PRIVACY POLICY

Effective Date:  September 27, 2021

This Privacy Policy describes how JITSUIN, Inc. (“Jitsuin,” “we,” or “us”) and its affiliates collect, store, use and disclose personal information in connection with:

  • Your use of and interaction with our websites, which includes the website located at https://jitsuin.com/ and https://rkvst.com/, as well as any and all other applications, platforms, and social media profiles owned or operated by Jitsuin, including each of their respective mobile applications (collectively, “Sites”)
  • The products and services that we provide and on which a link to this Privacy Policy is displayed (“Services”)
  • Other interactions (e.g., customer service inquiries) that you may have with Jitsuin

This Privacy Policy also explains how you can correct or change your personal information, as well as how to exercise your rights as applicable. Please read and review this Privacy Policy. If you do not agree with the data practices described in this Privacy Policy, you should not use the Sites and/or Services.

Who We Are and How To Contact Us

We are Jitsuin, Inc., a Delaware corporation with our principal headquarters located at:

5201 Great America Parkway Suite #320
Santa Clara, CA – 95054

If you have any questions or would like to access this Privacy Policy in an alternative format, please contact us at legal@jitsuin.com.

Changes To This Privacy Policy

This Privacy Policy was last updated on the date indicated above. Our business and/or Services may change from time to time, and as a result it may be necessary for us to make changes to this Privacy Policy. We reserve the right to update or modify this Privacy Policy at any time without prior notice. However, if we make changes that we believe will materially impact this Privacy Policy or your rights, we will promptly notify you of those changes. We encourage you to review this Privacy Policy from time to time. Your continued use of the Sites and Services after any changes or revisions to this Privacy Policy will indicate your agreement to the terms of any such revised Privacy Policy.

To Whom Does This Policy Apply

When we collect personal information as a ‘data controller’, we determine the means and purpose of processing and are responsible for the processing of such personal information. This Privacy Policy applies when we are acting as such and applies to:

  • Customers: any individual who registers individually or on behalf of an entity or organization in order to use the Services.
  • Site Visitors: visitors to our Sites, including those who contact us or request a demo.

When we provide our Services, we may also process personal information on behalf of our Customers, as a service provider. This Privacy Policy does not apply to the data that Jitsuin processes on behalf of our Customers (“Customer Data”) in our capacity as a service provider or processor. In such instances, our use of personal information is strictly limited to providing our Services and governed by our Terms of Use and each respective Customer’s privacy policies and terms.

Note: this Privacy Policy does not apply to any third-party applications or software that integrate with the Services, or any other third-party products, services or businesses, where we are not the controller of your personal information.

Children’s Privacy

Jitsuin does not knowingly collect information from children under the age of 16. If you are under the age of 16, please do not submit any personal information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide personal data on our Sites or Services without their permission.

If you have reason to believe that a child under the age of 16 has provided personal data to us through the Sites or Services, please contact legal@jitsuin.com and we will endeavor to delete that information from our databases.

Personal Information We Collect

When you visit our Sites (or otherwise interact with us via the Sites) or register for our Services, the personal information we collect falls into three general categories:

  • Information you provide to us
  • Information collected automatically
  • Information we obtain from third parties.

Information You Provide to Us

You can generally visit our Sites without having to submit any personal information. However, if you wish to learn more about our Services, contact us via our chat feature or otherwise, or register to use our Services, you will be asked to provide information about yourself.

  • Requesting a Demo: if you wish to receive a demo, we will collect your email and phone number, and your first and last name and company information.
  • Communications: if you interact via our chat feature or otherwise contact us, we also process any personal information contained in those communications.
  • Registering for our Services: when you register for our Services, we will collect your email, phone number, first and last name and company information (if applicable). Our third-party PCI-compliant payment processor will collect your payment information, and we will only receive a confirmation of payment, which we then associate with your account and any relevant transactions. In addition, if you are register on behalf of a corporate Customer, you may be asked to provide the names of other individuals authorized to use the Services or for contact purposes.
  • Social Media Interaction: if you interact with our social media accounts (e.g., Twitter), we may also process your personal information via such interactions, as explained in more detail below.
  • Participating in Surveys: from time to time, we may contact you to participate in online surveys. If you do decide to participate, you may be asked to provide certain information which may include personal information. All information collected from your participation in our surveys is provided by you voluntarily. We may use such information to improve Sites and/or Services and in any manner consistent with this Privacy Policy.
  • Public Forum Use: our Services may contain interactive functionality that allows you to engage with other users on the Services, post comments to forums, to upload photographs and other content (“User Materials”), participate in surveys, and otherwise to interact with the Services and with other users. If you use any interactive functionality on our Services that request or permit you to provide us with personal information (including, for example, any Services that allow you to post User Materials on any of our Services), we collect the personal information that you provide to us in the course of using these interactive features. If you choose to submit content to any public area of the Site, such content will be considered “public” and will be visible to others.
  • Events: if you participate in an event that we sponsor or attend, you may provide us with personal information, either directly or via an event provider. In the latter case, the event provider must disclose how and why your personal information will be used at the time of collection.

Information We Collect Automatically

Device, Usage and Location Information

When you visit, download, or interact with the Sites and/or Services – even if you do not have an account – we (or authorized third parties engaged by us) automatically collect information about your use of the Sites, which consists of:

  • Device Information: information about the devices and software you use to access the Sites – primarily the internet browser or mobile device that you use, the website or source that linked or referred you to the Sites, your IP address or device ID (or other persistent identifier that uniquely identifies your computer or mobile device on the Internet), the operating system of your computer or mobile device, device screen size, and other similar technical information.
  • Usage Information: information about your interactions with the Sites and Services, including access dates and times, hardware and software information, device event information, log data, crash data, cookie data. This information allows us to understand the screens that you view, how you’ve used the Sites and/or our Services (which may include administrative and support communications with us), and other actions on the Sites. We, or our authorized third parties, automatically collect log data when you access and use the Sites, even if you have not created an account or logged in. We use this information to administer and improve the Services, analyze trends, track users’ use of the Sites, and gather broad demographic information for aggregate use.
  • Location Information: based on this information, we are also able to determine general location information.

We (and our authorized third parties) uses cookies and similar technologies in order to collect Device, Usage and Location Information. Some cookies are necessary to make the Sites and our content available to you, while others are meant to improve the Sites and Services, enable us to analyze and measure audience and traffic and view your interactions with our social media accounts. For more information on our use of cookies, please review our Cookie Statement.

Transaction Information and Activity

When you use our Services, we collect transaction information as well as information about your activity within the Services. This information is connected to your personal information and allows us to communicate with you about your transactions or use of the Services, upgrades (if applicable), provide customer service and better understand how you use our Services.

Information from Third Parties

We process personal information from third parties, which consists of data from our partners, such as transactional data from providers of payment services, App stores or SNS accounts, or information from third parties with whom we host or sponsor events. In all such cases, individuals are informed of our processing activities and/or able to choose certain preferences at the time of collection. From time to time, we may combine information we collect as described above with personal information we obtain from third parties.

We also enable Single-Sign On (“SSO”), which allows you to sign up on our Sites through a third-party application like Google or Microsoft. When you use SSO, depending on how your privacy settings are configured within those third-party applications, you authorize us to collect your authentication information, such as your username and encrypted access credentials, and other information available through the third-party application account. This Privacy Policy does not cover information collected by the third-party applications with whom we enable SSO – the collection, use and disclosure of such information by the third-party applications is governed by their respective privacy policies.

Information We Process on Behalf of Our Customers

Customer Data (including personal information) that we host, collect or otherwise process on behalf of our Customers is processed only for the purposes of providing our Services. The use and/or disclosure of such information by Jitsuin is governed by the relevant terms and agreements that we have in place with each Customer, not this Privacy Policy.

If you have any questions or concerns about how such data is handled or would like to exercise your rights, you should directly contact the Customer (i.e., the data controller) who has contracted with Jitsuin to use the Services to host or process this data. Our Customers control the Customer Data, and determine the security settings within the account, access controls and credentials and how the Customer is to be processed. We will, however, provide reasonable assistance to our Customers to address any concerns you may have, in accordance with the terms of our contract with them.

Information We Do Not Collect

We do not intentionally collect or store special categories of personal data, such as genetic data, health information, or religious information. If you are a Customer, please ensure that any such information is not shared with or disclosed to us.

How We Use Your Information and Legal Bases

We use your personal information for a number of different reasons, as further explained below.

For users located in the EEA and the U.K., we must have a valid legal basis in order to process your personal data. The main legal bases under the European Union’s General Data Protection Regulation (GDPR) that justify our collection and use of your personal information are:

  • Performance of a contract – When your personal information is necessary to enter into or perform our contract with you.
  • Consent – When you have consented to our use of your personal information via a consent form (online or offline).
  • Legitimate interests – When we use your personal information to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights.
  • Legal obligation – When we need to use your personal information to comply with our legal obligations.
  • Legal claims – When your personal information is necessary for us to defend, prosecute or make a claim.

Below are the general purposes and corresponding legal bases (in brackets) for which we may use your personal information:

  • Providing you access to and use of the Services [depending on the context, performance of a contract, legitimate interests, and in some cases, legal claims]
  • Processing and completing transactions, and sending you related information, including purchase confirmations and invoices [performance of a contract]
  • Responding to your queries and requests, or otherwise communicating directly with you [depending on the context, performance of a contract, legitimate interests, and in some cases, legal claims]
  • Improving the content and general administration of the Sites and Services, and enhancing user experience [legitimate interests]
  • Providing customer support [depending on the context, performance of a contract, legitimate interests, and in some cases, legal claims]
  • Detecting fraud, illegal activities, or security breaches [legitimate interests]
  • Providing you with notices regarding purchases or other important information [depending on the context, performance of a contract or legitimate interests]
  • Interacting with individuals and marketing our Services on social media via our social media accounts [legitimate interests]
  • Ensuring compliance with applicable laws [compliance with a legal obligation]
  • Performing system maintenance and upgrades, and enabling new features [legitimate interests]
  • Conducting statistical analyses and analytics, by monitoring and analyzing trends, usage, and activities in connection with the Sites [consent where required (e.g., third-party cookies), or legitimate interests]
  • Increasing the number of customers who use our Services through marketing and advertising [consent where required, or legitimate interests]
  • Sending marketing communications, in line with your communication preferences [consent, depending on location, and in some cases legitimate interests]
  • Providing information to regulatory bodies when legally required, and only as outlined in this Privacy Policy [legal obligation, legal claims, legitimate interests].

Referring Your Friends or Colleagues

Jitsuin allows you to provide information about your friends or colleagues through our referral Services. Our referral Services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Email addresses that you may provide for referral purposes will only be used to send your friend or colleague the content or link you request. Please do not provide such information unless you have the permission to do so.

When We Share Information

We disclose your personal information as described below.

Third-Party Service Providers

Jitsuin discloses users’ information to our third-party agents, contractors, or service providers who are hired to perform services on our behalf. These companies do things to help us provide the Sites and Services, and in some cases collect information directly. Below is an illustrative list of functions for which we may use third-party service providers:

  • Hosting and content delivery network services
  • Analytics services
  • Ad Partners
  • Social media platforms
  • Customer relations
  • Customer support services
  • Chat feature provider
  • Payment processor
  • Hosting and content delivery network services
  • Functionality and debugging services
  • Professional service providers, such as auditors, lawyers, consultants, accountants, and insurers

Business Transfers

As we continue to grow, we may purchase websites, applications, subsidiaries, other businesses, or business units. Alternatively, we may sell businesses or business units, merge with other entities and/or sell assets or stock, in some cases as part of a reorganization or liquidation in bankruptcy. As part of these transactions, we may transfer your personal information to a successor entity upon a merger, consolidation, or other corporate reorganization in which Jitsuin participates, or to a purchaser or acquirer of all or a portion of Jitsuin’s assets, bankruptcy included. We may also disclose your personal information when such a transaction is being evaluated and before it is finalized. In such cases, we enter into confidentiality and similar agreements to ensure that your information is kept confidential and that such entity is restricted to reviewing the information for the purposes of evaluating the transaction.

Anonymized or Aggregate Information

In some instances, we share anonymized information, or aggregate, non-personal information with third parties for various purposes, including (i) compliance with reporting obligations; (ii) for business or marketing purposes; (iii) to assist us and other parties in understanding our users’ interests, habits and usage patterns for certain programs, content, services, marketing and/or functionality available through the Sites and/or Services. We do not share personal information about you in this case.

Legal Obligations and Security

In addition, Jitsuin will preserve or disclose your personal information in limited circumstances (other than as set forth in this Privacy Policy), including: (i) with your consent; (ii) when we have a good faith belief it is required by law, such as pursuant to a subpoena, warrant or other judicial or administrative order (as further explained below); (iii) to protect the safety of any person and to protect the safety or security of our Sites and/or Services or to prevent spam, abuse, or other malicious activity of actors with respect to the Sites and/or Services; or (iv) to protect our rights or property or the rights or property of those who use the Sites and/or Services.

If we are required to disclose personal information by law, such as pursuant to a subpoena, warrant or other judicial or administrative order, our policy is to respond to requests that are properly issued by law enforcement within the United States or via mutual legal assistance mechanism (such as a treaty). However, if we receive information that provides us with a good faith belief that there is an exigent emergency involving the danger of death or serious physical injury to a person, we may provide information to law enforcement trying to prevent or mitigate the danger (if we have it), to be determined on a case-by-case basis.

Public Forum Use

As explained above, if you use any public forum provided via our Services, the personal information that you share will be made public. Please do not share any personal information, including sensitive information, that you do not wish others to view or access.

Links to Third-Party Sites or Applications

This Privacy Policy applies only to information collected or processed in connection with our Sites and Services, as described herein. To the extent that we include links to other websites owned and operated by third parties or other applications, the policies and procedures described here do not apply with respect to how those third-party sites or applications use your personal information.

Advertising & Marketing

We partner with a network of third-party advertising partners (“Ad Partners”) to either display advertising or to manage our advertising on other sites. Our Ad Partners use cookies and similar technologies to collect information about your activities on our Sites and other websites and provide you targeted advertising based upon your interests. Some of these Ad Partners also provide re-targeting, which will serve ads to you if you visit our Sites but take no further action, in order to remind you of our Services.

These Ad Partners generally collect information about Device, Usage and/or Location Information based on your activity on our Sites, and this information is combined with other information from your other browsing activity across the Internet.

If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by visiting http://optout.aboutads.info/ or http://optout.networkadvertising.org/. If you are located in the EEA you may visit http://www.youronlinechoices.eu/.

Please note that this will not opt you out of being served advertising, and you will continue to receive generic ads. If you allow targeted advertising, please note that our Ad Partners share the information that they collect about you with a variety of other partners, companies, and publishers as part of the advertising ecosystem.

If you are located in the EEA and/or U.K., you must opt-in to advertising cookies via our cookie consent mechanism (or banner) when you visit the Sites before we can allow any advertising cookies to be dropped.

Please see our Cookie Statement for more information.

Social Media

We use social media plugins and have a presence on some social media platforms. As explained above, through our accounts on social medial platforms, we may in some instances collect personal information when you interact with our social media accounts or otherwise communicate with us through those accounts. Any information that you post on social media is governed by each platform’s privacy notices, and any personal information that we collect via our social media accounts will be processed in accordance with this Privacy Policy.

Note that in some cases, for users in the EEA, we are joint controllers with social media partners by virtue of maintaining an account and/or using certain products that they may offer.

Analytics

We use third-party analytics services on our Sites, including via Google and HubSpot, to track how often people gain access to or read our content. Provided you have opted-in to analytics cookies (if you are in the EEA or the U.K.), have not disabled analytics cookies through your browser settings, or have not disabled Google Analytics using the Google Analytics Opt-Out tool, we use this information in the aggregate to understand what content Site Visitors and Customers find useful or interesting, so we can produce the most valuable content to meet your needs.

Please see our Cookie Statement for more information.

“Do Not Track”

We do not respond to Do Not Track (“DNT”) browser signals. For more information on DNT settings generally, please visit https://allaboutdnt.com.

How to Change Your Communication Preferences

To keep your information accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update any information in our possession that you have previously submitted via the Site and/or Services. Note that you may also manage your communications preferences and the receipt of any commercial communication by clicking the “unsubscribe” link included at the bottom of all emails from Jitsuin. You may also send an email to legal@jitsuin.com.

Access and Accuracy

We use reasonable efforts to keep your personal information accurate. If you would like to access, update or correct your personal information stored with us, please send an email to legal@jitsuin.com.

How Long Do We Keep Your Personal information?

General Retention Periods

We use the following criteria to determine our retention periods: the amount, nature and sensitivity of your information, the reasons for which we collect and process your personal data, the length of time we have an ongoing relationship with you and provide you with access to our Sites and/or Services, and applicable legal requirements. We will retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to comply with applicable legal, tax or accounting requirements). Additionally, we cannot delete information when it is needed for the establishment, exercise or defense of legal claims (also known as a “litigation hold”). In this case, the information must be retained as long as needed for exercising respective potential legal claims.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), we will securely store your personal information and isolate it from any further processing until deletion is possible.

For any questions about data retention, please contact legal@jitsuin.com.

Anonymization

In some instances, we may choose to anonymize or aggregate your personal data instead of deleting it, for statistical use, for instance. If we choose to anonymize personal information, we make sure that there is no way that the personal information can be linked back to you or any specific user, whether by us or any third party.

Data Security and Integrity

We take steps that are reasonably necessary to securely provide our Sites and Services. We have put in place reasonably appropriate security measures designed to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. We limit access to personal data only to those employees, agents, contractors and the third parties who have a business need-to-know.

We also have procedures in place to deal with any suspected data security breach. If required, we will notify you and any applicable regulator of a suspected data security breach. We also require those parties to whom we transfer your personal information to provide acceptable standards of security.

Notwithstanding, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from the Services may not be secure. Therefore, take special care in deciding what information you send to us via email. For any questions about the security of your information, please contact legal@jitsuin.com.

Notice to Nevada Consumers

We do not sell your personal information within the scope of, and according to the defined meaning of, a “sale” under NRS 603A.

International Transfers

We are located in the United States, and the personal information that we collect is stored on servers located in the United States and elsewhere, including in Europe. This means that your personal information will be collected, processed, stored in, and/or accessed from, the United States, which may have data protection laws that are different from (and sometimes less protective than) the laws of your country or region, such as the GDPR.

By sending us personal information, you agree and consent to the processing of your personal information in the United States, which may not offer an equivalent level of protection to that required in other countries (particularly the European Union and the U.K.), and to the processing of that information by us on servers located in the United States, as described in this Privacy Policy.

We have implemented safeguards designed to ensure that the personal information we process remains protected in accordance with this Privacy Policy. Safeguards we may take in our discretion include, for instance, entering into standard contractual clauses in connection with any onward transfers of personal information. We may implement other mechanisms and take similar appropriate safeguards with our third-party service providers and partners. Further details can be provided upon request.

Staying In Control of Your Information: Your Rights

If you are in the EEA or the U.K., you have certain rights in relation to your personal data:

  • The right to be informed – our obligation to inform you that we process your personal data (and that’s what we’re doing in this Privacy Policy)
  • The right of access – your right to request a copy of the personal data we hold about you (also known as a ‘data subject access request’)
  • The right to rectification – your right to request that we correct personal data about you if it is incomplete or inaccurate (though we generally recommend first making any changes in your account settings)
  • The right to erasure (also known as the ‘right to be forgotten’) – under certain circumstances, you may ask us to delete the personal data we have about you (unless it remains necessary for us to continue processing your personal data for a legitimate business need or to comply with a legal obligation as permitted under the GDPR, in which case we will inform you)
  • The right to restrict processing – your right, under certain circumstances, to ask us to suspend our processing of your personal data
  • The right to data portability – your right to ask us for a copy of your personal data in a common format (for example, a .csv file)
  • The right to object – your right to object to us processing your personal data (for example, if you object to us processing your data for direct marketing); Rights in relation to automated decision-making and profiling – our obligation to be transparent about any profiling we do, or any automated decision-making
  • The right to lodge a complaint at any time to the supervisory authority for data protection issues in your country of residence – however, we ask that you please contact us first so that we can first address your concerns.

If you are located in the EEA or the U.K. and wish to exercise any of the rights set out above, you may contact us at legal@jitsuin.com or write to us at:

Jitsuin Ltd;

11 Central Avenue
BEVERLEY , HU17 8LH
United Kingdom

These rights are subject to certain rules around when you can exercise them.

If you would like to exercise your rights for Customer Data with a Customer who has collected your information and engaged us as a service provider, please contact the Customer directly. We will assist such Customer as instructed by the Customer with respect to your request(s).

You will not have to pay a fee to access your personal data (or to exercise any of the other rights) unless your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request under those or other permitted circumstances.

We may need to request specific information from you to help us confirm your identity. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. If we cannot reasonably verify your identity, we will not be able to comply with your request(s).

We will respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated as required by law.

If you no longer wish to receive our marketing/promotional information, we remind you that you may withdraw your consent to direct marketing at any time directly from the unsubscribe link included in each electronic marketing message we send to you. If you do so, we will promptly update our databases, and will take all reasonable steps to meet your request at the earliest possible opportunity, but we may continue to contact you to the extent necessary for the purposes of providing our Services, such to inform you of transactions or issues with your account.

California Privacy Rights

California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. Jitsuin does not share personal information with third parties for their own marketing purposes.

Contact Us

If you would like to contact us about our privacy practices, or exercise any of your data subject rights, please send a written request to

Jitsuin, Inc.
Legal Team

5201 Great America Parkway Suite #320
Santa Clara, CA – 95054

Or email us at legal@jitsuin.com.

 

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