2. What is the lawful basis for which we use your personal information?
You hereby acknowledge that all processing of your personal information will be justified by a "lawful ground" for processing. In most cases, processing will be justified on the basis that:
•
Consent:When you sign up and use our services, you provide explicit consent for JOKAL to collect and process your personal information for the purposes outlined in this Privacy Policy. You have the right to withdraw this consent at any time by contacting us at
contact@tk1t.gg. •
Performance of a contract:: In certain instances, the processing of your personal information is necessary for the performance of a contract between you and JOKAL. This includes providing you with access to our services, personalizing your user experience, and maintaining the functionality of our platform.
•
Legal obligations:JOKAL may process your personal information to comply with legal obligations. This includes but is not limited to obligations related to data protection and privacy laws. We take these obligations seriously and ensure that your data is handled in accordance with applicable legal requirements.
•
Legitimate interests:We may process your information based on our legitimate interests, such as improving our services, enhancing user experience, and ensuring the security of our platform. We carefully balance these interests with your privacy rights.
In any case, we will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract. Feel free to contact us for this purpose at
contact@tk1t.gg.3. How do we use this information?
At JOKAL, we use the information we collect for the following purposes:
•
Personalization:Your Google email, username, and profile picture are used to personalize your experience on our platform, creating a tailored and user-friendly environment.
•
Account Management:We utilize your information for managing user accounts, ensuring the security and integrity of our platform.
•
User-Generated Content:JOKAL allows users to create and store notes on our platform. The content of these notes is considered user-generated data. While we do not actively collect or access the content of your notes, it is stored securely on our servers.
•
Communication:Your contact information, including your Google email, is used to communicate with you regarding important updates, notifications, and any inquiries you may have.
•
Improvement of Services:We may analyze aggregated data to improve our services, enhance user experience, and optimize the functionality of our platform
•
Legal Compliance:We may use your information to comply with legal obligations, respond to legal requests, or protect our rights and interests in legal proceedings.
•
Customer Support:Your provided information, especially your Google email, helps us respond to your inquiries and provide efficient customer support. We strive to address any concerns or issues you may encounter during your interaction with JOKAL.
•
Aggregated Analytics:We may generate aggregated and anonymized analytics to understand overall usage patterns, preferences, and demographics. This information is used for internal analysis and does not identify individual users.
6. Sharing of Information
At JOKAL, we prioritize the confidentiality and security of your information. We do not sell, trade, or otherwise transfer your personal information to external parties. However, there are instances where we may share your information for specific purposes:
•
Third-Party Service Providers:We may engage reputable third-party service providers to assist us in delivering and improving our services. These providers are bound by strict confidentiality agreements and are authorized to use your information solely for the purpose of fulfilling their services.
•
Legal Compliance:In situations where we are obligated to comply with legal requirements, such as responding to legal processes or protecting our rights, we may share necessary information.
•
Business Transactions:In the event of a merger, acquisition, or any form of business transfer, your information may be transferred to the acquiring entity. We will ensure that the new entity abides by the terms of this Privacy Policy.
•
Aggregated and Anonymized Data:We may share aggregated and anonymized data for research, analytics, or marketing purposes. This data does not personally identify you but helps us understand overall usage patterns and trends.
•
De-identified Data for Research: In support of research and development efforts, we may share deidentified data with trusted partners. This data is stripped of personally identifiable information to ensure your privacy.
7. Storage and Security of Information
At JOKAL, we prioritize the secure storage and protection of your information. Here's how we ensure the confidentiality and integrity of your data:
•
Secure Infrastructure:Your information is stored on a secure infrastructure, utilizing industry-standard
encryption protocols to safeguard against unauthorized access.
•
Third-Party Hosting:We partner with a reputable private VPS (Virtual Private Server) provider for hosting
our platform. This provider employs robust security measures, including data storage in a secure MongoDB,
to ensure the safety of your information.
•
Access Controls:Access to your information is restricted to authorized personnel who require it for the
provision of services. We implement strict access controls to minimize the risk of unauthorized access.
•
Regular Audits:We conduct regular security audits and assessments to identify and address potential
vulnerabilities. This proactive approach helps us maintain a secure environment for your data.
•
Data Retention:We retain your information only for the duration necessary to fulfill the purposes outlined
in this Privacy Policy. Once the retention period expires, we take steps to securely delete or anonymize your
data.
Despite our best efforts, no method of data transmission or storage can guarantee absolute security. If you have any
concerns or questions about the security measures we have in place, please reach out to us at
contact@tk1t.gg.9. Rights of EU, EEA, and UK users
This section of the Policy supplements the other provisions of this Privacy Policy, and applies to you if you are in the
EU, the European Economic Area (EEA) or UK. For the purposes of GDPR, your DATA CONTROLLER is:
JOKAL
ALL YOUR USER INFORMATION WILL BE COLLECTED, STORED, PROCESSED AND SHARED
STRICTLY IN ACCORDANCE, IN LINE AND FULL COMPLIANCE WITH GDPR LAW (HERINAFTER
COLLECTIVELY REFERRED TO AS THE “GDPR”).
Under applicable GDPR, you have the following rights in respect of your personal information:
•
Right to obtain information:to obtain information about how and on what basis your personal
information is processed and to obtain a copy;
•
Right to rectification:You have the right to have any incomplete or inaccurate information we hold about
you rectified and corrected.
•
Right of Erasure:to erase your personal information in limited circumstances where (a) you believe that it
is no longer necessary for us to hold your personal information; (b) we are processing your personal
information on the basis of legitimate interests and you object to such processing, and we cannot
demonstrate an overriding legitimate ground for the processing; (c) where you have provided your personal
information to us with your consent and you wish to withdraw your consent and there is no other ground
under which we can process your personal information; and (d) where you believe the personal information
we hold about you is being unlawfully processed by us;
•
Right of restriction:to restrict processing of your personal information where: (a) the accuracy of the
personal information is contested; (b) the processing is unlawful but you object to the erasure of the
personal information; (c) we no longer require the personal information for the purposes for which it was
collected, but it is required for the establishment, exercise or defence of a legal claim or (d) you have
objected to us processing your personal information based on our legitimate interests and we are
considering your objection;
•
Right to object:to object to decisions which are based solely on automated processing or profiling;
•
Right to ask for a copy:where you have provided your personal information to us with your consent, to
ask us for a copy of this data in a structured, machine-readable format and to ask us to share (port) this data
to another data controller; or to obtain a copy of or access to safeguards under which your personal
information is transferred outside of the EEA.
•
Right to withdraw your consentYou have the right to withdraw your consent on using your personal
data. If you withdraw your consent, we may not be able to provide you with access to certain specific
functionalities of our services.
•
Request the transfer of your Personal DataWe will provide to you, or to a third-party you have chosen,
your personal data in a structured, commonly used, machine-readable format. Please note that this right
only applies to automated information which you initially provided consent for us to use or where we used
the information to perform a contract with you.
Under certain circumstances, you may have the right to object, on grounds relating to your particular
situation, to the processing of your personal data by us and we may be required to no longer process your
personal data. Moreover, if your personal data is processed for direct marketing purposes, you have the right
to object at any time to the processing of personal data concerning you for such marketing, which includes
profiling to the extent that it is related to such direct marketing. In this case your personal data will no longer
be processed for such purposes by us.
In addition to the above, you have the right to lodge a complaint with a supervisory authority for data protection.
Please note that the right of access and the right to erasure do not constitute absolute rights and the interests of other
individuals may restrict your right of access or erase in accordance with local laws.
We will ask you for additional data to confirm your identity and for security purposes, before disclosing data
requested by you. We reserve the right to charge a fee where permitted by law. We will decline to process requests
that jeopardize the privacy of others, are extremely impractical, or would cause us to take any action that is not
permissible under applicable laws. Additionally, as permitted by applicable laws, we will retain where necessary
certain personal information for a limited period for record-keeping, accounting, and fraud prevention purposes.
To make such requests, please contact us atcontact@tk1t.gg. 10. California Resident Rights
This section of the Policy applies to you, if you are a California resident, as per California Privacy Rights Act
(CPRA), California Consumer Policy Act, 2018 (simply called “CCPA”) and California Online Privacy
Protection Act (simply called “COPPA”). This privacy notice section for California residents supplements the
information contained in our Privacy Policy and it applies solely to all visitors, users, and others who reside in the
State of California.
Categories of Personal Information Collected
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could
reasonably be linked, directly or indirectly, with a particular consumer or device. The following is a list of categories
of personal information which we may collect or may have been collected from California residents within the last
twelve (12) months.
Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not
mean that all examples of that category of personal information were in fact collected by us, but reflects our good
faith belief to the best of our knowledge that some of that information from the applicable category may be and may
have been collected. For example, certain categories of personal information would only be collected if you
provided such personal information directly to us.
•
Category A: Identifiers.Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol
address, email address, account name, driver's license number, passport number, or other similar identifiers.
Collected: Yes.
•
Category B: Personal information categories listed in the California Customer Records statute (Cal.
Civ. Code § 1798.80(e)).Examples: A name, signature, Social Security number, physical characteristics or description, address,
telephone number, passport number, driver's license or state identification card number, insurance policy
number, education, employment, employment history, bank account number, credit card number, debit card
number, or any other financial information, medical information, or health insurance information. Some
personal information included in this category may overlap with other categories.
Collected: No.
•
Category C: Protected classification characteristics under California or federal law.
Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed,
marital status, medical condition, physical or mental disability, sex (including gender, gender identity,
gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or
military status, genetic information (including familial genetic information).
Collected: No.
•
Category D: Commercial information.Examples: Records and history of products or services purchased or considered.
Collected: No.
•
Category E: Biometric informationExamples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to
extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and
voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise
data.
Collected: No.
•
Category F: Internet or other similar network activity.Examples: Interaction with our Service or advertisement.
Collected: Yes.
•
Category G: Geolocation data.
Examples: Approximate physical location.
Collected: No.
•
Category H: Sensory data.Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
Collected: No.
•
Category I: Professional or employment-related information.
Examples: Current or past job history or performance evaluations.
Collected: No
•
Category J: Non-public education information (per the Family Educational Rights and Privacy Act
(20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).Examples: Education records directly related to a student maintained by an educational institution or party
acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes,
student financial information, or student disciplinary records.
Collected: No.
•
Category K: Inferences drawn from other personal informationExamples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions,
behaviour, attitudes, intelligence, abilities, and aptitudes.
Collected: No.
We use the personal information that we collect or receive for the business purposes as described above. We may
disclose the above listed categories of personal information to third parties for business purposes as described above.
As previously mentioned in this Policy, we do not “sell” (as such term is defined in the CCPA) personal
information.
You are entitled to the following specific rights under the CCPA and CPRA in relation to personal
information related to you:
•
You have a right to request that we will disclose certain information to you about our collection and use of
personal information related to you over the past 12 months, including: (i) The categories of personal
information that we collect about you; (ii)The categories of sources from which the personal information is
collected; (iii) The purposes for collecting, using, or selling that personal information. (iv) The categories
of personal information that we disclosed for a business purpose or sold, and the categories of third parties
to whom we disclosed or sold that particular category of personal information. (v) The specific pieces of
personal information that we have collected about you.
•
You have a right to request that we delete personal information related to you that we collected from you
under certain circumstances and exceptions.
•
You also have a right not to be discriminated against for exercising your rights under the CCPA.
•
You also have a right to submit your request via an authorized agent. If you use an authorized agent to
submit a request to access or delete your personal information on your behalf, the authorized agent must:
(1) be a person or business entity registered with the California Secretary of State to conduct business in
California; (2) provide proof of such registration; and (3) provide documentation or other proof indicating
that they are authorized to act on your behalf. We may also require you to verify your identity directly with
us, and directly confirm with us that you provided the authorized agent permission to submit the request
•
You have a right to opt-out of sale or sharing of Personal Information (“PI”) and limit the use or disclosure
of your Sensitive Personal Information (“SPI”).
•
You have a right to correction, where you can request to have your PI and SPI corrected if you find them to
be inaccurate.
•
You have a right to opt-out of automated decision making, where you can say no to your PI and SPI being
used to make automated inferences, e.g. in profiling for targeted, behavioral advertisement online.
•
You have a right to know about automated decision making, where you can request access to and
knowledge about how automated decision technologies work and what their probable outcomes are.
•
You have a right to limit use of sensitive personal information, where you can make businesses restrict
their use of your SPI, particularly around third-party sharing.
To make such requests, please contact us atcontact@tk1t.gg. The above rights will only become exercisable by California residents if our Company falls within the scope of
CCPA and/or CRPA. Further, we will verify your request using the information associated with your account,
including email address. Government identification may also be required.
A request for access can be made by you only twice within a 12-months period. Any disclosures that we provide will
only cover the 12-months period preceding receipt of your request. We do not charge a fee to process or respond to
your verifiable User request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the
request warrants a fee, we will inform you of the reasons for such decision and provide you with a cost estimate
before processing further your request.
Rights of other Data Subjects
Depending upon the laws of your jurisdiction, you may be eligible for some or all of the following rights in respect of
your personal information:
•
Right to obtain information:to obtain information about how and on what basis your personal
information is processed and to obtain a copy;
•
Right to rectification:You have the right to have any incomplete or inaccurate information we hold about
you rectified and corrected.
•
Right of Erasure:to erase your personal information in limited circumstances where (a) you believe that it
is no longer necessary for us to hold your personal information; (b) we are processing your personal
information on the basis of legitimate interests and you object to such processing, and we cannot
demonstrate an overriding legitimate ground for the processing; (c) where you have provided your personal
information to us with your consent and you wish to withdraw your consent and there is no other ground
under which we can process your personal information; and (d) where you believe the personal information
we hold about you is being unlawfully processed by us;
•
Right of restriction:to restrict processing of your personal information where: (a) the accuracy of the
personal information is contested; (b) the processing is unlawful but you object to the erasure of the
personal information; (c) we no longer require the personal information for the purposes for which it was
collected, but it is required for the establishment, exercise or defence of a legal claim or (d) you have
objected to us processing your personal information based on our legitimate interests and we are
considering your objection;
•
Right to object:to object to decisions which are based solely on automated processing or profiling;
•
Right to ask for a copy:where you have provided your personal information to us with your consent, to
ask us for a copy of this data in a structured, machine-readable format and to ask us to share (port) this data
to another data controller; or to obtain a copy of or access to safeguards under which your personal
information is transferred outside of the EEA.
•
Right to withdraw your consentYou have the right to withdraw your consent on using your personal
data. If you withdraw your consent, we may not be able to provide you with access to certain specific
functionalities of our services.
•
Request the transfer of your Personal DataWe will provide to you, or to a third-party you have chosen,
your personal data in a structured, commonly used, machine-readable format. Please note that this right
only applies to automated information which you initially provided consent for us to use or where we used
the information to perform a contract with you.
To make such requests, please contact us atcontact@tk1t.gg.