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Last updated on April 29, 2022

PRIVACY POLICY

This Privacy Policy details how Djaz Inc. and its affiliates (“Djaz”, “us,” “our,” or “we”) collect, use, store, or otherwise process personal information about customers and other individuals (collectively “you”) who access or use our websites, including djaz.io, our mobile applications, our web application, and/or any of our other websites, products, or services that link to this Privacy Policy (the “Services”). By using our Services, you understand that we will collect and use your personal information as described in this Privacy Policy.

If, after reviewing this Privacy Policy, you have any questions or concerns, please send us an email to team@djaz.io.

1. YOUR LOCATION

1.1 IF YOU ARE AN INDIVIDUAL LOCATED IN THE EUROPEAN ECONOMIC AREA OR THE UNITED KINGDOM: If you are located in the European Economic Area (“EEA”) or the United Kingdom (U.K.), this entire Privacy Policy applies to you. In addition, please see Additional Information for Individuals in the EEA and the U.K. below, which also applies to you and will inform you in detail about our legal bases for processing and which rights you have in connection with our processing of your personal information.

1.2 IF YOU ARE A RESIDENT OF NEVADA: If you are a resident of Nevada, this entire Privacy Policy applies to you. However, please see Notice for Nevada Consumers below, which will also apply to you.

2. COLLECTION OF PERSONAL INFORMATION

With respect to its collection and processing of personal information, Djaz acts as either a: (i) Data Controller - when it collects personal information on its own behalf and for its own commercial and business purposes, such as from Site visitors or to Customers, or; (ii) Data Processor - when it collects and processes personal information on behalf of its Customers in order to provide the Services.

2.1 Personal Information We Collect from You. You provide us with personal information about yourself when you visit the Site or use our Services. Information that we collect from you consists of:

  • First name;

  • Last name;

  • E-mail address;

  • Country.

In addition, if you send us an email or otherwise contact us, we will collect the personal information that you provide to us at that time.

If you use external authentication and authorization providers: Google, Microsoft and Yahoo (“Provider”), to access the Services, we may collect your Provider specific data, email address and required access or refresh tokens. How Provider uses your information is governed by Provider's privacy policy.

2.2 Payment Data. Djaz uses Stripe, Inc. (“Stripe”) as a billing service and payment gateway provider. We DO NOT store any payment related personal information on our side, including any part of card numbers, payment transactions and billing details. How Stripe uses your information is governed by Stripe's privacy policy.

2.3 Personal Information We Collect Automatically. We may automatically collect personal information from you and your devices when you use our Services, including when you visit our websites or apps without logging in.

2.3.1 Device, Usage Information, and Transactional Data. We collect personal information about how you use our Services and the devices (e.g., computers, mobile phones, tablets) you use to access our Services. This may include, but is not limited to, the following:

  • IP address.

  • Geolocation information may be obtained by us, or authorized third parties through your IP address.

  • Unique device identifiers and device attributes, such as operating system and browser type.

  • Usage data, such as web log data, referring and exit pages and URLs, platform type, domain names, landing pages, pages and content viewed and the order of those pages, the date(s) and time(s) you used our Services and other related information.

  • Transactional data, such as names and email addresses of parties to a transaction, subject line, history of actions that individuals take in connection with a transaction (e.g., review, sign, enable features) and personal information about those individuals or their devices, such as name, email address, IP address, and authentication methods.

2.3.2 Cookies and Related Technologies. We use cookies, which are text files containing small amounts of information that are downloaded on your device, or related technologies, such as local shared objects, to collect and/or store information.

We only use cookies that are necessary - or “essential” - for the Site to function and cannot be switched off in our systems (“Strictly Necessary Cookies”). They are mostly only set in response to actions made by you, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but if you do block them, some portions of the Site will not work. These cookies do not store any personally identifiable information.

3. USE OF PERSONAL INFORMATION

3.1 Purpose. In general, we may use your personal information to provide, fix, and improve our Services, develop new Services, and market our companies and their products and Services. Examples of how we use the personal information we process include, but are not limited to, the following:

  • Provide the Site and Services, including to collect payments.

  • Ensure that the Site and Services are operational and optimized for user experience.

  • Improve the content and general administration of the Site and Services.

  • Enhance Customer experience, including to provide customer support.

  • Detect, prevent and investigate fraud, illegal activities, unauthorized access to or use of our Services, security breaches or any other wrongful behavior/behavior.

  • Deliver content and tailored advertising, and generally market and advertise Services

  • Ensure compliance with mandatory retention requirements.

  • Provide you with notices regarding Services that you have purchased.

  • Provide you with notices regarding Services that you may wish to purchase in the future including, in some cases, to send you direct marketing communications regarding other services that we may think are of interest to you.

  • Respond to your queries and requests, or otherwise communicate directly with you.

  • Perform system maintenance and upgrades, and enable new features.

  • Understand how you access and use the Site and Services in order to provide technical functionality and/or develop new products and services.

  • Conduct statistical analyses and analytics based on usage and activity on the Site

  • Enforce our agreements with you if necessary.

  • Provide information to regulatory bodies when legally required, and only as outlined in this Privacy Policy.

3.2 Individuals located in the EEA and the U.K.,please see Additional Information for Individuals in the section EEA and the U.K. below for more information, including our legal bases for processing.

4. PERSONAL INFORMATION SHARING

We share your personal information under certain circumstances as further described below.

4.1 Third Parties and Service Providers. We share personal information with our third party agents, contractors, or service providers who are hired to perform services on our behalf or in order to assist with certain business purposes. These providers may operate or support certain functions of the Site and/or Services. Below is a list of categories of service providers that we may use to perform these functions (which are subject to change):

  • Analytics services

  • Customer support services

  • Billing services and payment gateway providers

  • Hosting and content delivery network services

  • Communication tools

  • Professional services (such as auditors, lawyers, consultants, accountants and insurers)

  • Customer Relationship Management (CRM) solutions

4.2 Affiliates. We may share your personal information with other companies under common ownership or control with Djaz, provided that these companies use your personal information as described in this Privacy Policy.

4.3 Other Djaz users. When you allow others to access, use, or edit content in your account, we share that content with them. For example, if you send an envelope to others for review or signature, we make the contents of the envelope available to them.

4.4 Legal Obligations and Security. Djaz may preserve or disclose your personal information in limited circumstances (other than as set forth in this Privacy Policy), including: (a) with your consent; (b) when we have a good faith belief it is required by law, such as pursuant to a valid subpoena, warrant, or other judicial or administrative order (as further explained below); (c) to protect the safety of any person; (d) to protect the safety or security of the Site and/or Services or to prevent spam, abuse, or other malicious activity of actors with respect to the Site and/or Services; or (e) to protect our rights or property and/or the rights or property of those who use the Site and/or Services.

If we are required to disclose personal information by law, such as pursuant to a subpoena, warrant, or other judicial or administrative order, we will use reasonable efforts to provide you with notice of this disclosure requirement, unless we are prohibited from doing so by statute, subpoena or court or administrative order. Our policy is to respond to requests that are properly issued by law enforcement within the United States or via mutual legal assistance mechanism (such as a treaty), and to object to requests that we do not believe were issued properly. However, if we receive information that provides us with a good faith belief that there is an exigent emergency involving the danger of death or serious physical injury to a person, we may provide information to law enforcement trying to prevent or mitigate the danger (if we have it), which will be determined on a case-by-case basis.

With respect to Services Data, Customers must review our Terms and Conditions, which address our retention and disclosure of information if required by law.

5. RETENTION OF PERSONAL INFORMATION

We keep your personal information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain personal information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws as set out in our data retention policy and information handling standards. Generally, this means we retain your personal information to comply with any retention or statutory limitations or for purposes of performing a contract with you. Where there are technical limitations that prevent deletion or anonymization, we safeguard personal information and limit active use of it.

6. CHILDREN'S PRIVACY

We do not knowingly collect any personal information directly from children under the legal age (18 years of age or older or otherwise of legal age in your resident jurisdiction) or such other age designated by applicable law (“minors”). If we discover we have received any personal information from a child under the legal age or minors in violation of this Policy, we will take reasonable steps to delete that information as quickly as possible. If you believe that we have any personal information from or about anyone under the legal age or minors, please contact us at team@djaz.io.

7. SOCIAL MEDIA

Djaz maintains an online presence on social media platforms (“Social Media Platforms”) such as Instagram, Twitter or Facebook, to provide information about our Services and communicate with users and/or visitors to those pages or accounts. When you interact or post to our account, we process your personal information.

8. HOW WE PROTECT PERSONAL INFORMATION

We use reasonably appropriate security measures designed to protect the security of personal information both online and offline. These measures vary based on the sensitivity of the information that we collect, process and store and the current state of technology. Please note, though, that no website or internet transmission is completely secure, so while we strive to protect your data, we cannot guarantee that unauthorized access, hacking, data loss or a data breach will never occur.

9. YOUR CHOICES

9.1 Use of Cookies and Automated Technologies on the Site. How you make choices about cookies and other tracking technologies depends on the type of cookie or tracking technology being used Some visitors in some locations may be required to opt-in to non-essential cookies.

9.2 Marketing Activities. If you are receiving promotional emails from us, you can choose to stop receiving those by following the unsubscribe/opt-out instructions in those emails. You can also contact us at team@djaz.io.

9.3 Accessing and Changing Your Information. To request access to, or to make changes to, data that we have collected from you via the Site or Services, please email us at team@djaz.io.

Individuals in the EEA and the U.K. have additional rights, as explained in the related section.

10. NOTICE TO NEVADA CONSUMERS

We do not sell your personal information within the scope of, and according to the defined meaning of a “sale” under, NRS 603A.

11. ADDITIONAL INFORMATION FOR INDIVIDUALS IN THE EEA AND THE U.K.

For purposes of this section, “personal information” has the same meaning as “personal data” as such a term is defined in applicable data protection laws.

11.1 Categories of Recipients of Personal Information. The categories of recipients of personal information with whom we may share your personal information are listed in section Personal Information Sharing.

11.2 Purposes of Processing and Legal Bases. As a Data Controller, Djaz processes your personal information for a number of different purposes. Some are essential for us to provide the Services or to fulfill our legal obligations, some help us run the Services efficiently and effectively, and some enable us to provide you with more relevant and personalized offers and information. In all cases, with respect to individuals in the EEA, we must have a reason and a lawful basis for processing your personal information. The most common legal grounds on which we rely are briefly explained below:

  • Performance of a Contract: we may process your personal information in order to enter into, or perform a contract to which you are a party - for instance, when a Customer signs up for the Services.

  • Legitimate Interests: we may process personal information where it is necessary for our legitimate business interests, but only to the extent that they are not outweighed by your own interests or fundamental rights and freedoms. When we rely on this legal basis, if required, we will carry out a legitimate interest assessment to ensure we consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws.

  • Consent: We rely on consent where it is required, such as when we are asking you to confirm your marketing preferences. When we rely on consent, you will be asked to confirm that you give your permission to Djaz to process your personal information. You have the right to withdraw your consent at any time if you no longer want to be part of the Djaz processing activity where your consent was sought.

  • Legal Obligation: Djaz may have legal obligations to retain and/or disclose your personal information, or may cooperate in a legal or governmental investigation. It is essential that Djaz complies with its legal, regulatory, and contractual requirements, so if you object to this processing, Djaz will not be able to provide its Services to you.

The following breakdown illustrates in more detail our processing activities and how the above legal bases for processing apply (in brackets):

  • Provide the Services, including to collect payment [Legal Basis: Performance of a Contract]

  • Provide the Site [Legal Basis: Legitimate Interests]

  • Ensure that the Site and Services are operational and optimized for user experience [Legal Basis: Legitimate Interests or Performance of a Contract, depending on the specific use]

  • Improve the content and general administration of the Site and Services [Legal Basis: Legitimate Interests]

  • Enhance user experience, including to provide you with customer support [Legal Basis: Legitimate Interests]

  • Detect, prevent and investigate fraud, illegal activities, unauthorized access to or use of our Services, security breaches or any other wrongful behavior [Legal Basis: Legitimate Interests]

  • Deliver content and tailored advertising, and generally market and advertise Services [Legal Basis: Legitimate Interests or Consent, depending on the specific circumstances]

  • Ensure compliance with mandatory retention requirements [Legal Basis: Compliance with a Legal Obligations]

  • Provide you with notices regarding Services that you have purchased [Legal Basis: Performance of a Contract]

  • Providing you information about Services that you may wish to purchase in the future including, in some cases, to send you direct marketing communications regarding other services that we may think are of interest to you [Legal Basis: Legitimate Interests]

  • Respond to your queries and requests, or otherwise communicate directly with you [Legal Basis: Legitimate Interests or Performance of a Contract, depending on the specific use]

  • Perform system maintenance and upgrades, and enable new features [Legal Basis: Legitimate Interests]

  • Understand how you access and use the Site and Services in order to provide technical functionality and/or develop new products and services [Legal Basis: Legitimate Interests]

  • Conduct statistical analyses and analytics based on usage and activity on the Site [Legal Basis: Legitimate Interests or Consent, depending on the specific circumstances]

  • Enforce our agreements with you if necessary [Legal Basis: Legitimate Interests]

  • Provide information to regulatory bodies when legally required, and only as outlined in this Privacy Policy [Legal Basis: Compliance with a Legal Obligations]

11.3 How Long Do We Keep Your Personal Information? We use the following criteria to determine our retention periods: the amount, nature and sensitivity of your information, the reasons for which we collect and process your personal information, how long we have an ongoing relationship with you and provide you with access to our Services, and applicable legal requirements. We will retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to comply with applicable legal, tax, or accounting requirements), when we are unable to reasonably verify your identity, or as may otherwise be required under GDPR. Additionally, we cannot delete information when it is needed for the establishment, exercise, or defense of legal claims (also known as a “litigation hold”). In this case, the information must be retained as long as needed for exercising respective potential legal claims.

When we have no ongoing business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), we will securely store your personal information and isolate it from any further processing until deletion is possible. If you have questions about, or need further information concerning, our data retention periods, please email team@djaz.io.

Note that with respect to Services Data, our retention periods may vary as set forth in the Terms and Conditions.

11.4 Staying in Control of Your Information: Your Rights. WITH RESPECT TO SERVICES DATA OR IF YOU ARE A CONTACT, YOU MUST EXERCISE YOUR DATA SUBJECT RIGHTS REQUESTS WITH THE CUSTOMER(S) (ACTING AS 'DATA CONTROLLER') ON BEHALF OF WHICH DJAZ PROVIDES THE SERVICES AND COLLECTS SERVICES DATA, AS EXPLAINED IN SECTION COLLECTION OF PERSONAL INFORMATION. IF WE RECEIVE SUCH REQUESTS, WE WILL SEND THOSE REQUESTS TO THE RELEVANT CUSTOMER, WHO WILL BE RESPONSIBLE FOR RESPONDING TO AND ADDRESSING RIGHTS REQUESTS, WITH OUR COOPERATION.

If the GDPR (or its equivalent in the U.K.) applies to you because you are in the EEA or the U.K., you have certain rights in relation to your personal information:

  • The right to be informed - our obligation to inform you that we process your personal information (and that is what we are doing in this Privacy Notice)

  • The right of access - your right to request a copy of the personal information we hold about you (also known as a 'data subject access request')

  • The right to rectification - your right to request that we correct personal information about you if it is incomplete or inaccurate (though we generally recommend first making any changes in your Account Settings)

  • The right to erasure (also known as the 'right to be forgotten') - under certain circumstances, you may ask us to delete the personal information we have about you (unless there is an overriding legal reason we need to keep it)

  • The right to restrict processing - your right, under certain circumstances, to ask us to suspend our processing of your personal information

  • The right to data portability - your right to ask us for a copy of your personal information in a common format (for example, a .csv file)

  • The right to object - your right to object to us processing your personal information (for example, if you object to us processing your data for direct marketing)

  • Rights in relation to automated decision-making and profiling - our obligation to be transparent about any profiling we do, or any automated decision-making.

  • The right to withdraw your consent where you had previously given consent.

These rights are subject to certain rules around when you can exercise them. If you are located in the EEA and wish to exercise any of the rights set out above, please contact us team@djaz.io.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights) unless your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request under those circumstances.

We may need to request specific information from you to help us confirm your identity. This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. Note that if we are unable to reasonably confirm your identity, we will not be able to honor certain requests.

We will respond to all legitimate requests within one month. Occasionally, it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated as required by law.

In addition, if you no longer wish to receive our marketing/promotional information, we remind you that you may withdraw your consent to direct marketing at any time directly from the unsubscribe link included in each electronic marketing message we send to you. If you do so, we will promptly update our databases, and will take all reasonable steps to meet your request at the earliest possible opportunity, but we may continue to contact you to the extent necessary for the purposes of providing our Services.

Finally, you have the right to make a complaint at any time to the supervisory authority for data protection issues in your country of residence. We would, however, appreciate the chance to address your concerns before you approach the supervisory authority, so please contact us directly first.

12. HOW TO CONTACT US

For questions or complaints regarding our use of your personal information or this Policy, please contact us at team@djaz.io or by sending a letter to Djaz Inc., Attention: Privacy Team, 770 Cordial Drive Des Plaines, IL 60018 US.