This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.
We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.
Interpretation and Definitions.
Interpretation
The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
Definitions
For the purposes of this Privacy Policy:
- Account means a unique account created for You to access our Service or parts of our Service.
- Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
- Application refers to app.vissibl.com, the software program provided by the Company.
- Business, for the purpose of CCPA/CPRA, refers to the Company as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information, that does business in the State of California.
- CCPA and/or CPRA refers to the California Consumer Privacy Act (the "CCPA") as amended by the California Privacy Rights Act of 2020 (the "CPRA").
- Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Vissibl Technology Limited, Unit 147, Innovation Hub, Gate Avenue, South Zone, DIFC. For the purpose of the GDPR, the Company is the Data Controller.
- Consumer, for the purpose of the CCPA/CPRA, means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.
- Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
- Country refers to: United Arab Emirates.
- Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
- Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
- Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.
- GDPR refers to EU General Data Protection Regulation.
- DIFC DPL refers to the Dubai International Financial Centre Data Protection Law.
- Personal Data is any information that relates to an identified or identifiable individual. For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity. For the purposes of the CCPA/CPRA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.
- Service refers to the Application or the Website or both.
- Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.
- Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
- Website refers to Vissibl, accessible from vissibl.com.
- You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable. Under GDPR, You can be referred to as the Data Subject or as the User.
Collecting and Using Your Personal Data.
Types of Data Collected
Personal Data
While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:
- Email address
- First name and last name
- Phone number
- Address, State, Province, ZIP/Postal code, City
- Usage Data
Usage Data
Usage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.
Information Collected while Using the Application
While using Our Application, in order to provide features of Our Application, We may collect, with Your prior permission:
- Information regarding your location
We use this information to provide features of Our Service, to improve and customize Our Service. The information may be uploaded to the Company's servers and/or a Service Provider's server or it may be simply stored on Your device. You can enable or disable access to this information at any time, through Your Device settings.
Tracking Technologies and Cookies
We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:
- Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
- Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics.
Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.
We use both Session and Persistent Cookies for the purposes set out below:
- Necessary / Essential Cookies (Session, administered by Us), essential to provide You with services available through the Website and to enable You to use some of its features, including to authenticate users and prevent fraudulent use of user accounts.
- Cookies Policy / Notice Acceptance Cookies (Persistent, administered by Us), identify if users have accepted the use of cookies on the Website.
- Functionality Cookies (Persistent, administered by Us), allow us to remember choices You make when You use the Website, such as remembering your login details or language preference.
- Tracking and Performance Cookies (Persistent, administered by Third-Parties), used to track information about traffic to the Website and how users use the Website.
Use of Your Personal Data
The Company may use Personal Data for the following purposes:
- To provide and maintain our Service, including to monitor the usage of our Service.
- To manage Your Account: to manage Your registration as a user of the Service.
- For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
- To contact You: by email, telephone calls, SMS, or other equivalent forms of electronic communication regarding updates or informative communications related to the functionalities, products or contracted services, including security updates.
- To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
- To manage Your requests: To attend and manage Your requests to Us.
- To deliver targeted advertising to You: We may use Your information to develop and display content and advertising tailored to Your interests and/or location and to measure its effectiveness.
- For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets.
- For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.
We may share Your personal information in the following situations:
- With Service Providers to monitor and analyze the use of our Service, to advertise on third party websites to You after You visited our Service, for payment processing, and to contact You.
- For business transfers: in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition.
- With Affiliates: who we will require to honor this Privacy Policy.
- With business partners to offer You certain products, services or promotions.
- With other users: when You share personal information or otherwise interact in the public areas with other users.
- With Your consent for any other purpose.
Retention of Your Personal Data
The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.
Transfer of Your Personal Data
Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. This information may be transferred to, and maintained on, computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.
Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.
The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.
Delete Your Personal Data
You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You. Our Service may give You the ability to delete certain information about You from within the Service.
You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us. Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.
Disclosure of Your Personal Data
Business Transactions
If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.
Law enforcement
Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Other legal requirements
The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
- Comply with a legal obligation
- Protect and defend the rights or property of the Company
- Prevent or investigate possible wrongdoing in connection with the Service
- Protect the personal safety of Users of the Service or the public
- Protect against legal liability
Security of Your Personal Data
The security of Your Personal 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.
Detailed Information on the Processing of Your Personal Data.
The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.
Analytics
- Google Analytics, a web analytics service offered by Google that tracks and reports website traffic. You can opt-out by installing the Google Analytics opt-out browser add-on.
- Firebase, an analytics service provided by Google Inc.
Email Marketing
We may use Your Personal Data to contact You with newsletters, marketing or promotional materials. You may opt-out by following the unsubscribe link in any email We send or by contacting Us. We may use Mailchimp to manage and send emails.
Payments
We may provide paid products and/or services within the Service. We will not store or collect Your payment card details, that information is provided directly to Our third-party payment processors (e.g. Stripe) whose use of Your personal information is governed by their Privacy Policy and PCI-DSS standards.
Behavioral Remarketing
The Company uses remarketing services (Google Ads, Facebook, LinkedIn) to advertise to You after You accessed or visited our Service. You can opt-out using each provider's settings or the NAI, EDAA and DAA opt-out platforms.
GDPR Privacy.
Legal Basis for Processing Personal Data under GDPR
- Consent
- Performance of a contract
- Legal obligations
- Vital interests
- Public interests
- Legitimate interests
Your Rights under the GDPR
- Request access to Your Personal Data
- Request correction of the Personal Data that We hold about You
- Object to processing of Your Personal Data
- Request erasure of Your Personal Data
- Request the transfer of Your Personal Data
- Withdraw Your consent
You may exercise Your rights by contacting Us. You also have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data.
CCPA/CPRA Privacy Notice (California Privacy Rights).
This section supplements the information contained in Our Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California.
Categories of Personal Information Collected
We may collect categories of personal information defined in the CCPA/CPRA including Identifiers (Category A), California Customer Records information (Category B), Commercial information (Category D), Internet or other similar network activity (Category F), Geolocation data (Category G), and Sensitive personal information (Category L).
Your Rights under the CCPA/CPRA
- The right to notice
- The right to know/access
- The right to opt-out of the sale or sharing of Personal Data
- The right to correct Personal Data
- The right to limit use and disclosure of sensitive Personal Data
- The right to delete Personal Data
- The right not to be discriminated against
To exercise any of Your rights under the CCPA/CPRA, You can contact Us by email at security@vissibl.com or via our contact page.
Do Not Sell My Personal Information
We do not sell personal information as the term sell is commonly understood. We do allow Service Providers to use Your personal information for the business purposes described in Our Privacy Policy, for activities such as advertising, marketing, and analytics, and these may be deemed a sale under CCPA/CPRA. You have the right to opt-out of the sale of Your personal information by contacting Us.
"Do Not Track" Policy as Required by CalOPPA.
Our Service does not respond to Do Not Track signals.
Children's Privacy.
Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.
Links to Other Websites.
Our Service may contain links to other websites that are not operated by Us. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
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 and update the "Last updated" date at the top of this Privacy Policy.
Contact Us.
If you have any questions about this Privacy Policy, You can contact us:
- By email: security@vissibl.com