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Privacy Policy

Last updated: June 19th, 2019

Effecive Date: June 19th, 2019

Soomla Inc. (“Soomla” “we” “us” or “our“) provides development and data tools to mobile applications In the course of providing our website and our services (our “Services“) we collect information about you and about the users (“End Users“) of your mobile application. This privacy policy explains how we collect, use, share and protect information about you as well as how we use information we collect about the End Users. It also explains what your choices are regarding the collection, use and sharing of your information and that of your End Users.

  1. What is "Personal Information"?

Personal information is information that we hold about you, and which identifies, or together with other information may identify, you and/or your End Users.

  1. Information We Collect:

We set out below examples of the different ways in which we use personal information and where this personal information comes from.

2.1 Information about you, as a user of our services or Website:

2.1.1 Information you provide to us:

When you sign up for the Services, we ask you for information such as your username, password, email address, website, Skype ID, phone number, job role and country of residence. This information is necessary for us to provide you the Services. If you do not provide this information we would not be able to provide the Services to you.

If you choose to connect to the Services using credentials from a third party service like Google will need to collect authentication information and encrypted access credentials. For Google we ask for information such as your Google account email address, and access to your public profile data including your user name and profile photo.

We use this information to identify you in your use of the Platform. For example, we may take your Third Party Service profile photo and present it alongside your Third Party Service email address.

Any feedback, questions, comments, suggestions, ideas, or the like that you send to us. These will be treated as non-confidential and non-proprietary and we may use them and share them with third parties. This is described more fully in Terms and Conditions.

 

2.1.2 Information we collect passively from you - Usage, Log, Cookies:

What are Cookies?

When you use our Services, we use cookies and similar technologies to collect information about your location, your application, your activities on our website, your activities in the Soomla platform, information about your device and log information

Cookies are text information files that your web browser places on your computer, mobile phone, or other device when you visit a website. The cookie will help website providers recognize your device the next time you visit their website. Similar technologies include pixel tags (transparent graphic images placed on a web page or in an email, that indicate whether it had been viewed), web bugs (similar to pixel tags), and local storage objects (using mechanisms such as browser web storage (including HTML 5) and application data caches), which are used in desktop software or mobile devices

To collect information from the End Users, we also use Software Development Kits (SDKs) or Advanced Programming Interfaces (APIs) to collect information of the types described above

What do we use them for?

We and our third party providers use both session cookies (that expire once you close your web browser) and persistent cookies (which stay on the device for a set period of time or until you delete them) in order to operate our services, and in order to optimize them through the performance of analytics.

These cookies are required for making use of the Services. These cookies include security cookies to authenticate users, prevent fraudulent use of login credentials, and protect user data from unauthorized parties as well as session cookies that remember your log-in session so you can move easily within the Services.

These cookies record some of your activity on the Services as well as information about your device, such as what browser you are running, and what pages you access. This information helps us and our third party service providers diagnose server and software errors, and in cases of abuse, track and mitigate the abuse.

Our service providers, including Google, LinkedIn, HubSpot, and Mixpanel, use cookies as part of their tools. These cookies allow our service providers and us to recognize and count the number of users of the Services, to see how they move around the Platform, and how they engage with different functions, including usage statistics, when they are using the Services. This helps us to improve the way our Services work, for example by making sure our users are finding what they need easily.

Our advertising providers, including Google and Facebook, use cookies and web pixels to identify and store behaviors that users take when visiting our website (such as pages visited and search terms used). The Google and Facebook marketing and advertising services we use do not collect IP addresses that are identified as located in the EU. These cookies are used in order to: (i) identify you as a prospect for our services; (ii) deliver advertisements that are more relevant to you and your interests; (iii) limit the number of times you see an advertisement as well as (iv) help measure the effectiveness of the advertising campaign. If a prospect engages with our content and provides their contact information, their web behavior on our site is paired with their contact info and used to send email marketing and to present them with targeted advertising based on their interests. This means that after you are done browsing our website you may see some advertisements about our Services elsewhere on the Internet. Click here to learn how to opt out of this collection of your information for the purpose of advertising.

What information do the cookies and other technologies collect:

We collect the following information from users of the Website (but not from your End Users):

Information about your estimated location which may be deduced by various technologies including: IP address.

The unique identifier assigned to your application by the relevant app store, information about the app meta data of your application, your application’s marketing materials publicly available on the different app stores and different attributes regarding the gameplay and structure of your Application.

This includes information, such as the time of an event, how you came to the Services, what search engine and search keywords you may have used to get to the Service, pages you visit on the Service, your activity on the forum. Your actions with respect to emails we send you such as when you open them and what you click in them.

Information about the device you are using such as, hardware model, operating system, application version number and browser, mobile network information, IP addresses, user names, real names, email addresses and other custom properties.

Server logs regarding how you use the Services or view content provided by Google, which may include: Google search queries, telephony log information like phone number, calling party number, forward number, time and date of calls, duration of calls SMS routing information and types of calls, IP address, device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL, cookies that may uniquely identify your browser or your Google Account.

Particular cookies to note for visitors of our website:

  • Facebook Pixel: We use Facebook pixel by Facebook to customize our advertising and to serve you ads on your social media based on your browsing behavior. This allows your behavior to be tracked after you have been redirected to our website by clicking on the Facebook ad. The Facebook Pixel stores a cookie on your computer to enable us to measure the effectiveness of Facebook ads for statistical and market research purposes. We do not have access to the personal information collected through the Facebook Pixel. However, the information collected via the Facebook Pixel is also stored and processed by Facebook. Facebook may link this information to your Facebook account and also use it for its own promotional purposes in accordance with Facebook's Data Usage Policy. The Facebook Pixel also allows Facebook and its partners to show you advertisements on and outside of Facebook. You can opt-out of displaying Facebook ads by visiting https://www.facebook.com/settings?tab=ads and see below [link to cookie opt out]
  • Google Ads: We utilize Google Doubleclick by Google to serve ads that appear on Google products and on sites across the Internet. The version of the Google Doubleclick product we use does not collect IP addresses identified as originating in the EU. Google places cookies, web beacons, and other similar technologies to serve you ads based on past visits to our website. Each customer receives a different conversion cookie. The information collected by the cookie is used to generate conversion statistics and allows us to see the total number of individuals who clicked on our ads. Please review Google’s privacy policy for additional information on how Google uses the information collected. You can control how Google uses your information through Google’s Ads Settings.
  • HubSpot: We use HubSpot Inc. to analyze and measure user behavior, to send out email newsletters and to track the readership in our newsletters. To measure user behavior Hubspot places a cookie when you visit our website and tracks your interaction with our website and advertisements. We also use Hubspot to send newsletters and to analyze the behavior of newsletter recipient including how many recipients have opened the newsletter message and how often which link in the newsletter was clicked in order to optimize the advertising displayed to you. With the help of conversion tracking, this can be used to analyze whether a predefined action (for example, purchase of a service on our website) took place after clicking on the link in the newsletter in order to be able to better adapt and distribute our newsletter content. To do this, the emails sent include web beacons or tracking pixels, which represent one-pixel image files that are integrated on our website.

    We link the data listed above as collected by cookies and web beacons with your e-mail address and an individual ID. With the obtained data we create a user profile to tailor the newsletter to your individual interests. In doing so, we record when you read our newsletters, which links you click in these and from that infer your personal interests. We link this data with the actions you have taken on our website.

    For more privacy and privacy information, please visit: https://legal.hubspot.com/product-privacy-policy. You can disable the email tracking by disabling the display of images by default in your e-mail program. In this case the newsletter will not be displayed completely and you may not be able to use all the features. If you display the images manually, the tracking described above will be done. You can revoke your consent and opt out of such email communications at any time by clicking the "unsubscribe" link at the bottom of each email or by contacting us at privacy@soomla.com. Even if you unsubscribe from these emails you will continue to receive service related correspondence.
  • LinkedIn: We use the LinkedIn Insight Tag by Linkedin to track ad conversions, retarget website visitors, and unlock additional insights about individuals interacting with our LinkedIn advertisements. If you are registered with LinkedIn, it is possible for LinkedIn to associate your interaction with our website with your user account. You can opt-out of the LinkedIn Insight Tag by clicking here.For further information, please see LinkedIn’s privacy policy here.
  • Google Analytics: We use a tool called “Google Analytics” to collect some information we listed above about your use of the Services. We use the information we get from Google Analytics to improve the Services and to help you improve your Application.  In order to collect this information, Google Analytics may set cookies on your browser or mobile device, or read cookies that are already there. Google Analytics may also receive information about you from apps you have downloaded, that partner with Google. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to the Services to another application which partners with Google, is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. Please review those and see http://www.google.com/policies/privacy/partners/ for information about how Google uses the information provided to Google Analytics and how you can control the information provided to Google. To prevent your data from being used by Google Analytics, you can download the Google Analytics opt-out browser add-on for Google Analytics which can be found here: https://tools.google.com/dlpage/gaoptout/.

Information received from third parties

We also use Linkedin Sales Navigator to locate and connect with individuals that may find our services interesting. You may decline such requests or remove the connection at any time. You can control which messages you receive by adjusting your communication preferences on your LinkedIn Privacy Settings page or using the unsubscribe options in the footer of messages as applicable (e.g., Sales Navigator InMails).

2.2 Information about your End Users:

We use technologies such as Software Development Kits (SDKs) or Advanced Programming Interfaces (APIs) to collect information about your End Users' technical data, mobile devices, use of your application, interaction with social media websites and interaction with advertising as described below.

We use these technologies to recognize the End User's device and to track the End User's activities in your application in order to provide our Services to you and in accordance with your instructions. These technologies work by storing a line of code in your application that resides in the End User's mobile device and synchronizes information back and forth between the End User's mobile device and our servers. When an End User removes the application from his or her mobile device this line of code will also be removed.

It is your responsibility to disclose clearly, and where necessary, obtain consent to, our use of cookies / SDK on your End User's device, how we collect and use your End User's data as well as our sharing it with third parties and processing information on servers outside of the European Economic Area.

We collect and store the following End User information:

This includes information, such as URL information, cookie data, IP address, network connection type (e.g., WiFi, 3G, LTE), browser type, language, operating system, and Soomla application version.

The types of devices the End User uses to access the Application, their mobile provider, network and device performance the unique device identifier assigned to that device by phone makers, carriers, or makers of the operating system (to the extent allowed by such phone makers, carriers, or makers of the operating system) identifiers for advertising Google Advertising ID or IDFA and geographic or geolocation information.

Information about how the End User uses and interacts with the applications whose developers are users of our Services. This includes: how the End User uses the different Application functions, the amount of time the End User spends in the Application.

We collect data about how End Users interact with ads inside the application. This includes viewing, clicking on the ads as well as whether or not an End User performed post-click action like installing the advertised.

Information about the country in which the End User might reside as deduced by various technologies including: IP address.

 

Where available, we combine an End User's device id or advertising with non personally identifiable information in order to allow us to uniquely identify such End User's device for purposes of storing specific and aggregate usage preferences and data. We then treat the combined information as personal information in accordance with this Privacy Policy.

  1. How We Use Personal Information

We use personal information to provide our Services to you, to market and advertise our services, to improve our Services and to protect our legal rights. We limit the collection of personal information to that which is relevant for these purposes. We will not store, access, transmit, retain or otherwise use personal information in any way that is incompatible with the purposes for which it has been collected or stored as described in this Privacy Policy, unless such alternative use is authorized in writing.

To the extent EU data protection law applies to our processing of personal data about you as user of our Services, we act as the "data controller". To the extent EU data protection law applies to our processing of personal data about users of your mobile applications ("End Users") we serve as the "data processor".

We use your information in order to:

To do this we also use your information to: Provide you with technical support and assistance in the development of the modules in your Application; ensure that the Services function well and communicate with you about the Services by email, forums, notifications within the Services (transactional messages). For example we will contact you to notify you of any issues with the Services or any suspicious activity in your account or use what we learn about your End Users' interactions with your application and with advertising to provide you with information you can use to improve your application. The legal basis for these uses is the performance of the contract with you.

In some cases, your use of information provided to you by us may require the End User's consent. It is your responsibility to disclose clearly, and obtain consent if and as required by applicable data protection law.

We use information about you, collected through cookies and other technologies - see here. We use this information about you, but not about your End Users (i) identify you as a prospect for our services; (ii) deliver advertisements that are more relevant to you and your interests; (iii) limit the number of times you see an advertisement as well as (iv) help measure the effectiveness of the advertising campaign. The advertising services we use for this do not collect IP addresses identified as originating in the EU.

This means that after you are done browsing our website you may see some advertisements about our Services elsewhere on the Internet. Click here to learn how to opt out of this collection of your information for the purpose of advertising.

We use your information, but not your End Users’ information, for analytics and measurement to understand how our Services are used in order to make improvements to our services or develop new components to the Services through understanding how you, but not your End Users use and interact with them, including how you interact with applications, advertising, products, and services that are made available, linked to, or offered through the Services. For example: we use what we learn about volume usages by mobile devices of the users of our Services (but not End Users) to help optimize the layout of the Services, and use Hubspot email tracking to improve our newletters and services.

The legal basis for these uses is our legitimate interest in the improvement and optimization of our service offerings and in ensuring the security of our services and we apply appropriate safeguards to protect your information (see Section 6 below).

When needed, we use your information to enforce the Terms of Use (https://www.soomla.com/terms-and-conditions/) and any other terms that you have agreed to, including to protect the rights, property, or safety of Soomla, its users, or any other person, or the copyright-protected content of the Services as well as to comply with our legal obligations.

The legal basis for these uses is our legitimate interest in the performance of our contractual obligations; protection of our legal rights, compliance with legal obligations and protection of the rights of users and other individuals.

If you agree, we will contact you by email to inform you of new products and Services that might be of interest to you. The legal basis for this is your consent. You can revoke your consent and opt out of such email communications at any time by clicking the "unsubscribe" link at the bottom of each email or by contacting us at privacy@soomla.com. Even if you unsubscribe from these emails you will continue to receive service related correspondence

Soomla representatives may send you connection requests or messages on social media. You may decline such requests or remove the connection at any time.

 

  1. How we Share the Information Collected:

We share information collected about you and your End Users with service providers that assist use with the provision of our Services, as well as in connection with a business transaction or as necessary to comply with our legal obligations. We share your information with marketing and advertising providers to optimize our services and present you with targeted advertising. The advertising services we use to this end do not collect IP addresses identified as originating in the EU.

We share your information and that of your End Users with service providers to perform functions and process your data and to help provide our Services, consistent with this Privacy Policy. As with respect to your End Users – we share information only with the subprocessors described in our agreement with you or in the applicable data processing agreement. We share your information with our hosting provider as well as with analytics providers, including Google Analytics (see above) and Mixpanel to help us understand your use of our Services. Other service providers include, Marketing Automation, CRM, Cloud File Storage, Accounting software and communication software. The legal basis for this sharing of your information is our legitimate interest in providing our Services efficiently.

We share your information and that of your End Users with our parent company, subsidiaries, joint ventures, or other companies under common control with Soomla in the ordinary operation of our business. In addition, we would share your information, or that of your End Users, if we are involved in a merger, acquisition, consolidation, change of control or sale of all or a portion of our assets or if we undergo bankruptcy or liquidation. The legal basis for this sharing is our legitimate interest in carrying out our business operations.

We share your information and that of your End Users, per your instructions, in order to prevent fraud or abuse to our services, to protect your rights, to comply with our legal obligations and to protect our rights. [each of these should be a click to the below]. The legal basis for this sharing is compliance with the law and our legitimate interest in the prevention of fraud, compliance with legal obligation and the protection of the rights of others.

When requested, we will share or facilitate the sharing of End User information with third parties pursuant to your instructions. We do not have any legal relationship with such parties. You are responsible for entering into separate contractual arrangements with such third parties binding them to comply with data protection obligations. These third party data processors are not sub-processors and we shall not bear any responsibility or liability for sharing information with such parties. The legal basis for this sharing is necessary for the performance of our contract with you.

We will share information to prevent or detect fraud or to address technical issues and if we believe it is necessary to investigate, prevent, or take action regarding situations that involve abuse of the Services infrastructure or the Internet in general (such as voluminous spamming, denial of service attacks, or attempts to compromise the security of the website infrastructure or the Services generally).

We will share information in an emergency or to protect the safety of any person and if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person.

We will share information if we are legally required to do so, such as in response to court orders or legal process (e.g., a court order or subpoena), or to establish, protect, or exercise our legal rights or to defend against legal claims or demands, or to comply with requirements of mandatory applicable law. We will also share information as necessary to enforce the Terms of Use (http://soomla.com/terms-and-conditions/) and any other terms that you have agreed to, including to protect the rights, property, or safety of Soomla, its users, or any other person, or the copyright-protected content of the Services.

We also process and share information in an aggregated, de-identified manner, where the information is shared as part of a statistical report and does not contain personal information.

We also process and share information in an aggregated, de-identified manner, where the information is shared as part of a statistical report and does not contain personal information.

If you have given permission in connection with using the third party services for the purpose of signing in, or on your preferences set with the third party service, some information about you can be shared with social media services and with others through third party services and may be published by them or may be shared  by default. You understand and agree that a third party service’s use of information collected from you (or as authorized by you) is governed by the third party service’s privacy policies and your settings on the relevant service, and that our use of such information is governed by this Privacy Policy and your Soomla account settings.

We allow our advertising partners to collect personal information about you, but not your End Users, for the purpose of advertising - see above for more information.

Please see the section “Cookies and Other technologies” below for information about the technologies that we and third parties use to collect information and to learn about options in connection with these.

 

  1. Third Party Links

The Services may contain links to third party sites that are not owned or controlled by Soomla. We have no control over the content, privacy policies, or practices of any third party site. You are subject to the policies of those third party sites where applicable. We encourage you to ask questions before you disclose your Personal Information.

  1. Security and Information Protection

We take reasonable precautions to protect your personal information. For example, all personal information collected by us is transferred over https and all personal information stored by us or for us is kept on a server in a secure environment. Only employees, our partners and any sub-contractors who need the information to perform a specific service are granted access to the information.  All of our employees that have access to personal information are bound by confidentiality obligations. Please keep in mind that the Internet is not a 100% secure medium for communication, and we cannot guarantee that your personal information will always remain private when using the Services.

  1. Policy Regarding Children

If you are a user of the Services: The Services are not directed to children under the age of 16.  We do not knowingly collect Personal Information from children under 16. If you are under 16, please do not use the Services and do not provide any personal information to us. If you become aware that a child under 16 is a user of the Services and has provided us with personal information without parental consent, please contact us at  privacy@soomla.com.

If you are an End User: We have no direct relationship with our users’ customers or end users whose personal data we process. Our users are responsible for acquiring any parental consent necessary from End Users who are under 16 as may be required by applicable law. If you are an End User who is under 16 and wish your information to be deleted or to have any other action be taken with respect to your information, please contact our user (the “data controller) as set forth in Section 8 of this notice. If you are a California resident under the age of 18 and you wish to remove publicly available content, please contact us at privacy@soomla.com with the subject line “California Eraser”.

  1. For EU Individuals: Your Rights under the General Data Protection Regulation:

If you are a user or an End User or our services, and reside in the EU you may be entitled by law as well as under the Privacy Shield principles (see below) to access, correct, amend, or delete personal information about you that we hold. A list of these rights is below. For specific things you can do to control how we use your information please see Section 9 below.

If you are an End User: We have no direct relationship with our user’s customers or end users whose personal data we process. If you are an End User, and you would like to access, amend or delete your data or otherwise exercise your data subject rights under applicable EU data protection law, then you need to contact our user (the “data controller”) directly and we will respond within a reasonable period of time to any such request by our user.

If you are a user of our services: You may access your Soomla account to access, correct or delete the information you provided to us, or information we hold about your End Users, and which is associated with your account. For instructions on accessing your information or otherwise for assistance with these rights please write us at privacy@soom.la.

In the event that we refuse a request, we will provide the individual with a reason as to why. Individuals in the EU have the right to complain as outlined in Section 15 below.

A list of your rights is below:

The right to request a copy of the information that we hold about the individual.

The right to correct data that we hold about the individual that is inaccurate or incomplete.

in certain circumstances the individual can ask for the data we hold about him or her to be erased from our records.

where certain conditions apply to have a right to restrict the processing.

the right to have the data we hold about the individual transferred to another organization.

you have the right to object to certain types of processing such as direct marketing (to the extent applicable). We do not engage in any marketing to the End Users of the Services.

the right to not be subject to the legal effects of automated processing or profiling.

 

You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here. If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law. In some cases our ability to uphold these rights for you may depend upon our obligations to process personal information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.

  1. What can you do about how we use your information

Email communication: Users may opt out of receiving promotional email communication from Soomla by clicking the “unsubscribe” link provided with each email. We will continue to send you notifications necessary for the Services to this email address.

Email tracking via Hubspot: You can disable the email tracking by disabling the display of images by default in your e-mail program. In this case the newsletter will not be displayed completely and you may not be able to use all the features. If you display the images manually, the tracking described above will be done.

Deleting your account: You may request that we delete your account or delete information pertaining to your End Users by writing us at privacy@soomla.com.

Cookies and other technologies:

Google Ads:

  • To opt out of targeted advertising by Google, you can go to Google’s ad settings.
  • You may also install the DoubleClick opt-out add-on. Once installed, even if you clear all your cookies and restart your browser, it will prevent the DoubleClick cookie from being saved to your browser.

Facebook Pixel: You can control your Facebook ad preferences by visiting https://www.facebook.com/about/ads.

Interest based advertising generally:

  • To opt out of interest based advertising or to learn more about the use of this information, you can visit the Network Advertising Initiative, the Digital Advertising Alliance or in Europe.
  • If you choose to opt out, an opt-out cookie will be placed on your computer. The opt-out cookie is browser-specific and device-specific and only lasts until cookies are cleared from your browser or device. The opt-out cookie will not work for essential cookies. If the cookie is removed or deleted, if you upgrade your browser, or if you visit us from a different computer, you will need to return to the links above to re-select your preferences.
  • lease note that these actions will do not opt you out of being served advertising. You will continue to receive generic ads.

Google Analytics: You can control the information provided to Google and opt out of certain ad provided by Google by using of the of the methods set forth http://www.google.com/policies/privacy/partners/ or downloading the Google Analytics opt-out browser add-on for Google Analytics which can be found here.

LinkedIn: You can opt-out of the LinkedIn Insight Tag by clicking here.

Mixpanel: You can opt-out of Mixpanel’s automatic retention of data collected through your browsers by clicking here. To track opt-outs Mixpanel uses a persistent opt-out cookie placed on your devices. Mixpanel opt-out cookies will not prevent any other data collection methods. If you get a new computer, install a new browser, erase or otherwise alter your browser’s cookie file (including upgrading certain browsers) they may also clear the Mixpanel opt-out cookies.

All Cookies: You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. The Help feature on most browsers provide information on how to accept cookies, disable cookies, or to notify you when receiving a new cookie. If you do not accept cookies, you may not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly. Turning off the browser’s cookies will prevent web beacons from tracking your specific activity. The web beacon may still record an anonymous visit from your IP address, but unique information will not be recorded. If you do not want to receive tracking pixels, you will need to disable HTML images in your email client, and that may affect your ability to view images in other emails that you receive. You can find more information about cookies at http://www.allaboutcookies.org/.

  1. How Long Do We Keep Your Information

We retain your End User information in accordance with the provisions of the agreement between us or the applicable data processing addendum.

We retain your information for as long as necessary for the purpose for which it was provided and to the extent that we are obliged to do so in accordance with applicable laws and regulations and/or as necessary to protect our legal rights or for certain business requirements. For example, when we process your payments, we will retain this data for longer periods of time as required for tax or accounting purposes. To read more about specific reasons we would retain some data for longer periods of time see below:

I.e. to protect you, other people, and Soomla from fraud, abuse, and unauthorized access.

When you make a payment to us we are often required to retain this information for long period of time for purposes of accounting, dispute resolution and compliance with tax, anti-money laundering, and other financial regulations

To meet any applicable law, regulation, legal process or enforceable governmental request, as required to enforce our terms of service, including investigation of potential violations.

For example, when you share information with other users, deleting it from your account will not eliminate copies maintained by the recipients

If you have directly communicated with us , through a customer support channel, feedback form, or a bug report, we may retain reasonable records of those communications.

 

Even if you delete your account, keep in mind that the deletion by our third party providers may not be immediate and that the deleted information may persist in backup copies for a reasonable period of time. Also, information that had already been shared with third parties may not be deleted by them. For any privacy or data-protection-related questions, please write to privacy@soomla.com.

  1. Cross Border Transfer

Soomla transfers, processes and stores information about you on servers located in a number of countries, including the United States. We also subcontract processing to, or share your information with, third parties located in countries other than your home country.

Transfers of Information from the EEA and Switzerland:

For EU and Swiss Individuals: Privacy Shield Notice for Personal Data Transfers to the United.

Soomla Inc. will conduct any transfers of personal information from the European Economic Area (EEA) and the United Kingdom, or from Switzerland to the US in compliance with the EU–US Privacy Shield Framework and the Swiss–U.S. Privacy Shield Framework (“Privacy Shield”) as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information from European Union member countries and the United Kingdom, and Switzerland transferred to the United States pursuant to Privacy Shield. Soomla has certified to the Department of Commerce that we adhere to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this Privacy Policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

With respect to personal data received or transferred pursuant to Privacy Shield, Soomla is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

If we become subject to an FTC or court order based on non-compliance, Soomla shall make public any relevant Privacy Shield-related sections of any compliance or assessment report submitted to the FTC, to the extent consistent with confidentiality requirements.

Pursuant to the Privacy Shield Frameworks, EU, UK, and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also may correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to privacy@soomla.com. If requested to remove data, we will respond within a reasonable timeframe.

We will provide an individual opt-out or opt-in choice before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to privacy@soomla.com.

In certain situations, Soomla may be required to disclose personal information in response to lawful requests by public authorities, including in order to meet national security or law enforcement requirements. For more information, please see Section 4 above headed "What do we do with the information collected?"

Soomla’s accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Soomla remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless Soomla proves that it is not responsible for the event giving rise to the damage.

In compliance with the Privacy Shield Principles, Soomla commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union and United Kingdom, and Swiss individuals with Privacy Shield inquiries or complaints should first contact us at privacy@soomla.com.

Soomla has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction

Transfers of information not from the EEA

To the extent that personal information is transferred to the United States from countries other than countries within the European Economic Area and the United Kingdom or Switzerland, including personal information that is transferred from Canada, we employ similar safeguards such as selecting third party vendors carefully, ensuring personal information will be used and disclosed only as set out in this privacy policy and that it is protected by appropriate security safeguards.

However, in connection with these transfers of personal information, your personal information may be subject to privacy laws that may not provide the same protection as your country of residence. For example, government entities in such other countries may have certain rights to access your personal information. By using this Site or using our products or services that this privacy notice relates to you are consenting to this transfer of your personal information.

 

  1. Browser Do Not Track

The Services do not support Do Not Track at this time. Do Not Track (DNT) is a privacy preference you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. For all the details, including how to turn on Do Not Track, visit donottrack.us.

  1. Changes to Privacy Policy

We change this Privacy Policy from time to time. When we update this Privacy Policy, we will notify you by posting the revised Privacy Policy on our website and will always indicate the date the last changes were published. If changes are significant, we will provide notice in an additional means we deem appropriate which may include: directly notifying you by email of the change, posting a banner on our website, and/or when required, asking your consent for the change.

  1. Questions or Comments

We welcome questions and comments about this Privacy Policy.  Questions or comments should be directed to privacy@soomla.com

SOOMLA Inc.
260 MADISON AVE, SUITE 204
NEW YORK, NY 10016 United States

Last Updated: June 19th, 2019

Effective Date: June 19th, 2019