis applicable to your data, please contact us using the details provided in Section 15 of this policy.

6. Data Storage and Security

Holy Space implements comprehensive technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. As a computer systems design firm, security is foundational to everything we build.

Technical Safeguards: We employ industry-standard encryption for data in transit (TLS 1.3) and at rest (AES-256), network segmentation, intrusion detection and prevention systems, regular vulnerability assessments, multi-factor authentication for administrative access, and comprehensive logging and monitoring.

Organizational Measures: Access to personal data is restricted to authorized personnel who require it to perform their job functions. All staff undergo privacy and security training. We maintain documented security policies and incident response procedures that are regularly reviewed and updated.

Data Location: Our primary data storage and processing infrastructure is located in secure facilities. For certain services, data may be processed in other jurisdictions as described in the International Data Transfers section below.

Breach Notification: In the unlikely event of a data breach involving your personal information, we will notify you and relevant authorities as required by applicable law, without undue delay.

While we strive to protect your data, no method of electronic storage or transmission over the Internet is absolutely secure. We continuously evaluate and enhance our security posture to address evolving threats.

7. Data Sharing and Disclosure

Holy Space does not sell, trade, or rent personal information. We share data only in the following limited circumstances:

Service Providers: We engage trusted third-party companies to perform functions on our behalf, such as hosting infrastructure, email delivery, analytics, and payment processing. These providers are contractually bound to process data only according to our instructions and to maintain confidentiality and security standards at least as stringent as our own.

Professional Advisors: We may share information with our legal, accounting, and audit professionals as necessary for the operation of our business and compliance with legal obligations.

Legal Requirements: We may disclose information if required to do so by law, regulation, court order, or other legal process, or if we believe in good faith that such disclosure is necessary to protect our rights, your safety, or the safety of others.

Business Transfers: In the event of a merger, acquisition, reorganization, or sale of all or a portion of our assets, your information may be transferred as part of that transaction. You will be notified of any such change in ownership or control of your personal data.

With Your Consent: We may share your information for other purposes with your explicit consent or at your direction.

All third parties that receive personal data from Holy Space are carefully vetted and are required to enter into data processing agreements that ensure compliance with applicable data protection laws.

8. Cookies and Tracking Technologies

Holy Space uses cookies and similar tracking technologies to enhance your browsing experience and collect usage analytics. By using our website, you consent to the use of cookies as described in this section.

Essential Cookies: These cookies are necessary for the basic functioning of our website. They enable core features such as security, network management, and accessibility. Our website cannot function properly without these cookies, and they do not require your consent under most privacy regulations.

Analytics Cookies: We use analytics cookies to understand how visitors interact with our website, which pages are most frequently visited, and how users navigate through our content. This information helps us improve our website design and content strategy. The data collected is aggregated and anonymized.

Functional Cookies: These cookies remember your preferences and choices to provide a more personalized experience. For example, they may remember your language preference or form submission preferences.

Third-Party Cookies: Some of our pages may contain embedded content or integrate with third-party services that set their own cookies. We do not control these third-party cookies, and we encourage you to review the privacy policies of these services.

Managing Cookies: Most web browsers allow you to control cookie settings through their preferences. You can set your browser to refuse cookies, delete existing cookies, or alert you when cookies are being sent. Please note that disabling cookies may affect the functionality of our website.

9. Third-Party Services and Integrations

Our website and services may integrate with or link to third-party platforms, services, and websites. These third parties have their own privacy policies that govern their handling of your information.

Hosting Infrastructure: Our website is hosted on cloud infrastructure provided by reputable hosting providers. These providers maintain their own security certifications and compliance programs. Data processed on their infrastructure is protected according to their stated security commitments.

Email Services: We use third-party email services to send and receive communications. Emails transmitted through these services are subject to the provider's privacy and security practices.

External Links: Our website may contain links to external sites that are not operated by Holy Space. We have no control over the content, privacy policies, or practices of these third-party sites and strongly encourage you to review their privacy policies before providing any personal information.

Holy Space is not responsible for the privacy practices of third-party services. We recommend that you review the privacy policies of any third-party services you interact with through our platform.

10. Data Retention Policy

Holy Space retains personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law.

Client Data: Information related to client engagements is retained for the duration of the client relationship plus an additional period as required by legal, regulatory, and contractual obligations. Typically, project records are maintained for a minimum of five years following project completion, in accordance with standard business practices and Chinese commercial law.

Inquiry Data: Information from prospective clients who have submitted inquiries but have not engaged our services is retained for up to twelve months, after which it is deleted unless a client relationship is established.

Website Analytics: Aggregated and anonymized analytics data may be retained indefinitely for trend analysis. Raw log data containing IP addresses is retained for a maximum of ninety days for security monitoring purposes.

Communication Records: Email correspondence and other communications are retained for the duration of the client relationship plus two years, unless a longer retention period is required for legal or regulatory purposes.

Deletion: When personal data is no longer needed, we securely delete or anonymize it using methods appropriate to the sensitivity of the data. Physical records are shredded; digital records are overwritten or cryptographically erased.

11. Your Data Protection Rights

Depending on your jurisdiction, you may have the following rights regarding your personal data:

Right of Access: You have the right to request a copy of the personal data we hold about you and to receive information about how we process it.

Right to Rectification: You have the right to request that we correct any inaccurate or incomplete personal data we hold about you without undue delay.

Right to Erasure: In certain circumstances, you have the right to request that we delete your personal data. This is also known as the right to be forgotten.

Right to Restriction: You have the right to request that we restrict the processing of your personal data in specific situations, such as while we verify the accuracy of disputed data.

Right to Data Portability: Where processing is based on consent or contract and carried out by automated means, you have the right to receive your personal data in a structured, commonly used, and machine-readable format.

Right to Object: You have the right to object to processing based on legitimate interests, including profiling. You also have an absolute right to object to direct marketing at any time.

Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

To exercise any of these rights, please contact us using the details provided in Section 15. We will respond to your request within the timeframe required by applicable law, typically within thirty days. We may need to verify your identity before processing your request.

If you believe that our processing of your personal data infringes applicable data protection laws, you have the right to lodge a complaint with a supervisory authority in your jurisdiction.

12. Children's Privacy

Holy Space's services and website are not directed to individuals under the age of 16. We do not knowingly collect, use, or disclose personal information from children under 16 years of age.

If we become aware that we have inadvertently collected personal data from a child under 16 without verifiable parental consent, we will take immediate steps to delete such information from our records. If you believe that we might have information from or about a child under 16, please contact us immediately using the details provided in Section 15.

Our computer systems design services are intended for businesses and professional organizations. We do not market our engineering services to minors, and our client engagements typically involve corporate entities rather than individual consumers.

Parents and guardians who have concerns about their children's privacy in relation to our website are encouraged to contact us. We take the protection of minors' privacy very seriously.

13. International Data Transfers

Holy Space is headquartered in Laixi, Qingdao, China (CN), and our primary data processing activities occur within China. However, as we serve international clients and utilize global technology infrastructure, your personal data may be transferred to, stored, and processed in countries outside your country of residence.

Transfer Safeguards: When we transfer personal data across international borders, we implement appropriate safeguards in accordance with applicable data protection laws. These safeguards may include standard contractual clauses approved by relevant regulatory authorities, adequacy decisions, binding corporate rules, or certifications under approved frameworks.

China-Specific Provisions: For data subjects in China, we comply with the Personal Information Protection Law (PIPL) of the People's Republic of China regarding cross-border data transfers. Personal information collected within China is stored and processed primarily on servers located in China.

Your Consent: By using our website and services, you acknowledge that your information may be transferred internationally as described in this policy. If you have questions about the specific safeguards applicable to your data, please contact us.

14. Changes to This Privacy Policy

Holy Space reserves the right to update or modify this Privacy Policy at any time to reflect changes in our practices, technology, legal requirements, or operational needs. When we make material changes, we will take reasonable steps to notify you.

Notification Methods: We will post the updated Privacy Policy on this page with a revised Last Updated date. For material changes, we may also provide notice through our website homepage, by email to clients who have provided their email address, or through other reasonable means.

Review Responsibility: We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information. Your continued use of our website or services after any changes to this Privacy Policy constitutes your acceptance of the updated terms.

Historical Versions: Previous versions of this Privacy Policy are available upon request. If you would like to review a prior version, please contact us using the details provided in Section 15.

15. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our data protection practices, please contact us through any of the following channels:

We take all privacy inquiries seriously and will respond to your message promptly. Our data protection team is available during regular business hours to address any concerns you may have about how your personal information is handled.

This website and its privacy infrastructure are designed, developed, and maintained by Holy Space. As both the service provider and the developer, we take full responsibility for the data protection measures implemented across our digital presence.

If you are a client with an active engagement, you may also contact your designated project manager for privacy-related inquiries. They will coordinate with our data protection team to address your concerns expediently.