🌎EARTH🌍Legal Paradigm
Effective date: 10/13/2020
- Introduction
- Definitions
- Information Collection and Use
- Use of Data
- Retention of Data
- Transfer of Data
- Disclosure of Data
Security of Data
The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
- Your Data Protection Rights Under General Data Protection Regulation (GDPR)
If you are a resident of the European Union (EU) and European Economic Area (EEA), you have certain data protection rights, covered by GDPR. – See more at https://eur-lex.europa.eu/eli/reg/2016/679/oj
We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.
If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please email us at contact@laylo.com.
In certain circumstances, you have the following data protection rights:
- the right to access, update or to delete the information we have on you;
- the right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete;
- the right to object. You have the right to object to our processing of your Personal Data;
- the right of restriction. You have the right to request that we restrict the processing of your personal information;
- the right to data portability. You have the right to be provided with a copy of your Personal Data in a structured, machine-readable and commonly used format;
- the right to withdraw consent. You also have the right to withdraw your consent at any time where we rely on your consent to process your personal information;
Please note that we may ask you to verify your identity before responding to such requests. Please note, we may not able to provide Service without some necessary data.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
- Your Data Protection Rights under the California Privacy Protection Act (CalOPPA)
CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require a person or company in the United States (and conceivable the world) that operates websites collecting personally identifiable information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy. – See more at: https://consumercal.org/about-cfc/cfc-education-foundation/california-online-privacy-protection-act-caloppa-3/
According to CalOPPA we agree to the following:
- users can visit our site anonymously;
- our Privacy Policy link includes the word “Privacy”, and can easily be found on the page specified above on the home page of our website;
- users will be notified of any privacy policy changes on our Privacy Policy Page;
- users are able to change their personal information by emailing us at contact@laylo.com.
Our Policy on “Do Not Track” Signals:
We honor Do Not Track signals and do not track, plant cookies, or use advertising when a Do Not Track browser mechanism is in place. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
Your Data Protection Rights under the California Consumer Privacy Act (CCPA)
If you are a California resident, you are entitled to learn what data we collect about you, ask to delete your data and not to sell (share) it. To exercise your data protection rights, you can make certain requests and ask us:
- What personal information we have about you. If you make this request, we will return to you:
- The categories of personal information we have collected about you.
- The categories of sources from which we collect your personal information.
- The business or commercial purpose for collecting or selling your personal information.
- The categories of third parties with whom we share personal information.
- The specific pieces of personal information we have collected about you.
- A list of categories of personal information that we have sold, along with the category of any other company we sold it to. If we have not sold your personal information, we will inform you of that fact.
- A list of categories of personal information that we have disclosed for a business purpose, along with the category of any other company we shared it with.
Please note, you are entitled to ask us to provide you with this information up to two times in a rolling twelve-month period. When you make this request, the information provided may be limited to the personal information we collected about you in the previous 12 months.
- To delete your personal information. If you make this request, we will delete the personal information we hold about you as of the date of your request from our records and direct any service providers to do the same. In some cases, deletion may be accomplished through de-identification of the information. If you choose to delete your personal information, you may not be able to use certain functions that require your personal information to operate.****
- To stop selling your personal information. We do not sell your personal information for monetary consideration. However, under some circumstances, a transfer of personal information to a third party, or within our family of companies, without monetary consideration may be considered a “sale” under California law.
If you submit a request to stop selling your personal information, we will stop making such transfers. If you are a California resident, to opt-out of the sale of your personal information, send an email to contact@laylo.com
Please note, if you ask us to delete or stop selling your data, it may impact your experience with us, and you may not be able to participate in certain programs or membership services which require the usage of your personal information to function. But in no circumstances, we will discriminate against you for exercising your rights.
To exercise your California data protection rights described above, please send your request(s) by one of the following means:
By email: contact@laylo.com
Your data protection rights, described above, are covered by the CCPA, short for the California Consumer Privacy Act. To find out more, visit the official California Legislative Information website. The CCPA took effect on 01/01/2020.
- Service Providers
We may employ third party companies and individuals to facilitate our Service (“Service Providers”), provide Service on our behalf, perform Service-related services or assist us in analysing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
- Analytics
We may use third-party Service Providers to monitor and analyze the use of our Service.
Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en
We also encourage you to review the Google's policy for safeguarding your data: https://support.google.com/analytics/answer/6004245.
Firebase
Firebase is analytics service provided by Google Inc.
You may opt-out of certain Firebase features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy?hl=en
For more information on what type of information Firebase collects, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en
Cloudflare analytics
Cloudflare analytics is a web analytics service operated by Cloudflare Inc. Read the Privacy Policy here: https://www.cloudflare.com/privacypolicy/
Mixpanel
Mixpanel is provided by Mixpanel Inc.
You can prevent Mixpanel from using your information for analytics purposes by opting-out. To opt-out of Mixpanel service, please visit this page: https://mixpanel.com/optout/
For more information on what type of information Mixpanel collects, please visit the Terms of Use page of Mixpanel: https://mixpanel.com/terms/
- CI/CD tools
We may use third-party Service Providers to automate the development process of our Service.
GitHub
GitHub is provided by GitHub, Inc.
GitHub is a development platform to host and review code, manage projects, and build software.
For more information on what data GitHub collects for what purpose and how the protection of the data is ensured, please visit GitHub Privacy Policy page: [https://help.github.com/en/articles/github-privacy-statement.](https://help.github.com/en/articles/github-privacy-statement)
GitLab CI/CD
GitLab CI/CD is provided by GitLab, Inc.
GitLab CI (Continuous Integration) service is a part of GitLab that build and test the software whenever developer pushes code to application.
GitLab CD (Continuous Deployment) is a software service that places the changes of every code in the production which results in every day deployment of production.
For more information on what data GitLab CI/CD collects for what purpose and how the protection of the data is ensured, please visit GitLab CI/CD Privacy Policy page: https://about.gitlab.com/privacy/.
CircleCI
CircleCI is provided by Circle Internet Services, Inc.
CircleCI is Continuous Integration, a development practice which is being used by software teams allowing them to build, test and deploy applications easier and quicker on multiple platforms.
For more information on what data Circle CI collects for what purpose and how the protection of the data is ensured, please visit Circle CI Privacy Policy page: https://circleci.com/privacy/.
- Behavioral Remarketing
Laylo, Inc. uses remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimise and serve ads based on your past visits to our Service.
Google Ads (AdWords)
Google Ads (AdWords) remarketing service is provided by Google Inc.
You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en
Twitter remarketing service is provided by Twitter Inc.
You can opt-out from Twitter's interest-based ads by following their instructions: https://support.twitter.com/articles/20170405
You can learn more about the privacy practices and policies of Twitter by visiting their Privacy Policy page: https://twitter.com/privacy
Facebook remarketing service is provided by Facebook Inc.
You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950
To opt-out from Facebook's interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217
Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.
For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation
- Payments
We may provide paid products and/or services within Service. In that case, we use third-party services for payment processing (e.g. payment processors).
We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
The payment processors we work with are:
PayPal or Braintree:
Their Privacy Policy can be viewed at https://www.paypal.com/webapps/mpp/ua/privacy-full
Stripe:
Their Privacy Policy can be viewed at: https://stripe.com/us/privacy
- Links to Other Sites
Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
- Children's Privacy
Our Services are not intended for use by children under the age of 13 (“Children”).
We do not knowingly collect personally identifiable information from Children under 13. If you become aware that a Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information from our servers.
- Changes to This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update “effective date” at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
Data Import Addendum
This binding addendum (this “Addendum”) is between Laylo, Inc. (“Laylo”) and Customer and supplements the Laylo Customer Terms of service or the Platform Terms (the “Agreement”) between Laylo and Customer. Capitalized terms used but not defined herein shall have the meanings ascribed to such terms in the Agreement. For good and valuable consideration, the receipt and sufficiency of which is hereby acknowledged, the parties agree to supplement and amend the Agreement as follows:
1. Data Imports; License
Subject to Laylo’s then-current data import functionality and policies (including, without limitation, Laylo’s requirements regarding form and formatting of imported data), Laylo will ingest certain data, information and other materials uploaded, transmitted or otherwise provided to or through the Service by Customer, including without limitation pre-collected telephone numbers (collectively, “Data Imports”) so as to permit Customers to send messages via Laylo Numbers solely to individuals residing in the United States and Canada (and other Territories as may be added by Laylo from time to time, if any). Customer hereby grants to Laylo a non-exclusive license to host, copy, process, use, transmit and disclose all Data Imports as necessary to perform its obligations and exercise its rights under this Addendum and the Agreement.
2. Representations and Warranties
Customer, for itself and on behalf of its Authorized Users, represents, warrants, and covenants that: (a) it owns or otherwise has all necessary rights to the Data Imports to grant to Laylo all rights and licenses set forth herein; (b) Laylo’s ingestion and use of Data Imports on or through the Service does not and will not violate Applicable Law, the AUP, or the privacy rights, publicity rights, copyrights, contract rights, intellectual property rights, or other rights of any person or entity; (c) Customer/Authorized User will not upload or otherwise provide any Data Imports to the Service that contain any Restricted Data; (d) the upload, posting or other submission of Data Imports to the Service does not and will not result in a breach of contract between Customer/Authorized User and any third party; (e) Customer/Authorized User will not knowingly collect personally identifiable information from children under thirteen (13) in connection with Data Imports and/or the Service; and (f) when using the Service to send messages, Customer will, and will cause Customer/Authorized User to: (i) comply and maintain appropriate records to demonstrate its compliance with all Applicable Laws and the AUP; (ii) ensure the content of all messages complies with Applicable Laws and the AUP; (iii) send messages only to individuals from whom Customer has obtained all necessary and legally required consent to do so in accordance with its obligations under Applicable Laws; (iv) promptly notify Laylo of all requests made by individuals to stop receiving messages from Laylo on behalf of Customer; and (v) verify any previously collected Data Imports have been collected in accordance with Applicable Laws. Customer’s responsibilities as set forth in this Section 2 and the Agreement will remain the sole responsibility and liability of Customer notwithstanding that Laylo may offer templates, advice, guidance or suggestions relating to any of the matters that are Customer’s responsibility and notwithstanding that Laylo may be engaged to provide services related to such responsibilities of Customer.
3. Indemnification
Customer will indemnify, defend and hold Laylo, its affiliates, and their respective directors, officers, employees, agents, successors, and assigns (each, a “Laylo Indemnitee”) harmless from and against any losses, damages, liabilities, debts, and expenses, including reasonable attorneys’ and experts’ fees that may be incurred by a Laylo Indemnitee in relation to any demand, suit, cause of action or governmental/regulatory inquiry/proceeding arising from or relating to any (a) use of the Service by Customer or any Authorized User in violation of this Addendum, the Agreement, Applicable Laws or the AUP; (b) breach Customer’s representations, warranties or covenants contained herein; (c) Data Imports uploaded, transmitted or otherwise provided to the Service and/or Laylo’s use thereof in the exercise of its rights or performance of its obligations hereunder; or (d) allegation that Customer or Authorized User used the Service, or otherwise caused Laylo, to send messages in violation of any Applicable Laws. Customer may not enter into any settlement on a Laylo Indemnitee’s behalf without the Laylo Indemnitee’s prior written consent. Each Laylo Indemnitee shall have the right to employ separate counsel and participate in its defense at its sole expense.
EU REPRESENTATIVE:
Under Article 27 of the GDPR , we have appointed an EU Representative to act as our data protection agent. Our nominated EU Representative is: Instant EU GDPR Representative Ltd.
Adam Brogden contact@gdprlocal.com
Tel +35315549700
INSTANT EU GDPR REPRESENTATIVE LTD
Office 2,
12A Lower Main Street, Lucan Co. Dublin
K78 X5P8
Ireland
