Effective date: 10/13/2020
Welcome to Laylo, Inc.
Laylo, Inc. (“us”, “we”, or “our”) operates https://laylo.com (hereinafter referred to as
safeguard and disclose information that results from your use of our Service.
SERVICE means the https://laylo.com website operated by Laylo, Inc.
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 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:
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:
First name and last name
Address, State, Province, ZIP/Postal code, City
Cookies and Usage 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.
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 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.
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
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:
Session Cookies: We use Session Cookies to operate our Service.
Preference Cookies: We use Preference Cookies to remember your preferences and various settings.
Security Cookies: We use Security Cookies for security purposes.
Advertising Cookies: Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.
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:
to provide and maintain our Service;
to notify you about changes to our Service;
to allow you to participate in interactive features of our Service when you choose to do so;
to provide customer support;
to gather analysis or valuable information so that we can improve our Service;
to monitor the usage of our Service;
to detect, prevent and address technical issues;
to fulfill any other purpose for which you provide it;
to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
to provide you with notices about your account and/or subscription, including expiration and renewal notices, email-instructions, etc.;
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;
in any other way we may describe when you provide the information;
for any other purpose with your consent.
6. Retention of Data
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.
8. Disclosure of Data
We may disclose personal information that we collect, or you provide:
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. 2.
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:
to our subsidiaries and affiliates;
to contractors, service providers, and other third parties we use to support our business;
to fulfill the purpose for which you provide it;
for the purpose of including your company’s logo on our website;
for any other purpose disclosed by us when you provide the information;
with your consent in any other cases;
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:
the right to access, update or to delete the information we have on you;
the right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete;
the right to object. You have the right to object to our processing of your Personal Data;
the right of restriction. You have the right to request that we restrict the processing of your personal information;
the right to data portability. You have the right to be provided with a copy of your Personal Data in a structured, machine-readable and commonly used format;
the right to withdraw consent. You also have the right to withdraw your consent at any time where we rely on your consent to process your personal information;
Please note that we may ask you to verify your identity before responding to such requests. Please note, we may not able to provide Service without some necessary data.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
11. Your Data Protection Rights under the California Privacy Protection Act (CalOPPA)
According to CalOPPA we agree to the following:
users can visit our site anonymously;
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:
What personal information we have about you. If you make this request, we will return to you:
The categories of personal information we have collected about you.
The categories of sources from which we collect your personal information.
The business or commercial purpose for collecting or selling your personal information.
The categories of third parties with whom we share personal information.
The specific pieces of personal information we have collected about you.
A list of categories of personal information that we have sold, along with the category of any other company we sold it to. If we have not sold your personal information, we will inform you of that fact.
A list of categories of personal information that we have disclosed for a business purpose, along with the category of any other company we shared it with.
To delete your personal information. If you make this request, we will delete the personal information we hold about you as of the date of your request from our records and direct any service providers to do the same. In some cases, deletion may be accomplished through de-identification of the information. If you choose to delete your personal information, you may not be able to use certain functions that require your personal information to operate.
To stop selling your personal information. We do not sell your personal information for monetary consideration. However, under some circumstances, a transfer of personal information to a third party, or within our family of companies, without monetary consideration may be considered a “sale” under California law.
If you submit a request to stop selling your personal information, we will stop making such transfers. If you are a California resident, to opt-out of the sale of your personal information, send an email to [email protected]
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.
Please note, if you ask us to delete or stop selling your data, it may impact your experience with us, and you may not be able to participate in certain programs or membership services which require the usage of your personal information to function. But in no circumstances, we will discriminate against you for exercising your rights.
To exercise your California data protection rights described above, please send your request(s) by one of the following means:
By email: [email protected]
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 (“Service Providers”), provide Service on our behalf, perform Service-related services or assist us in analysing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
We may use third-party Service Providers to monitor and analyze the use of our
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en
We also encourage you to review the Google's policy for safeguarding your data: https://support.google.com/analytics/answer/6004245.
Firebase is analytics service provided by Google Inc.
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
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/
15. CI/CD tools
We may use third-party Service Providers to automate the development process of our service.
GitHub is provided by GitHub, Inc.
GitHub is a development platform to host and review code, manage projects, and build software.
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.
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.
16. Behavioral Remarketing
Google Ads (AdWords)
Google Ads (AdWords) remarketing service is provided by Google Inc.
You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt- out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en
Twitter remarketing service is provided by Twitter Inc.
You can opt-out from Twitter's interest-based ads by following their instructions: https://support.twitter.com/articles/20170405
Facebook remarketing service is provided by Facebook Inc.
You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950
To opt-out from Facebook's interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217
Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.
For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation
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).
The payment processors we work with are:
PayPal or Braintree:
18. Links to Other Sites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
19. Children's Privacy
Our Services are not intended for use by children under the age of 13 (“Children”).
We do not knowingly collect personally identifiable information from Children under 13. If you become aware that a Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information from our servers.
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.
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.
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]
INSTANT EU GDPR REPRESENTATIVE LTD Office 2,
12A Lower Main Street, Lucan Co. Dublin
K78 X5P8 Ireland
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