Effective March. 1st, 2021.
Hello and thank you for using a Jalalio Web Property!
Jalalio Digital Marketing, and its affiliates ("we", "us", "our"), a division of Cisery Inc. ("we", "us", "our") knows that you value your privacy; earning and maintaining your trust is paramout to us. We offer innovative products and services that enable businesses and government institutions to leverage state-of-the-art tooling for the lifecycle management of their operational data.
- "Customer": end users of our Products and Services deployed and operated by either a Tenant or a Partner.
- "Do Not Track": is a privacy preference that users can set in their web browsers. When a user turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the user.
- "Partner": individuals, people and companies that provide to us resources and offerings that we integrate in our Products and Services; or that distribute or integrate or operate our Products and Services into their own value propositions.
- "Personal Data": any factual or subjective information, recorded or not, about an identifiable individual.
- Including age, name, ID numbers, income, ethnic origin, blood type, opinions, evaluations, comments, social status, disciplinary actions, employee files, credit records, loan records, medical records, existence of a dispute between a consumer and a merchant, intentions (for example, to acquire goods or services, or change jobs).
- Information about Tenants who are sole proprietors or Partners is considered to be "Personal Data" if it is information about the individuals themselves, as distinct from information about their businesses.
- Personal Data do not include de-identified or aggregated information that cannot reasonably be linked to a specific individual.
- Personal Data do not include the name, title or business address (including business email address) or business telephone of an employee of an organization
- "Products": our self-service kioks, our digitizing equipment, our scanners, our IoT devices and our software packages.
- "Services": our software-as-a-service products, our consulting services or our licensed software deployments.
- "Tenant": an individual who uses, or applies to use, one or more of our Products and Services.
- "You": may be a visitor to one of our websites, a Customer, a Tenant, or a Partner.
Personal Data that we process when you use our Sites, Products and Services
We obtain Personal Data about you from various sources to operate our Products, to provide our Services and to manage our Sites.
The Personal Data that you provide directly to us while using our Sites, Products or Services normally occur when:
- You register for an account, we collect:
- You are a Tenant; in order to set up your account with us you will provide your contact details, such as your full name, email address, domain name, postal address and telephone numbers.
- You are a Customer of a Tenant or Partner; when you conduct transactions through their Website we will receive your transaction information. Depending on how the Tenant or the Partner implements our Products or Services, we may receive this information directly from you, or from the Tenant, Partner or third parties including your name, email, billing or shipping address and log-in credential information. Your agreement with the relevant Tenant or Partner should explain how the Tenant or Partner shares your Personal Data with us. If you have questions about this sharing, please direct those questions to the Tenant or Partner.
- You fill-in our online forms to contact our sales team or technical support team; we collect your full name, email, country, and anything else you tell us about your interests and needs.
- You use the "Remember Me" feature of Log In forms.
- You submit content and information while using the Sites, Products or the Services.
- You respond to emails sent by us or surveys; we collect your email address, name and any other information you choose to include in the body of your email or responses. If you contact us by phone, we will collect the phone number you use to call us. If you contact us by phone as a Tenant, we may collect additional information in order to verify your identity.
- Location information, including location information provided by a device interacting with one of our sites or applications or associated with your IP address.
Personal Data collected when a Session is active
When you log-in on our Services we collect:
- Your device identifiers, including your IP address, iOS Identifier for Advertising (IDFA), Android Advertising ID, and our own-service specific identifier.
- Your precise geo-location, when location services have been enabled for your Browser or an app on your device. Note that when location services have not been enabled we will still infer data about your location based on other information, including your IP address.
- Information that a Service Provider has collected about you and/or shared with us, including demographic information (e.g., your age or gender) or information about your interests, to help make the ads served to you more relevant.
- Information about your device, including the type and model, manufacturer, operating system (e.g., iOS or Android), carrier name, Browser (e.g., Chrome, Safari), and screen size.
- Information about your usage of the Services, the start/stop time of your session, your current time zone, and your network connection type (e.g., WiFi, cellular).
- Information about ads served, viewed, or clicked on, including the type of ad, where the ad was served, whether you clicked on it, and whether you visited the advertiser’s website or downloaded the advertiser’s app.
Offline or non-Website sources
We may also collect information by offline or non-Website sources, for example when:
- Interacting with our social media accounts;
- Interacting with marketing campaign activities;
- While exploring or exercising a business relationship with us;
- Handling to us your business card.
We may also collect non-personally identifiable information. We may use both personal information and non-personally identifiable information to create Aggregated Personal Data.
Cookies, pixels and other technologies
We want to inform you that whenever you visit our Websites or use our Services, we collect information that your browser sends to us that is called Log Data.
Cookies are files with small amount of data that is commonly used an anonymous unique identifier. These are sent to your browser from the website that you visit and are stored on your computer’s hard drive.
Our website uses these "cookies" to collection information, to improve our Services and for the effective functioning of various systems. You have the option to either accept or refuse these cookies, and know when a cookie is being sent to your computer. If you choose to refuse our cookies, you may not be able to use some portions of our Services.
In addition, some of our advertising service providers and other third-party services may use standard technologies, such as cookies, pixel tags and web beacons, to collect information about your internet activities across websites.
- Browser and device data; such as IP address, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons and the language version of the Sites you are visiting;
- Usage data; such as time spent on the Sites, pages visited, links clicked, language preferences, and the pages that led or referred you to our Sites.
We work with a variety of Service Providers in order to provide the Services or to design, develop, deploy and operate our Products.
We want to inform that those third parties potentially have access to your Personal Data. The reason is to perform the tasks assigned to them on our behalf. However, the amount of information is limited to only the type of information necessary to the scope of their tasks but they are obligated not to disclose, share or use the information for any other purpose.
We may employ third-party companies and individuals due to the following reasons:
- To facilitate our Services;
- To improve the efficiency and speed of Internet connections with our content;
- To provide the Services on our behalf;
- To perform Service-related services;
- To assist us in analyzing how our Services are used.
- We use Google Analytics on our Sites to help us analyze your use of our Sites and diagnose technical issues.
How we use Personal Data
We may retain and use the Personal Data collected about you in order:
- To understand your needs and preferences; for example your prefered language for interfaces, the formatting of values and your device capabilities.
- Process your orders and requests and respond to your questions and concerns; for example, if you inquire about our Product or Services we may use your data to respond to and process these requests.
- Provide you with products and services, and personalize your experience; for example, we may use information on your prior activities to tailor the features and content, or we may use technical data to remember your preferences.
- Communicate with you about your account or transactions, and provide you with product-related communications, such as information about new features and policy updates.
- To make suggestions to you, based on your shopping history and use details of the products you have previously purchased; for example, from time to time we develop new Products and Services or enhanced those already in production which we believe you will also be interested in.
- Operate, maintain, analyze, develop, update and improve our Sites, and Products and Services we offer. For example, we may administer and track users’ activities on our Sites to determine how to improve our content and features, or we may analyze trends and gather demographic information about our user base to better tailor our marketing efforts.
- If you are a Tenant, to provide project-specific Quality Assurance features; for example, that a poll sample was taken within the perimeter you assigned a pollster to.
- To detect, investigate and prevent activities that may violate our policies, or applicable laws; for example activities such as fraud detection and prevention or that may threaten the security, integrity or availability of our or another party’s products, systems and services.
- To send you news, updates, promotions, product information, event announcements, and other marketing communications; for example announcements of new features and invoicing.
- To provide you with personalized advertising based on your activity and interests, both on our own Sites, Products and Services and on third-party sites and applications; for example we will retain and evaluate information on your recent visits to our website and how you move around different sections of our website for analytics purposes to understand how people use our website so that we can make it more intuitive.
- To understand the topics that interest you the most; for example we will keep a record of the articles on our website that you have clicked on and use that information to target advertising on this website to you that is relevant to your interests, which we have identified based on articles you have read.
- To perform Geo-Targeting tasks; for example, allowing Advertising Service Providers to serve ads based on your current or prior location, including through location-based targeting segments created by Data Partners.
- Act pursuant to your consent for a specific purpose not listed in this policy; for example, with your consent, we may post your testimonial along with your name on our Sites. If you wish to update or delete your testimonial, please contact us.
- To meet legal and regulatory requirements.
We also use aggregated information, such as usage data, for other lawful purposes, such as to create blog posts and content that others may find useful.
Self-service tools for managing your own Personal Data
We provide you with, and constantly improve on, self-service controls and preference settings that you can use to manage the way we use your Personal Data, or if so you choose to edit it or delete it. These controls and settings may include:
- Editing account information. By logging into your account on our Site you will be able to change certain account information. Your account settings may also permit you to opt-out of some types of notification messages. To protect your privacy and security, we require you to identify yourself in order to verify your identity before granting you account access or making any changes.
- Changing your preferences for transactional and marketing communications. You can opt-out of the marketing communications we send by clicking the unsubscribe link in the applicable email. Please note that, even after you opt out from receiving marketing messages from us, you may continue to receive transactional and product-related notifications such as invoicing, notifications, or operations-related alerts.
In most cases you can exercise these choices yourself using the tools described above. If you cannot do so please contact us as indicated in the "Contact Us" section below. We will respond to your request within 30 days.
Please be aware that if you do not allow us to collect personal information from you, we may not be able to deliver certain products, features and services to you, and some of our products and services may not work appropriately or be able to take account of your interests and preferences.
Data storage and processing juridiction
Your Personal Data will be securely stored and processed in Canada where we maintain systems and datacentre infrastructure, but some of our Service Providers may store and process your Personal Data in other countries.
In addition, as part of our regular operations the Personal Data that we collect about you may be transferred to entities and/or to other third parties across borders and/or from your country to other countries around the world.
You acknowledge that we may transfer information to and from Canada and to any other country in which ourselves and our service providers maintain systems or facilities, and to other countries globally.
If you are located in the European Union or other regions with laws governing data collection and use that may differ from the Canadian law you acknowledge that we may transfer information, including Personal Data, to a country and jurisdiction that does not have the same data protection laws that your jurisdiction has.
European Economic Area (EEA) and Swiss Data Subjects
Depending on which of our Sites, Products and Services you use and how you use them we collect and process Personal Data about you only where we have legal bases for doing so under applicable European Union laws, meaning we collect and use your information only where:
- We need it to provide and operate the Sites, Products and Services.
- We need it to process your requests, orders, questions and concerns.
- We need it to provide customer support.
- We need it for other legitimate uses that are not overridden by your data protection interests, including:
- Marketing and selling our products and services, consistent with applicable laws.
- Maintaining, analyzing, developing, updating, and improving our Sites, Products and Services.
- Keeping records of bugs, customer support requests and similar requests you file, and our response to these requests.
- Using information to personalize content and features on our Sites and the Products and Services.
- Detecting, preventing and investigating activities that may violate our policies or applicable laws such as spamming and fraud activities.
- Maintaining corporate or business records consistent with our retention policies and applicable laws.
- Protecting against activities that may threaten the security, integrity, or availability of our Service Providers products, systems, and services.
- We are processing your Personal Data to protect our legal rights, in such cases as:
- You give us consent to process your Personal Data.
- We need to process your Personal Data to comply with a legal obligation, such as a lawful subpoena or law-enforcement request or to fulfill the lawful instructions of our customers (when they are acting as the controller); and/or
- We have another lawful basis for processing in accordance with applicable European Union laws.
In accordance with the General Data Protection Regulation (GDPR), if an individual in the European Economic Area (EEA) has consented to our use of their Personal Data, and our processing is based on that consent, that individual has the right to withdraw their consent without affecting any processing that has already taken place. You acknowledge that if you object to or restrict processing your Personal Data, you may not be able to use the Sites and Products and Services or certain features any longer.
Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, individuals in the European Economic Area (EEA) have the right to object to that use as specified in Article 21 of the General Data Protection Regulation (GDPR), though, in some cases, this may mean no longer using the Sites, Products and Services. We acknowledge that European Economic Area (EEA) data subjects have certain other rights under the General Data Protection Regulation (GDPR), including the right to lodge a complaint with a supervisory authority and to request from the controller access to, and rectification or erasure of, personal data, restriction of processing concerning the data subject, and data portability as specified under the General Data Protection Regulation (GDPR).
When we are acting as a controller, you can initiate a request by contacting our Data Protection Officer as indicated in the "Contact Us" section below. Please note that these requests apply only to information that we hold as a "controller." If your request relates to the Personal Data collected through a customer’s websites or digital products, you should direct your request to the owner of that website or product. Please note that you must verify your identity and request before we process your request. You may be required to provide email confirmation or other information in order for us to verify your identity.
European Economic Area (EEA) and Swiss data subjects can please contact our Data Protection Officer as indicated in the "Contact Us" section below.
California Consumer Privacy Act
Effective January 1, 2020, the California Consumer Privacy Act of 2018 (CCPA) allows consumers who are California residents, upon a verifiable consumer request, to request from a business:
- Delete any Personal Data about the consumer which the business has collected from the consumer.
- Disclose to the consumer certain information about the Personal Data that the business collects from the consumer.
- Direct a business that sells Personal Data about the consumer to third parties not to sell the consumer’s Personal Data.
We do not sell any consumer Personal Data to third parties. To submit a data access or data deletion request, please contact our Data Protection Officer as indicated in the "Contact Us" section below. These requests apply only to information that we hold if acting as a "controller." If your request relates to the Personal Data collected through a customer’s websites or digital products, you should direct your request to the owner of that website or product. Please note that you must verify your identity and request before we will process your request. You may be required to provide email confirmation or other information in order for us to verify your identity.
Under certain circumstances, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, your valid government government issued identification, and the authorized agent’s valid government issued identification to allow us to verify that the agent is authorized to make the request on your behalf.
California’s Shine the Light Law
CA Civil Code § 1798.83 permits California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we may have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Data disclosed to those third parties. As a general policy, we do not share Personal Data with third parties for their own direct marketing purposes without your prior consent. Accordingly, you can prevent disclosure of your Personal Data to third parties for their direct marketing purposes by withholding consent. Please contact our Data Protection Officer as indicated in the "Contact Us" section below if you would like to make such a request.
Currently we do not respond to Do Not Track browser settings or signals which may also be the case with some of our Service Providers.
We value your trust in providing us your Personal Data, thus we are striving to use commercially acceptable means of protecting it.
We cannot ensure, and do not warrant or guarantee, that the information you transmit to us will remain secure, nor do we guarantee that this information will not be accessed, disclosed, altered, destroyed or used in an unauthorized manner.
If we learn of a security breach, we may attempt to notify you electronically so that you can take appropriate protective steps. We may also post a notice on the Site or our Services if a security breach occurs.
Depending on the jurisdiction where you live, you may have a legal right to receive a notice of a security breach in writing. If you have any questions about the security of your personal information, please contact us as indicated in the "Contact Us" section below.
It will depend on the type of Personal Data, the purpose for which it is used and how sensitive it is how long we will keep it.
- We will retain and use your Personal Data for as long as necessary to resolve disputes and/or enforce our rights and agreements.
- If you are a Tenant, we will retain employees account information for as long as your Tenant account is active and thereafter unless your Tenant requests deletion.
- Aggregated information may be stored indefinitely.
Links to other sites
Our Services do not address anyone under the age of 18. We do not knowingly collect personal identifiable information from a person under 18. In the case we discover that a child under 13 has provided us with Personal Data, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us so that we will be able to do necessary actions.
Your data protection rights
We would like to make sure you are fully aware of all of your data protection rights.
You are entitled to the following:
- The right to access. You have the right to request to us copies of your Personal Data. We may charge you a small fee for this service.
- The right to rectification. You have the right to request us to correct any information you believe is inaccurate. You also have the right to request to us to complete the information you believe is incomplete.
- The right to erasure. You have the right to request to us to erase your Personal Data, under certain conditions.
- The right to restrict processing. You have the right to request that we restrict the processing of your Personal Data, under certain conditions.
- The right to object to processing. You have the right to object us to process your Personal Data, under certain conditions.
- The right to data portability. You have the right to request to us to transfer the data that we have collected to another organization, or directly to you, under certain conditions.
If you make a request, we have one month to respond to you. If you would like to exercise any of the above rights, please contact us as indicated in the "Contact Us" section below.
For all Privacy-related enquires we pledge to respond to your request within 30 days.
60 Atlantic Avenue, Suite 200
Toronto, Ontario, M6K 1X9