InJoy Global Privacy Policy
Effective Date: August 17, 2016
We want to thank you for using InJoy Global’s products, services, websites, and products. Our customers are the most important aspect of our business and we appreciate you looking to InJoy Global to further your business. InJoy Global offers our customers an online platform to create programs to support their digital businesses. The entire selection of products, services and tools offered on our platform are our “Product.”
This Privacy Policy applies to your use of our Product and including your use of the “Challenge Creator” customer mobile application, which enables our users to build their own “challenge” scenarios for their clients and communities.
The terms "we", "us", "our" and "Company" refer to InJoy Global, Inc., a Nevada corporation. "You" or "your" refers to the person or company who uses the Product. Your use of the Product is governed by Privacy Policy as it exists at the time of your use. We reserve the right to change this Privacy Policy in the future without notice, as described below
GENERAL POLICIES
By accessing the Product, you agree to the terms of this Privacy Policy and expressly consent to the processing of personal information and session data according to the terms contained herein. By using our Product, you accept the policies and restrictions set forth in this Privacy Policy. If you do not agree to this policy, please do not use the Product.
This Privacy Policy is incorporated into and subject to the applicable Terms of Service[link] and Acceptable Use Policy[link].
Consent
Voluntarily submitting personal information constitutes your consent for InJoy Global to use the information for the purpose stated and indicates to us that you are aware of this Privacy Policy’s provisions.
If you have any questions or unresolved privacy concerns, please contact us at [email protected]
Information that We Collect
- You give permission to those third parties to share your information with us or where you have made that information publicly available online.
- You create or log into your account through a third-party social networking site or one of our integration partners, we will have access to certain information from that service such as your name and account information.
- If you subscribe to our Product, we may receive information from our third-party payment processors.
- We may collect information from unaffiliated third parties so that we can better understand you and provide you with information and offers that may interest you.
How We Use the Information We Collect
Use of Information: We may use the personal information collected through our Product to:
- Operate and improve our Product;
- Send you advertising or promotional materials;
- Provide and deliver the Product or other services you request, process transactions, and send you related information;
- Send you technical notices, updates, security alerts, and support and administrative messages;
- Respond to your comments, questions, and requests and provide you with requested customer support;
- Monitor and evaluate trends, usage, and activities in connection with our Product;
- Secure our systems, prevent fraud, and help us to protect the security of your account;
- Prevent, detect, and investigate potentially prohibited or illegal activities and to enforce our terms and policies;
- Personalize and improve the Product, and provide content, communications, or features that match users interests; and
- Link or combine with other information we obtain from third parties to help understand your needs and provide you with better service.
We reserve the right at all times to review your content and information to help resolve problems with our software or Product, or to ensure that you remain in compliance with our Terms of Service[link] and Acceptable Use Policy[link].
Information we may share: We do not “sell” your personal information (as that term is defined in the California Consumer Privacy Act). However, we may share your personal information with third parties as follows:
- Authorized Service Providers: We use other companies, agents, or contractors to perform services on our behalf or to assist us with the provision of services to you. For example, we engage service providers to provide marketing, advertising, communications, security, payment processing, infrastructure and IT services, to customize, personalize, and optimize our Product, to process payment transactions, to provide customer service, and to analyze and enhance data. To provide the services, these service providers may have access to your personal information. These service providers have agreed to maintain the confidentiality, security, and integrity of the personal information that they obtain from us and we do not authorize them to use or disclose your personal information except in connection with providing their services.
- Protection of Injoy Global and others: Injoy Global and its service providers may disclose and otherwise use your personal information where we or they reasonably believe such disclosure is needed to (i) satisfy and applicable law, regulation, legal process, or governmental request; (ii) enforce applicable terms of use, including investigation of potential violations; (iii) detect, prevent, or otherwise address illegal or suspected illegal activity, security, or technical issues; or (d) protect against harm to the rights, property, safety of Injoy Global, our users, or the public, as required or permitted by law.
- Business transfers: In connection with any reorganization, restructuring, merger, or sale, or other transfer of assets, we will transfer information, including personal information, provided that the receiving party agrees to respect your privacy in a manner that is consistent with our Privacy Policy.
- Other Users: Content that you create, upload, or copy into our Product, may, if you choose, be read, copied, used, and distributed by people you know, your members, or people you don’t know. Information that you disclose using the chat function of the Product may be read, copied, used, and distributed by people participating in the chat. Use care when including sensitive information, such as home addresses or phone numbers, in content you share or chat sessions.
- With Your Consent: We may share your personal information when we have your consent.
We may allow others to provide analytics services for our Product. These providers (for example, Google Analytics) may use cookies, web beacons, device identifiers, and other tracking technologies that collect information about your use of our Product. This information may be used by us and others to determine the popularity of our Product, deliver advertising and content targeted to your interests in the Product, and on other websites, apps, and other services, and to better understand your online activity. You can opt out of Google Analytics by visiting https://tools.google.com/dlpage/gaoptout.
Where We Store Your Personal Data
Data Storage: All data that you provide to use through our Product is stored on secure servers located in the United States. Any payment transactions will be encrypted using SSL technology; all payment data is stored by our payment processors and is never stored on our servers. Where we have given you (or where you have chosen) a password that enables you to access your account and the Product, you are responsible for keeping this password confidential. We recommend that you not share your password and that you change it frequently.
Data Security: Injoy Global takes reasonable measures to protect your personal information and your content from loss, misuse, and unauthorized access, disclosure, modification, and destruction and to ensure that your content remains protected and available to you. Unfortunately, the transmission of data via the internet is not completely secure and although we do our best to protect your personal data, we cannot guarantee the security of your data transmitted through the Product. All transmissions are at your own risk.
Data Retention: Injoy Global stores the information we collect for as long as necessary for the purpose for which it was originally collected and in compliance with our legal obligations. The retention periods applied by Injoy Global comply with applicable legislation then in effect, namely:
- For data relating to your account, such data will not be retained beyond your request that your account be deleted.
- For transactional data relating to your purchases, such data is kept for the entire period of our contractual relationship, then in accordance with legal obligations and applicable statute of limitations periods. Please note that this data does not include payment card information, which is processed by our third-party payment processors and not InJoy Global.
- For data collected based on your consent to receive marketing communications, we will use the data until you withdraw your consent or applicable law requires that such data is no longer used.
- For data collected in connection with your requests or questions, such data is kept for the period necessary to process and reply to your request or question.
- When cookies or other trackers are placed on your computer, they may be retained for a period of 12 months.
We may retain certain information for legitimate business purposes or as required by law.
Third Parties
Third parties who provide and/or publish content via our Product shall be deemed the data controllers for any personal data contained in the content uploaded by any such party to the Product (“Third-Party Content”) and any other personal data processed in relation to such Third-Party Content. This Privacy Policy only concerns the processing for which InJoy Global is the data controller. If you have any questions regarding personal data contained in Third-Party Content, please contact the third-party provider responsible for such Third-Party Content.
Children Age 16 and Under
The Product is not directed at children under the age of 16 and we never knowingly collect personal information from children. We recognize the special obligation to protect personal information obtained from children age 13 and under. IF YOU ARE 16 YEARS OLD OR YOUNGER, THE COMPANY REQUESTS THAT YOU NOT SUBMIT ANY PERSONAL INFORMATION TO THE SITE OR TO INJOY GLOBAL. If we discover that a child age 16 or younger has signed up for our Product or provided us with personal information, we will delete that child’s identifiable information from our records.
How We Use “Cookies” and Other Tracking Technologies
Cookies are files that web servers place on an Internet user’s browser that are designed to store basic information, such as visitor preferences. The use of cookies on a website allows visitors to enjoy more seamless visits and more accurately measures visitor behavior on a website.
The cookies used on the Website do not identify you personally. They merely recognize your browser, unless you choose to identify yourself voluntarily. You may choose to identify yourself for the following reason: So the browser will remember your username and password.
We may use session and persistent cookies. Session cookies exist only during an Internet user’s online session. They disappear (or expire) from the user’s computer when he/she closes the browser software.
Persistent cookies remain on the user’s browser after the browser has been closed. We may place persistent cookies on your web browser to remember your information and settings when you visit our Website at a future date. This makes your experience more convenient, meaningful, and relevant. When you come to the Website, our web server uses persistent cookies to improve your interaction with the Website by, for example, remembering your preferences and dynamically serving more relevant content to you. We use cookies to identify the fact that you are one of our customers or a prior visitor (as applicable). Visitors who disable their web browsers’ ability to accept cookies will still be able to browse a website, however, they may lose some of the functionality provided by the use of cookies.
We may also use first-party and third-party cookies. First-party cookies are served directly by a website to your computer’s browser and are only used by the website operator, who recognizes your computer when you revisit a website. Third-party cookies are served to your computer through one of our service providers on behalf of a website operator.
You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. For further information about disabling cookies you can visit www.allaboutcookies.org. If you choose to decline cookies, you may not be able to login or use other interactive features of our Website and services that depend on cookies.
Your Choices and Rights
Subject to applicable law, we will make reasonable efforts to ensure your collected personal information is accurate and complete and we will update or correct your information as needed when notified by you. If you would like to request access to your personal information, request to verify your personal information, identify any inaccuracy in your personal information, or change or delete your personal information, please contact us at [email protected] We strive to respond to these requests with 30 days or as required in accordance with applicable law.
Whenever you directly provide us with your personal information, please be sure it is accurate and complete. We cannot be responsible for any information you provide to us that is incomplete or incorrect.
We will not collect, use, or disclose your personal information in any ways or for any purposes that are materially different from those set forth herein. However, if we wish to do so in the future, we will obtain your consent first, and offer you the choice to opt-out of such proposed collection, use, or disclosure.
In addition, you have several options with respect to your personal information, as follows:
- You may terminate your use of the Product at any time. However, please note that InJoy Global may still process your personal information as a service provider to our customers if your personal data.
- If you have created an account, you may at any time access, edit, or delete your personal information. Please note that even if you delete information from your account, or deactivate your account, we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of your information for a certain period of time.
- You may opt out of receiving promotional emails, text messages, or mail from InJoy Global by visiting your user settings via the “Edit Your Preferences” or “Completely Unsubscribe” link in any promotional email or make this request via email to [email protected] If you opt out, we may still send you transactional or relationship messages, such as emails about your account or updates to our Product.
- If you do not have a user account and wish to delete your email address or other personal information that you might have provided through your use of our Product and/or any other services, please email us at [email protected] with the words “Delete My Information” in the subject line.
Links to External Sites
Our Product may, from time to time, contain links to and from third party websites, such as partners, affiliates, and advertisers. If you follow a link to any external website, it will have its own privacy policy and we are not responsible for the content or practices of such third-party websites or their policies. We are also not responsible for any information that you might share with such linked websites. You should refer to each website’s respective privacy policy and practices before you submit any personal information.
Data Posted on Forums
Product users may have the ability to post content to one or more Product or other forums sponsored by Injoy Global, such as chat rooms and bulletin boards. You should be aware that when you voluntarily disclose personal information in any forum, that information can be collected and used by others and may result in unsolicited messages from other people. You are responsible for the personal information you choose to submit in these instances. Please take care when using these features. You may request and obtain removal of such posted content by contacting us at [email protected] and specifically identifying the content to be removed. Please be advised that any such removal does not ensure complete or comprehensive removal of all traces of the content posted on the our forums.
Located in the United States
For users located outside the jurisdiction of the United States, InJoy Global operates and processes data in the United States. Information we collect from you will be processed in the United States, and by using this website you acknowledge and consent to the processing of your data in the United States. The United States has not received a finding of “adequacy” from the European Union under Article 41 of the GDPR. We collect and transfer to the US personal data only with your consent; to perform a contract with you; or to fulfill a compelling legitimate interest of ours in a manner that does not outweigh your rights and freedoms. Please be aware that the United States and jurisdictions other than the one in which you are located may not provide the same level of data protection as considered adequate in your country. Note also that your personal information may be available to the US Government or its agencies under legal process in the United States.
If your business operates within the European Economic Area (EEA), United Kingdom or Switzerland, as an InJoy Global customer you are operating as a “data controller” of “personal data” of “data subjects” located in the EEA (as those terms are defined in the European General Data Protection Regulation 2016/679 (GDPR)). By requesting the Product and agreeing to these Terms, you are providing us with instructions to process any personal data collected by you through our Product on your behalf. You shall ensure and hereby warrant and represent that you are entitled to transfer personal data to InJoy Global so that we may lawfully process and transfer the personal data in accordance with these Terms. You shall ensure that relevant data subjects have been informed of, and have given their consent to, such use, processing, and transfer as required by all applicable data protection laws and have sole responsibility for the accuracy, quality and legality of personal data processed by us in the provision of the Product.
California Privacy Rights
Nevada Privacy Rights
European Economic Area, UK and Swiss Privacy Rights
For residents of the European Economic Area (EEA), United Kingdom (UK) or Switzerland, we advise that your personal information will be transferred to and processed in the United States, which has data protection laws that are different than those in your country and may not be as protective. The United States has not sought or received a finding of “adequacy” from the European Union under Article 45 of the General Data Protection Regulation (GDPR). Our legal basis for collecting and using your personal information is to do so with your consent; where we need the personal information for performance of a contract or requested service, or where the collection and use is in our or another’s legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect the personal information in question. If we collected your personal information with your consent, you may withdraw your consent at any time.
Our retention of your personal information and any subsequent communications are based on our legitimate interest in providing you with new and potentially relevant materials based on your geography, role, or company. As always, you can elect to opt out from receiving such future communications.
To the extent that we transfer personal information from the EEA, UK or Switzerland to a jurisdiction outside those countries that has not been adduced by the European Commission as providing adequate data protections (such as the United States), we will ensure that such personal information is safeguarded through appropriate contractual terms or other approved mechanisms.
Rights for EEA/UK/Swiss Residents - If you are a resident of the EEA, UK or Switzerland, you have the right to:
- Find out if we use your personal information, to access your personal information and receive copies of your personal information.
- Withdraw any express consent that you have provided to the processing of your personal information at any time without penalty.
- Access your personal information and have it corrected or amended if it is inaccurate or incomplete.
- Obtain a transferable copy of some of your personal information which can be transferred to another provider when the personal information was processed based on your consent.
- If you believe your personal information is inaccurate, no longer necessary for our business purposes, or if you object to our processing of your personal information, you also have the right to request that we restrict the processing of your data pending our investigation and/or verification of your claim.
- Request your personal information be deleted or restricted under certain circumstances. For example, if is using your personal information on the basis of your consent and has no other legal basis to use such, you may request your personal information be deleted when you withdraw your consent.
Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
If we ask you to provide personal information to us to comply with a legal requirement or enter into a contract, we will inform you of this and let you know whether providing us with your personal information is required and if not, the consequences of not sharing your personal information with us.
Similarly, if we collect and use your personal information in reliance on our or a third party's legitimate interests and those interests are not already described above, we will let you know what those legitimate interests are.
We endeavor to apply suitable safeguards to protect the privacy and security of your personal information and to use it only consistent with your relationship with us and the practices described in this Privacy Policy.
To withdraw consent or exercise these rights, please contact us via email at [email protected]
If you are not satisfied with our response, or believe we are processing your personal information in violation of the law, you have the right to lodge a complaint with the Supervisory Authority (also known as Data Protection Authority) or other appropriate governmental authority in your EEA Member State. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.
Do Not Track Disclosure
We currently do not process or comply with any web browser’s “do-not-track” signal or other similar mechanism that indicates a request to disable online tracking of individual users who visit the Product or visit an Injoy Global website.
Changes to Our Privacy Policy
We may update this Privacy Policy to reflect changes to our data practices. If we make any material changes, we may notify you by email (sent to the email address specified in your account) or by means of a notice on our website or in the Product prior to becoming effective. We encourage you to periodically review this page for the latest data on our privacy practices.
Contact Information for Complaints or Concerns
We welcome your questions, comments, and requests regarding our Privacy Policy. Written questions or comments regarding this Policy should be submitted to InJoy Global as follows:
Your Acceptance of These Terms
By using our website or Product, you accept the policies and restrictions set forth in this Privacy Policy. If you do not agree to this policy, please do not use the website or the Product.