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🕵️‍♀️ Privacy and GDPR Policy

Below you can find our Privacy Policy

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Written by Alec Ellin

Effective date: 10/20/2024

Privacy Policy

1. Introduction

Welcome to Laylo, Inc. Laylo, Inc. (“Laylo”, “us”, “we” or “our”) operates https://laylo.com.

Our Privacy Policy governs your visit to https://laylo.com on all platforms, and explains how we collect, safeguard and disclose information that results from your use of our Service.

We use your data to provide and improve Service. We are a United States corporation subject to the laws of the United States. The United States may not offer a level of privacy protection as great as that offered in other jurisdictions. Since our servers are located in the United States, your data may be transferred to, stored, or processed in the United States. By using Service, you agree to the collection and use of information in accordance with this Privacy Policy and you understand and consent to the collection, storage, processing, and transfer of your data to our facilities in the United States and those third parties we share your data with as described in this Privacy Policy and our Terms of Service. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms of Service.

Our Terms of Service (“Terms”) govern all use of our Service and together with the Privacy Policy constitutes your agreement with us (“agreement”).

2. Definitions

SERVICE meansour web pages located at https://laylo.com and all of our services, software, technical and communications platform(s) available on and through our website or otherwise on all platforms.

PERSONAL DATA means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

USAGE DATA is data collected automatically either generated by the use of Service or from Service infrastructure itself (for example, the duration of a page visit).

COOKIES are small files stored on your device (computer or mobile device).

DATA CONTROLLER means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your data.

DATA PROCESSORS (OR SERVICE PROVIDERS) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

DATA SUBJECT is any living individual who is the subject of Personal Data.

THE USER is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.

3. Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

4. 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 (“Personal Data”). Personally identifiable information may include, but is not limited to:

  1. Email address

  2. First name and last name

  3. Phone number

  4. Address, State, Province, ZIP/Postal code, City

  5. Cookies and Usage Data

  6. Purchase Data

  7. Billing Information

  8. Social Media Data

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link.

From time to time, we may share aggregate or de-identified information about use of the Service and individuals. We may disclose such aggregate or de-identified information to any third party, including our customers, business partners, promotional partners, sponsors, advertisers and for other business purposes as described in the agreement.

All the above categories exclude text messaging originator opt-in data and consent; your Personal Data will not be shared with any third parties, excluding aggregators and providers of the Messages (as defined in the Terms) services.

Non-Personal Data

While using our Service, we may ask you to provide us with certain Non-Personal Data. “Non-Personal Data” is any information not relating to an identified or identifiable natural person. Non-Personal Data we may collect includes:

  1. Usage Data: as more fully explained below.

  2. Cookies and Tracking Technologies: as more fully explained below.

  3. Aggregate Information: data about how you use the Service combined with data about how others use the Service in order to help us better develop new features and tailor the Service.

Usage Data

We may also collect information that your browser sends whenever you visit our Service or when you access Service by or through a mobile device (“Usage Data”).

This Usage Data may include information such as your computer'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, plug- ins, add-ons, location, the version of the Service you are using and other diagnostic data.

When you access Service with a mobile device, this Usage Data may include information such as 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.

Location Data

We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Service, to improve and customize our Service.

You can enable or disable location services when you use our Service at any time by way of your device settings.

Tracking Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device.

Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Service.

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 portions of our Service.

Examples of Cookies we use:

  1. Session Cookies: We use Session Cookies to operate our Service.

  2. Preference Cookies: We use Preference Cookies to remember your preferences and various settings.

  3. Security Cookies: We use Security Cookies for security purposes.

  4. Advertising Cookies: Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.

Other Data

While using our Service, we may also collect the following information: sex, age, date of birth, place of birth, passport details, citizenship, registration at place of residence and actual address, telephone number (work, mobile), details of documents on education, qualification, professional training, employment agreements, non-disclosure agreements, information on bonuses and compensation, information on marital status, family members, social security (or other taxpayer identification) number, office location and other data.

5. Use of Data

Laylo, Inc. uses the collected data for various purposes:

  1. to provide and maintain our Service;

  2. to notify you about changes to our Service;

  3. to allow you to participate in interactive features of our Service when you choose to do so;

  4. to provide customer support;

  5. to gather analysis or valuable information so that we can improve our Service;

  6. to monitor the usage of our Service;

  7. to detect, prevent and address technical issues;

  8. to fulfill any other purpose for which you provide it;

  9. to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;

  10. to provide you with notices about your account and/or subscription, including expiration and renewal notices, email-instructions, etc.;

  11. 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;

  12. in any other way we may describe when you provide the information;

  13. for any other purpose with your consent.

6. Retention of Data

We 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 (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, 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.

7. Transfer of Data

Your information, including Personal Data, 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 from those of your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Laylo, Inc. will take all the 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.

8. Disclosure of Data

We may disclose personal information that we collect, or you provide:

(a) Disclosure for Law Enforcement.

Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities.

(b)Business Transaction.

If we or our subsidiaries are involved in a merger, acquisition or asset sale, your Personal Data may be transferred.

Other cases. We may disclose your information also:

  1. to our subsidiaries and affiliates;

  2. to contractors, service providers, and other third parties we use to support our business;

  3. to fulfill the purpose for which you provide it;

  4. for the purpose of including your company’s logo on our website;

  5. for any other purpose disclosed by us when you provide the information;

  6. with your consent in any other cases;

  7. if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.

9. 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.

10. 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 [email protected].

In certain circumstances, you have the following data protection rights:

  1. the right to access, update or to delete the information we have on you;

  2. the right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete;

  3. the right to object. You have the right to object to our processing of your Personal Data;

  4. the right of restriction. You have the right to request that we restrict the processing of your personal information;

  5. 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;

  6. 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).

11. 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 Privacy 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:

  1. users can visit our site anonymously;

  2. 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;

  3. users will be notified of any privacy policy changes on our Privacy Policy Page;

  4. users are able to change their personal information by emailing us at [email protected].

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.

12. 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:

(a) What personal information we have about you. If you make this request, we will return to you:

  1. The categories of personal information we have collected about you.

  2. The categories of sources from which we collect your personal information.

  3. The business or commercial purpose for collecting or selling your personal information.

  4. The categories of third parties with whom we share personal information.

  5. The specific pieces of personal information we have collected about you.

  6. 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.

  7. 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.

(b) 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.****

(c) 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 [email protected].

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:

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.

13. Service Providers

We may employ third party companies and individuals to facilitate our Service and/or that help us promote, provide, or support our Service or the services of our customers (“Service Providers”), provide Service on our behalf, perform Service-related services or assist us in analyzing 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.

14. 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 contextualize and personalize 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.

Segment.io

Segment.io is a web traffic analysis tool. You can read the Privacy Policy for Segment.io here: https://segment.com/legal/privacy/.

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/.

15. 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/.

16. Advertising

We may use third-party Service Providers to show advertisements to you to help support and maintain our Service.

Opting Out of Receiving Email Communications from Us

If you no longer want to receive marketing-related emails from us, you may opt-out via the unsubscribe link or by notifying us at [email protected]. We may still send you important messages regarding administrative matters, updates, disputes, and customer service issues that are required to provide you with the Service.

Opting Out of Receiving SMS Messages from Us.

Laylo offers you mobile alerts regarding its and/or its business partners’, customers’, vendors’, event organizers’, suppliers’, advertisers’ or sponsors’ information, migrations, products, events, marketing, advertising, and promotions by SMS messaging (“SMS Messaging”). Enrollment in SMS Messaging requires you to provide your mobile phone number and agree to this Privacy Policy and Laylo’s Terms of Service before the SMS Messaging starts. To stop receiving SMS Messaging from Laylo, reply with STOP to any SMS Messaging you received from Laylo or use the unsubscribe link we may provide within any of Laylo’s SMS Messaging. This is the exclusive method for opting out. After texting STOP to Laylo, you may receive one additional message confirming that your request has been processed. Text HELP to any SMS Messaging you received from Laylo for support.

Cookies and Other Tracking Technologies

Laylo and/or its business partners, customers, vendors, event organizers, suppliers, advertisers or sponsors may use cookies and other tracking technologies such as pixels and web beacons on the Service to administer the Service, track your movements around the Service, analyze trends, serve targeted advertisements, and gather demographic information. You can control the use of cookies at the individual browser level. Our third-party partners may use cookies or other tracking technologies to provide you advertising on other sites based upon your browsing activities and interests. If you want to opt-out of interest-based advertising, please visit http://preferences-mgr.truste.com/, or if located in the European Union, visit http://www.youronlinechoices.eu.

Web Beacons

When we send emails to customers and/or users, we may use web beacons to track who opened the emails and clicked links to measure campaign performance and improve features for our customers and/or users. We also use web beacons in the emails we deliver for our customers and/or users to create reports about campaign performance and determine what actions our subscribers and/or users took.

Our Relationship with Subscribers

Our customers may import into the Services Personal Data they have collected from their subscribers or other individuals. We have no direct relationship with Customers’ subscribers or any individuals other than our customers. Customers are responsible for making sure they have the necessary permissions for us to collect, store, and process Personal Data about our customers’ subscribers or other individuals. A subscriber should unsubscribe directly from a customer’s email, newsletter or other communication or contact the customer directly to change, update, or delete the subscriber’s data. If a subscriber contacts us, we will refer you to that customer and support them in responding to your request if necessary.

Consistent with this Privacy Policy, we may transfer customer or subscriber Personal Data to our Service Providers. All Service Providers agree to protect Personal Data in accordance with this Privacy Policy.

Google AdSense DoubleClick Cookie

Google, as a third party vendor, uses cookies to serve ads on our Service. Google's use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Service or other websites on the Internet.

You may opt out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page: http://www.google.com/ads/preferences/.

17. 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, optimize 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.

X

X remarketing service is provided by X Corp.

You can opt-out from Twitter's interest-based ads by following their instructions: https://help.x.com/en/safety-and-security/privacy-controls-for-tailored-ads

You can learn more about the privacy practices and policies of Twitter by visiting their Privacy Policy page: https://x.com/privacy.

Meta

Meta remarketing service is provided by Meta Inc.

You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/business/help/182371508761821?id=176276233019487.

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.

18. 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.

19. Links to Other Sites and Public Data

Third-Party 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. When you click on links to third-party sites, you may leave the Service. This Privacy Policy does not cover any collection, use, or disclosure by third parties through any applications, websites, products, or services that we do NOT control or own, or any third-party features or services made available through the Service. By using the Service, you expressly relieve Laylo from any and all liability arising from your use of any third-party website.

The inclusion of a link or accessibility of third-party sites does not imply endorsement of such third-party site by us. All trademarks, trade names, and logos of third parties featured on the Service belong to their respective owners.

Each merchant and third-party payment processor collects and shares your information according to its own privacy policy and terms of service. Laylo is not responsible for the actions of third-party processors or merchants, including how such entities treat your information. You are responsible for knowing and understanding their policies and terms.

Public Data.

We may provide areas on the Service where you can publicly post information. This information may be read, collected, and used by anyone. We do not control or endorse the information posted by third-party users, are not liable for your or third-party posts to the Service, and specifically disclaim any liability resulting from such posts.

20. Children's Privacy

Our Service is 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.

21. Other Region and State-Specific Privacy Laws and Rights

Depending on where you live, you may have certain state or country-specific rights regarding your Personal Data. Under some of these laws and regulations, where applicable, you may have the right to access, deletion, correction, verification, portability, opt-out of tracking for targeted advertising purposes, opt-out of profiling, among other rights. To exercise any rights under these or other applicable data protection laws, please email us at [email protected].

You may also have the right to file a complaint about Laylo’s collection and processing of Personal Data. To file a complaint, contact the applicable supervisory authority or data protection authority.

22. Data Privacy Framework (EU-U.S. DPF & UK Extension)

Laylo, Inc. (“Laylo”) complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF as set forth by the U.S. Department of Commerce. Laylo has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (“Principles”) with regard to the processing of personal data received from the European Union and the United Kingdom (and Gibraltar) in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. If there is any conflict between the terms in this privacy policy and the Principles, the Principles govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

Laylo’s certification covers personal data, other than human resources data, that we receive from the European Union, the United Kingdom (and Gibraltar) in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. Laylo is not currently certified under the Swiss-U.S. Data Privacy Framework, and our DPF commitments do not extend to personal data transferred from Switzerland.

22.1 Inquiries and complaints

EU and UK individuals with DPF-related questions or complaints should first contact us at [email protected] or by mail at: Laylo, Inc., 2261 Market St PMB 4748, San Francisco, CA 94114-1612, USA. Laylo will respond within 45 days of receiving a complaint.

22.2 Independent dispute resolution (no charge)
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, Laylo commits to refer unresolved complaints concerning our handling of personal data received in reliance on the DPF to JAMS, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://www.jamsadr.com/DPF-Dispute-Resolution for more information or to file a complaint. The services of JAMS are provided to you at no cost.

22.3 Binding arbitration
Under certain conditions, more fully described in Annex I to the Principles, you may be able to invoke binding arbitration to address a complaint that has not been resolved through the other recourse mechanisms described above.

22.4 Onward transfers and accountability
Laylo is responsible for the processing of personal data it receives under the EU-U.S. DPF and the UK Extension and subsequently transfers to a third party acting as an agent on its behalf. Laylo remains liable under the Principles if its agent processes such personal data in a manner inconsistent with the Principles, unless Laylo proves that it is not responsible for the event giving rise to the damage.

22.5 Choice and opt-out
You may opt out of (i) disclosures of your personal data to non-agent third parties or (ii) uses of your personal data for purposes materially different from those for which it was originally collected or subsequently authorized. To exercise this choice, email [email protected].

22.6 Access
EU and UK individuals whose personal data we process under the Data Privacy Framework may request access to, correction of, or deletion of that data by contacting [email protected]. We will respond within 45 days.

22.7 Lawful disclosures
Laylo may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

22.8 U.S. regulatory jurisdiction
Laylo’s commitments under the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

23. 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 this page or 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.

24. Contact Us

If you have any questions about this Privacy Policy, please contact us:

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 [email protected]

Tel +35315549700

INSTANT EU GDPR REPRESENTATIVE LTD

Office 2,

12A Lower Main Street, Lucan Co. Dublin

K78 X5P8

Ireland

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