Joshu Policies

Joshu Inc. (referenced below as the “Company”, “We”, “Us” or “Our”, as applicable), respects your privacy and is committed to protect the Personal Information that you share with Us. This policy describes the scope of Personal Information collection in respect of The Company's website.

Please be aware that this Privacy Policy does not apply to the practices of any third parties to whom The Company may disclose Personal Information (as defined below) pursuant to the terms of this Privacy Policy.

This Privacy Policy may be occasionally updated. If We make any substantial changes in the manner We use your Personal Information, then We will provide a proper notice.

1. DATA AND PERSONAL INFORMATION WE COLLECT

Personal Information - Personal Information in this Privacy Policy refers to any information that may be used to identify an individual.

The types of Personal Information collected in accordance with your use of Our website and may include:

• Contact information – Your full name and/or nickname, a company or other entity to which you are affiliated, e-mail address and phone number.
• Application/request for information, questions, inquiries, comments, responses and/or additional information derived from correspondences with the Company.
• Any information provided by you when you interact with Us.

Other Information – We may use Google Analytics, HubSpot, Statcounter, RB2B, or other similar tools to collect user interaction data of Our website users, in order to adjust your browsing experience on Our website and to derive statistical insights in those aspects. You can find further information on Google website at https://www.google.com/intl/en/policies/technologies/ads/. We may use HubSpot or an equivalent Customer Relationship Management platform in order to track prospects and clients interactions with Our website to personalize their experience or improve our service to them. We may also use other analytics tools to collect information about the use of Our website and types of technical data in the context of the use of Our website, including information about your computer or mobile device or any other device and system, software, location data, time zone, Internet Protocol (IP) address, language preference etc. When you visit or log in to our website, cookies and similar technologies may be used by our online data partners or vendors to associate these activities with other personal information they or others have about you, including by association with your email, LinkedIn Profile, or home address. We (or service providers on our behalf) may then send communications and marketing to these email or LinkedIn Profile home addresses. You may opt out of receiving this advertising by visiting https://app.retention.com/optout.

In addition, you acknowledge that you are not required under applicable law to provide Us with any of your Personal Information, and that if you provide such information, it’s at your own free will and consent.

2. PURPOSE AND THE LEGAL BASIS OF DATA COLLECTING AND PROCESSING

If you are a resident of the EU, the purposes of Our collection and processing of information in the context of Our website are:

• To provide customer service and/or customer support and/or to interact with Our website users, including addressing users' applications, inquiries, questions, requests, comments, responses etc.

The legal basis for collection of data is Our legitimate interest to conduct an effective interaction with Our users which are customers and/or potential customers.

• To study the users' perception of, and interaction with, Our website or product and/or to study the behavior of users in the context of their use of Our website, for the purpose of assessing the website performance and/or effectiveness, and/or to personalize Our product offering.

The legal basis for collection of data is Our legitimate interest to study the use of Our website and the behavior of users in the context of their use of Our website or product.

• To send marketing messages, subject to their being able to request their removal at any time.

To the extent that we use the Personal Information for advertising, marketing or promotional activities, we will request your specific, freely-given, unbundled, informed and separate consent to such uses.

3. INFORMATION SHARING AND DISCLOSURE

The Company is committed to protecting your privacy and will not share or disclose information about you, unless otherwise permitted under the following terms and/or circumstances:

• When we have your consent to share such information;
• When we need to share your information to provide the product and/or service you have requested as part of Our contractual relationship;
• When we need to send the information to companies who work on Our behalf to provide a product and/or service you have requested as part of Our contractual relationship (they are prohibited from using that information for any other purpose);
• For the purpose of analysis and statistics, provided that such disclosure is done anonymously and is non-personal identifiable;
• In the event of sale or transfer, in whole or in part, of the Company or any of its affiliate’s shares or assets, in cases of mergers or in case of negotiations with respect to the foregoing;
• Where needed for corporate audits or to investigate or respond to a complaint or security threat, to prevent illegal uses of Our services, and assist in fraud prevention or investigation;
• If required to do so by applicable law, or in the good-faith belief, that (i) disclosing such information is necessary to comply with any applicable law or respond to any court order, search warrant or equivalent, or where in reasonable belief an action is needed in order to protect the personal safety of any individual; and (ii) such disclosure is appropriate or necessary in order to enforce the Free Trial Terms and Conditions or other terms outlined in Our contract with paid clients, take precautions against liabilities, investigate and defend against any third party claims or allegations, assist government enforcement agencies, protect the security or integrity of Our website and servers and protect Our rights and property.

All Personal Information as described above may be stored on servers and/or transferred (for the above purposes) to recipients in countries around the world (which may be located outside the EU/EEA, European Economic Area) which in some cases may have a lower level of protection than that within the EU/EEA. When transferring personal data of EU residents to countries outside the EU/EEA, to jurisdictions that did not receive an adequacy decision by the European Commission, we use standard contractual clauses approved by the European Commission to ensure a sufficient level of protection for your personal information. The standard contractual clauses can be found via the following link: http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm. You acknowledge and agree to such transfer of personal information, and the Company undertakes that it will take the necessary measures to ensure a sufficient level of protection.

Other than as described above, any other transfer of your Personal Information to third parties will be subject to your consent.

4. COOKIES

We may use industry-wide technologies such as cookies (a string of information that can be stored on your device, if your device is set to permit storage of cookies), or other similar tracking technologies, which store certain local information on your device to help Us learn more about how you use Our website and enhance your experience. You may adjust your device or operating system settings to limit such tracking or to decline cookies, but by doing so, you may not be able to use certain features on Our website. It is possible to prohibit and/or delete the cookies, inter alia, via settings option of your device. For more information you may refer Our Cookie Policy.

5. DATA RETENTION & SECURITY

• The Company stores Personal Information if it is necessary to fulfill the purpose for which the information has been collected.
• Notwithstanding the foregoing, unless you instruct Us otherwise, we may retain and use your Personal Information for as long as reasonably required for the purposes of which such Personal Information was collected, including without limitation, for future analytics and analysis, comply with Our legal or business requirements or obligations, to resolve disputes, to enforce Our Free Trial Terms and Conditions or other terms outlined in Our contract with paid clients, all as permitted under any applicable privacy laws.
• Aggregate and/or statistics and/or analysis which have been derived from your use of Our website and anonymised may remain on Our servers indefinitely.
• We will take commercially reasonable measures in providing secure transmission of your information across the internet to Our servers, and in securing the data which relates your information while at rest.
• We may use cloud service providers for Our servers and\or storage. In such cases, we rely on the security measures taken by the cloud service provider for the physical security, the integrity, redundancy and the data protection of the data which relates your information.
• However, you should be aware that there is always some risk involved in transmitting information over the internet and that there is also some risk that others could find a way to thwart Our and/or the cloud service provider security systems. As a result, while we strive to protect your information, we cannot ensure or warrant the security and privacy of your Personal Information or other content you may have provided while using Our website, and you do so at your own risk. We encourage you to exercise discretion regarding the Personal Information you choose to disclose.

6. DATA SUBJECT RIGHTS

You may at any time request the rectification of your Personal Information. If you are a resident of the EU/EEA you may also request the erasure of your Personal Information. However, please note that erasure could mean that the Company will not be able to process your applications/inquiries and to provide you any requested answers and/or services. You have the right to request a copy of your Personal Information from Our records. You have the right to request a limitation of the use of your personal information (for example if you deem the information to be incorrect) or the termination of use of your personal information (for example as regards the use of the information to improve Our services). If you wish to do so, you can send Us an e-mail with your request to: privacy@joshuins.com and we will make reasonable efforts to respond within a reasonable period of time, and pursuant to any applicable privacy laws.

7. RIGHTS OF CALIFORNIA RESIDENTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT (THE "CCPA")

Right to Access Personal Information Collected, Disclosed or Sold
You have the right to ask Us to disclose to you certain information regarding Our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (as described below), we will disclose to you:

• The categories of personal information we sold about you;
• The categories of personal information we disclosed about you;
• The categories of sources for the personal information we collected about you;
• Our business or commercial purpose for collecting or selling that personal information;
• The categories of third parties with whom we shared that personal information;
• The specific pieces of personal information we collected about you; and/or
• If we sold or disclosed your personal information for a "business or commercial purpose", as defined in the CCPA, lists of sales, identifying the categories of personal information that each category of recipient purchased or obtained.

Right to Request Deletion of Personal Information
You have the right to request that we delete any of your personal information that we collected from you, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete, and direct Our service providers to delete, your personal information from Our records, unless an exception applies.

We may deny your request to delete your personal information if retaining the information is necessary for Us or Our service providers to:

1. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
2. Debug or identify and repair errors that impair existing intended functionality;
3. Exercise free speech, ensure the right of another consumer to exercise that consumer’s right of free speech, or exercise another right provided for by law;
4. Comply with the California Electronic Communications Privacy Act;
5. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when Our deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent;
6. Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with Us;
7. Comply with a legal obligation; and/or
8. Make other internal and lawful uses of the personal information that are compatible with the context in which you provided such information.

Right to Non-Discrimination
We will not discriminate against you for exercising any of your rights under the CCPA. Unless permitted by the CCPA, we will not:

• Deny you goods or services;
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
• Provide you a different level or quality of goods or services; or
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

8. CALIFORNIA SHINE THE LIGHT LAW

California Civil Code Section 1798.83 permits Our visitors who are California residents to request certain information regarding Our disclosure of personal data to third parties for their direct marketing purposes. To make such a request, please contact us at: privacy@joshuins.com.

9. PRIVACY INQUIRIES

If you are a resident of the EU/EEA and have a complaint regarding the processing of your personal data by the Company you are entitled to report such dissatisfaction to the applicable supervisory authority in your country of residence.

If you have any questions or queries about this Privacy Policy or Our services in general, please do not hesitate to contact Us at: privacy@joshuins.com.

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