Last update: June 4, 2019
This policy describes how the operator of Xunto (“Xunto”, “we”) collects, processes, uses and shares personal information and personal data about users of the Xunto Web Application (the “Application”).
In this policy, the term personal data refers to information that relates to an individual who is identifiable.
The contact details of the entity collecting personal data under this policy are below.
Okapya Software Solutions Inc.
In order to enable you to use the Application and the services offered through the Application, we must collect and process personal data about you. Our processing of personal data is mainly based on the following principles:
We collect the information you provide to us (for example by completing a form) through the Application interface or otherwise. This information may include:
We collect information automatically when you use the Application. This information is saved each time you interact with the Application and includes information about your mobile device and data about your interactions with the Application, in particular:
We collect data about your use of the Application, such as features used, actions taken, the number of connections to the Application, the date of the connections to the Application, type of content uploaded to the Application.
When you access the Application, we collect data provided by analytics tools such as Google Analytics. This data may include, for example, sex, age, interests, but it is not associated with you personally and is provided to us in aggregated form.
We collect information from sites or social networking Applications (Facebook, Twitter, YouTube, LinkedIn, Vimeo, Pinterest, Yahoo, etc.) when you interact with profiles belonging to us. These sites or Applications are also governed by their own policies regarding your personal data which may be different from ours and may be applicable.
We process personal data collected through the Application for the purposes described below. Some processing is subject to your specific consent, while other processing is necessary to provide you with services or is based on your implied consent or the pursuit of legitimate interests.
We use the personal data you provided us (for example your name and email address) to contact you, but only if you have provided such data and if you agree to receive communications from us.
We abide by applicable regulations with respect to unwanted electronic communications. If you no longer wish to receive electronic communications from Xunto, you can notify us at any time at the following address: firstname.lastname@example.org.
We use personal data to identify content uploaded to the Application and to associate such content with you for our Customer that have access to your account.
We use data collected through the Application and data collected from analytics tools to monitor usage of the Application generally, to prevent misuse of the Application, to identify problems or bugs in the Application and to determine which features we should improve.
We process personal data collected through the Application to fulfill our legitimate interests, including improving our services and providing our users with personalized content.
We take the privacy of our users seriously. That is why the processing of personal data based on our legitimate interests never involves targeted monitoring or communicating specific personal data about identifiable individuals to third parties, except to Customer.
We keep your personal data until you ask us to destroy it, until our activities no longer require keeping your data for up to 36 months after your last connection to the Application. We do not, however, undertake to keep any data for a determined period of time.
Personal data is stored electronically on servers are operated by our hosting provider, Heroku, located in the United States which undertakes in writing to keep your personal data confidential.
Personal data collected about individuals is transferred to the United States and Canada. Canada is recognized as an appropriate jurisdiction for the transfer of personal data from the European Union. Our hosting provider, Heroku, is certified under the EU-U.S. Privacy Shield Framework. Visit http://www.salesforce.com/assets/pdf/misc/privacy-shield-notice.pdf for more details.
Your personal data is hosted by our hosting provider which agrees to use industry-standard security measures to maintain the integrity and confidentiality of data. For more information about the security measures put in place by our hosting providers, please visit their website at this address : https://www.heroku.com/policy/security.
Our employees and service providers are aware that the personal data collected through the Application is confidential and are informed about the appropriate security measures to prevent unauthorized access to personal data.
We only share your personal data as described in this policy or when we have your consent. Your personal data may be disclosed to the categories of recipients described below for the purposes mentioned.
Collected personal data is only available to our officers and employees who must access it for the purposes described in this policy.
Your personal data may be disclosed to our Customers where such Customer is associated with you on the Application. Your contact information and usage information could be shared with the owners of projects you participate in through the Application.
We share some personal data with service providers that enable us to render our services more efficiently. These providers agree in writing to keep personal data confidential and to limit their use of personal data to what is necessary to provide their services.
We may also disclose personal data to third parties if the law expressly authorizes or requires such disclosure, or if we are ordered to do so by a competent authority. We may disclose personal data in the context of court proceedings if necessary to protect our rights or those of our Customers.
In the event that the sale or restructuring of all or part of our business is envisioned, we may disclose collected personal data to the persons or organizations involved before and after the transaction, whether or not it takes place. In such a case, these persons or organizations undertake to keep disclosed personal data confidential and to use same exclusively in order to evaluate the feasibility or the opportunity of the proposed transaction as well as in accordance with this policy.
The Application includes features that allow you to share content through social networking platforms. If you share content that includes personal data, that information may become publicly available based on the settings you selected.
You may access and modify some personal data that you have personally provided to us by accessing your account through the Application.
To access the personal data that we hold about you or to rectify personal data that is incorrect, you may make a request in writing to the following address: email@example.com or to the address of the data controller at the beginning of this policy.
We will respond to your request promptly (within 30 days of receipt), allowing you to access your personal data that is under our control. When required by law, we will provide your data in a portable machine-readable format.
The Application allows you to withdraw your consent to certain processing of your personal data, including by opting in or out of promotional offers based on your activities on the Application.
If you wish to withdraw your consent to the processing of your personal data beyond what the Application or your mobile device allows, please notify us in writing at firstname.lastname@example.org. It is not possible to stop all processing of your personal data and continue using the Application. The only way to stop all processing of your personal data is to stop using the Application.
In certain circumstances, depending on your place of residence, you may have the right to object to the processing of your personal data based on our legitimate interests. You may object to the processing of your data in writing at email@example.com.
You may request the erasure of personal data that we hold about you in writing at firstname.lastname@example.org. We will respond to your request as soon as possible (within 30 days of receipt). We will not direct our Customer to erase personal data that was disclosed or communicated to them in accordance with this policy. You may exercise any rights you may have with regards to such personal data directly with them.
If you continue to use the Application after your personal data has been erased, we will continue to collect personal data about you.
If you reside in the European Union, you have the right to lodge a complaint about the processing of your personal data with a supervisory authority responsible for the protection of privacy. The competent authority may vary depending on your country of residence.
If you reside outside of the European Union, this policy shall be governed by the laws applicable in Canada and the Canadian authorities shall have exclusive jurisdiction to hear any complaint or proceedings.
We reserve the right to verify the identity of individuals requesting access to personal data. Any information collected to perform this verification will not be used for any other purpose.
We may update this policy from time to time to reflect changes in our personal data management practices. If this policy is modified, the new policy will be available through the Application and on our website at the following URL: https://xunto.io/privacy-policy
The parties have expressly requested that this Agreement be drafted in English. Il est de la volonté expresse des parties que cette entente soit rédigée en anglais.