Privacy policy

Please, read our Privacy Policy carefully before using this service, so how we may collect and use personal information, and the rights and choices available to our visitors and users regarding such information.

We strongly urge you read this policy and make sure you fully understand and agree with it, before you access or use any of our services.

If you do not read, fully understand and agree to this Privacy Policy, you must immediately leave this website and avoid or discontinue all use of any of our services.

This Privacy Statement applies to the parent organization Sakasa Ltd, registered in the Hong Kong.

Overview

This privacy statement («Privacy Policy») indicates the way information is collected and utilized by

Sakasa Ltd., its subsidiaries and affiliates («Sakasa», «we», or «us») respect your privacy and are committed to protecting your Personal Information and being transparent about how we collect, use, and share your Personal Information This privacy policy («Privacy Policy») applies to all Sakasa’s online services and website (www.sayboost.com) or to any website that includes a link or reference to this Privacy Policy (together, the “Website”) and describes how we handle Personal Information (as described below) and the choices available to you regarding collection, use, access and how to update and correct your Personal Information.

Our website is managed in accordance with the General Data Protection Regulation (GDPR), (Regulation (EC) 2016/679), which is binding on the implementation of the legislative act. The GDPR introduces a number of new rules for individuals and reinforces some of the rights enshrined in Directive 95/46 / EC. Directive 95/46/EC will enter into force on May 25, 2018. This Regulation is drawn up in accordance with the requirements of the GDPR and, thus, complies with Directive 95/46 / EC and issued for the purpose of its execution to national acts, until it expires on May 25, 2018. Measures include the following: a data processing/transfer agreements between Sakasa Ltd and its entities or its service providers for onward transfers of data processing agreements for data relating to EU residents.


The Privacy Policy clause falls under the responsibility of the legal department of Sakasa Ltd, whose duty is to ensure its compliance with laws. Sakasa Ltd is responsible for managing the data, as well as determining the purposes and methods of processing personal data provided and collected online.

Principles

  • Sakasa Ltd’s data protection policy is based on the following principles:
  • Processing of personal data must be carried out in a lawful, conscientious and transparent manner;
  • The collection of personal data must be carried out only for established, unambiguous and legitimate purposes and does not provide for additional processing of data incompatible with these purposes;
  • The collection of personal data must be appropriate, appropriate and limited to information that is necessary for the purposes in which these data are collected;
  • Personal data must be accurate and updated if necessary;
  • All reasonable measures must be taken to ensure that inaccurate personal data, depending on the purpose of their processing, will be immediately deleted or corrected;
  • Personal data must be stored in such a way that the data subject can be identified no longer than is required to achieve the purposes in which the data was collected;
  • All personal data must be stored in such a way as to ensure their confidentiality and safety;
  • Personal data should not be transferred to third parties, except when necessary to provide services on the basis of the contract;
  • Data subjects should have the right to access personal data, to modify or delete data, to limit processing, to object to it, and to transfer data.

Personal information we collect

  • Through the website

We collect data, including Personal Information that you provide on our Website and as you use the Website. «Personal Information» includes information that can be used to identify you as a natural person, directly or indirectly, in particular in combination with other information available to us such as an identification number, online identifier or one or more factors specific to your identity as a natural person and may include, but is not limited to, your:

As such, should you use the form made available on the Website, we may also collect the following information:

  • Contact information, such as name, address, phone number, email address (etc.);
  • Demographic information, such as your country, company,  job title;
  • Comments

Sakasa Ltd’s aims at keeping the Personal Information we hold is accurate and up-to-date. Please ensure that the Personal Information you communicate to us is accurate and up-to-date.

If you fail to provide certain personal data when requested, we may not be able to perform the contract we have entered into with you (such as providing you with a product or service), or we may be prevented from complying with our legal obligations.

In addition, when you visit our website to browse, read, or download information on the Website, your web browser automatically sends us (and we may retain) information such as the:

  • Internet domain through which you access the Internet
  • Internet Protocol address of the computer you are using
  • Type of browser software and operating system you are using
  • Date and time you access our site
  • The Internet address of the site from which you linked directly to our site

We will use this information as aggregate data to help us maintain this site, e.g., to determine the number of visitors to different sections of our site, to ensure the site is working properly, and to help us make our site more accessible and useful and in accordance with our Cookie Policy.

We also collect Personal Information from trusted third-party sources and engage third parties to collect Personal Information to assist us.

  • Through our services

In addition, in order to provide our services to our customers, we may also collect additional Personal Information, through our cookies placed by our customers on their own websites or from website partners authorized to collect such Personal Information.

This Personal Information is collected only if you accept the cookies for such advertising purpose.

Personal Information collected on Internet:

  • Sakasa Cookie identifier,
  • IP address,
  • IP geolocation,
  • URLs of pages of the various sites visited,
  • The time of your browsing on the various pages,
  • The type and version of the browser with which you browse the Net,
  • Cookie identifiers of partner technological platforms, which share the same goals, for which this data has been collected.
  • Ad ID
  • Ad web page URL
  • Event ID -such as the end user «clicks» the Ad or «views» the impression

Personal information collected via Mobile Application

To collect Personal Information using a mobile application, Sakasa relies on various partners to collect the following Personal Information:

  • The IP address,
  • The mobile phone’s identifier for advertisers (IDFA for IOS devices and GAID for Android),
  • GPS geolocation data,
  • The model of mobile phone as well as its operating system (IOS, Android, etc.).
  • URL of pages on the client website which have been viewed.
  • Time
  • Ad ID
  • App name.

When you visit or use our services – you may also provide us with certain information (either automatically through your uses, or by manually submitting it).

How we use your personal information

We only collect, use and store your Personal Information for the purposes of operating our business, delivering, improving, and customizing our Website as well as products and services we provide, sending marketing and other communications related to our business, providing you with information, products and services that you request from us, and for [other legitimate purposes permitted by applicable law].

As the case may be, we will provide you with the basis of such legitimate purposes upon its occurrence, prior to implementation of the related processing.

Sakasa collects Personal Information for a variety of purposes, including the following:

  • Providing you with information you requested from us;
  • Respond to an inquiry from you;
  • Sending communications to you, including for marketing or customer survey purposes, either directly from Sakasa or, subject to your consent, as the case may be, from our third-party partners;
  • Contract with you for, and provide you with our services to which you have subscribed or considering subscribing;
  • Creating an account;
  • Prevent and address fraud, breach of policies or terms, and threats or harm.
  • Providing customer service and support, notably through chatbots;
  • Improving the operation of the Website and/or help adjust the content of the Website to the general geographic location of you and for reporting purposes;
  • Managing a job application.

We may also use the Personal Information in connection with the services rendered to our customers, and notably:

  • To deliver advertisements as well as marketing and sales offers to you that best correspond to your needs and preferences,
  • To help advertisers and publishers better target their current and future customers in their loyalty building and commercial prospecting campaigns,
  • To help businesses distribute non-intrusive advertising,
  • To optimise distribution frequency of advertisements (marketing pressure) with a view to avoiding saturation,
  • To develop studies for advertisers of various industries (automotive, real estate, distribution, etc.) in the interest, amongst others, of helping them to better understand consumers’ needs and their market as well as to analyse the performance of their loyalty building and commercial prospecting campaigns.
  • Reconcile the different identifiers of various terminals in order to bring them closer to a profile in a probabilistic way.

Where required or permitted by applicable law, we also use or disclose your Personal Information to limited third parties when we believe, in good faith, that such use or disclosure is reasonably necessary to (i) comply with the legal obligation bearing on Sakasa, (ii) enforce or apply the terms of any agreement to which we are a party, or (iii) protect the rights, property or safety of Sakasa, Sakasa customers, or others.

How we share your personal information

We may share your personal Information with our affiliate entities and other third-party business partners, providers, vendors or contractors acting on our behalf and under our instructions, whether located within or outside of the European Union (“EU”) or the Economic Area (“EEA”), for the purposes of operating our business, delivering, improving, and customizing our Website as well as our products and services, sending marketing and other communications related to our business and when needed, with your consent.

Therefore, we may share Personal Information in the following ways:

  • Within Sakasa and any of our affiliate entities located within or outside of the EU/EEA, for purposes of Personal Information processing or storage in connection with the aforementioned purposes;
  • With Sakasa’s business partners, vendors, authorized third-party agents or contractors to provide our products and services or facilitate transactions. Examples include, but are not limited to: processing or orders, hosting websites and providing support.
  • In connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by another company;
  • As the case may be, for further protection of your privacy, Sakasa will share your Personal Information in aggregated form which may be used to identify you direclty or indirectly;

Where mandated or permitted by applicable law, regulation or legal process, we will disclose your Personal Information to law enforcement officials, government authorities or other third parties, located inside and outside of the EU/EEA, where such disclosure is in accordance with due process of law and binding upon Sakasa, to the extent necessary to comply with legal process or meet national security requirements, protect the rights, property, or safety of  Sakasa, its business partners, you, or others

Links to third-parties’ websites

The Website may contain links to third-party websites that are operated by companies outside of our control. Your activities on those third-party websites will be solely governed by the privacy policies and procedures of those third parties. Sakasa takes no responsibility whatsoever for the content or information practices of such third parties and encourage you to review the privacy polices of these third parties before disclosing any information on their websites.

How long we keep information and the method of destruction

We will retain your Personal Information only for the duration of the purpose for which it was collected in accordance with Section 4, as well as as necessary to comply with our business requirements, legal obligations, resolve disputes, protect our assets and enforce agreements to which Sakasa is a party and will delete your Personal information further to this period.

We may keep your Personal Information for as long as your account is active, and longer as needed (for example, if we are legally obligated to keep it further, or need it to protect our interests).

Security and confidentiality of your personal information

The security and confidentiality of your Personal Information is important to us. We implement appropriate physical, administrative, and technical measures and safeguards designed to protect your Personal Information from loss, theft, misuse, alteration, unlawful or unauthorized access, use, or disclosure.

Sakasa also relies on reasonable measures to safeguard Personal Information in our possession, including:

  • Enforcement of group-wide policies and procedures on Personal Information use, security and confidentiality;
  • Restricting access to Personal Information to only those employees and third-party service providers on a “need to know” basis and under strict confidentiality requirements;
  • Among other things, we offer HTTPS secure access to most areas on our Services. Use of technologies to safeguard data during transmission, such as SSL encryption for some of the data that you provide via the Website and using appropriate security measures to safeguard the data we collect and possess;
  • The transmission of sensitive payment information (such as a credit card number) through our designated purchase forms is protected by an industry standard SSL/TLS encrypted connection; and we regularly maintain a PCI DSS (Payment Card Industry Data Security Standards) certification.
  • Use of industry-standard measures and processes for detecting and responding to inappropriate attempts to breach our computer systems and networks.

The Internet and any communication thereon cannot be guaranteed to be secure at all times, and we cannot ensure or warrant the security of any Personal Information you provide us through this technology. In this regard, we have procedures to deal with any suspected data security breach and will notify you and any regulator of a suspected breach, as mandated by law.

Please note that electronic communication, particularly email, is not necessarily secure against interception. Sakasa uses industry-standard data collection and encryption systems to ensure the secure collection and transmission of your personal identifiable information. Please do not send sensitive data (e.g., Social Security, bank account, or credit card numbers) by email or web form.

Your rights

You have the right to access, obtain a paper or electronic copy, review, correct and update all your Personal Information stored by us, notably to confirm its accuracy. Subject to any relevant legal requirements and exemptions, you may also oppose to or limit the processing or your Personal Information or request that certain of your Personal Information be deleted from our files.

If you reside within the EU, you may also exercise you right to portability of your Personal Information where the lawful basis for the processing is (i) (a) a contract or (b) your consent and (ii) by automated means. Please note that such a request could be limited to the sole Personal Information you provided us with or that we hold at that given time and subject to any relevant legal requirements and exemptions, including identity verification procedures.

Sakasa will make reasonable efforts to comply with the aforementioned requests, unless such requests are prohibited by law, or there is a legitimate purpose to retain your Personal Information, in which case we will inform you without undue delay. We reserve the right to verify your identity before any request relating to your Personal Information processed by us. Please direct any questions about your Personal Information using the contact details provided at the end of this Privacy Policy.

In accordance with this Privacy Policy, but excluding (i) any transfers of data to third parties performing tasks directly on our behalf and pursuant to our instructions and (ii) new processing operation requiring your prior consent, where we receive Personal Information directly from an EU or Swiss individual to which such Personal Information relates, we will offer the individual the opportunity to choose (as the case may be, through opt-out or opt-in) whether his or her Personal Information is (1) disclosed to a third party, including for direct marketing purposes; or (2) used for a purpose that is different than the purpose it was originally collected or subsequently authorized by the individual and compatible with that original purpose.

Any individual who wishes to opt out can do so freely and at any time by contacting Sakasa at using the contact details provided at the end of this Privacy Policy or further to the information process relating to the new purpose.

Children’s privacy

Sakasa encourages parents and guardians to take an active role in their children’s online activities. Sakasa does not sell or offer its products and services to children. As such, our Website is designed for adult user interaction. We do not intentionally collect Personal Information from children under the age of 18. If you are a parent or legal guardian of a minor under the age of 16 and believe that the minor has disclosed personal information to us, please contact us using the contact details provided in this Privacy Policy.

Where do we store your information 

We may store and process Personal Information subject to this policy all over in the Worldwide.
Sakasa’s data storage providers are committed to protect and secure your data. Sakasa may collect, store and process certain Non-personal and Personal Information of partners and theirs users, solely on our Users’ behalf and at their direction. For example, each of our Users is able to import their e-mail contacts from third party services like Gmail, or otherwise collect and manage contacts via their User Website. These contacts are stored at Sakasa, on behalf of the User. For such purposes, Sakasa serves and shall be considered as a “Data Processor” and not as the “Controller” (as both such capitalized terms are defined in the European Data Protection Directive) of such all Information. The Users of our services (participants) controlling and operating such User Websites shall be considered as the “Controllers” of such Users Information, and are responsible for complying with all laws and regulations that may apply to the collection and control of such Users-of- Participants Information, including all privacy and data protection laws of all relevant jurisdictions.
Participants are responsible for the security, integrity and authorized usage of your Users-of-Users’ Personal Information, and for obtaining any consents and permissions required for the collection and usage of such information.

Sakasa cannot provide legal advice to all Users, however we do recommend that all Users publish and maintain clear and comprehensive privacy policies on their User Websites, in accordance with the applicable laws and regulations, and that all Users-of participants carefully read those policies and make sure that they consent to them.

If you are a visitor, user or customer of any of our Users, and would like to make any requests or queries regarding your Personal Information, please contact such User(s) directly. For example, if you wish to access, correct, amend, or delete inaccurate information processed by  Sakasa on behalf of its Users, please direct your query to the relevant User (who is the “Controller” of such data). If requested to remove any Users Personal Information, we will respond to such request within forty (40) days. Unless otherwise instructed by our User, we will retain their Users-of-Users’ Personal Information for the period set forth in Section  below.

The information may be shared solely in accordance with this policy. Sakasa, together with its marketing, analytics and technology partners, uses certain monitoring and tracking technologies (such as cookies, beacons, pixels, tags and scripts). These technologies are used in order to maintain, provide and improve our Services on an ongoing basis, and in order to provide our Visitors, all our Users with a better experience.

For example, thanks to these technologies, we are able to maintain and keep track of our Visitor’s and Users’ preferences and authenticated sessions, to better secure our Services, to identify technical issues, user trends and effectiveness of campaigns, and to monitor and improve the overall performance of our Services.

Please note that Third Party Services placing cookies or utilizing other tracking technologies through our Services may have their own policies regarding how they collect and store information. Such practices are not covered by our Privacy Policy and we do not have any control over them.

Cookies: In order for some of these technologies to work properly, a small data file (“cookie”) must be downloaded and stored on your device. By default, we use several persistent cookies for purposes of session and user authentication, security, keeping the User’s preferences (e.g., regarding default language and settings), connection stability (e.g., for uploading media, using e-Commerce features, etc.), monitoring performance of our services and marketing campaigns, and generally providing and improving our Services.

If you want to delete or block any cookies, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies. Information on deleting or controlling cookies is also available at www.aboutcookie.org (note that this website is not own by Sakasa, and we therefore cannot ensure its accuracy, completeness or availability).

Please note that deleting our cookies or disabling future cookies or tracking technologies may prevent you from accessing certain areas or features of our Services, or may otherwise adversely affect your user experience.

Clear Gifs: We and certain Third Party Services may employ a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), which enables them and us to improve our Services by measuring their effectiveness and performance. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, however unlike cookies these are not stored on your device, but are instead embedded within our Services.

Flash and HTML5: We and certain Third Party Services may also employ certain tracking technologies known as “Flash cookies” and “HTML5”, mainly for advertising purposes. Various browsers may offer their own management tools for removing or blocking such technologies. Additional information about managing Flash cookies is available here. (note that this website is not provided by  Sakasa, and we therefore cannot ensure its accuracy, completeness or availability).

Behavioral Targeting/Re-Targeting:

Certain Third Party Services and ad networks may display advertising on our Website, on  Sakasa mobile apps, or manage our advertising on other websites. Such parties may use certain tracking technologies to collect certain information about your activities on the Services and different third party Services to provide you with targeted advertising based on your interests and preferences.

User Data Supplementation: We may receive information about you from other sources, including publicly available databases or third parties from whom we have purchased data, and combine this data with information we already have about you.  This helps us to update, expand and analyze our records, identify new customers, and provide products and services that may be of interest to you.

If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.“Do Not Track” Signals:

Please note that we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application.

Use of cookies and other tracking technologies

By subscribing to any Services (including to any of our newsletters, blogs, social media accounts or public events) and providing  Sakasa with your e-mail address or any other contact information (such as your phone number or social media handle), you expressly agree to receive promotional content, messages or calls from  Sakasa or our partners (acting on  Sakasa’s behalf) through such means.

Accordingly,  Sakasa and its partners shall be entitled to call you or send you promotional content or messages by e-mail, SMS, direct text messages, marketing calls and similar forms of communication. If you wish not to receive such promotional messages or calls, you may notify  Sakasa at any time or follow the “unsubscribe” or STOP instructions contained in the promotional communications you receive.

Accessing your personal information

You may request to access or correct the personal information you have stored with us, by sending us an e-mail. You may also correct, update or remove certain information, or deactivate your account, through your account or website settings. We will respond to your request within a reasonable timeframe. We may retain your Personal Information (as well as your all Users Information) for as long as your User Account is active or as otherwise needed to provide you with our Services. We may continue to retain such Personal Information even after you deactivate your User Account and/or cease to use any particular Services, as reasonably necessary to comply with our legal obligations, to resolve disputes regarding our Users or their Users-of-Users, prevent fraud and abuse, enforce our agreements and/or protect our legitimate interests.


Changes to privacy policy

We reserve the right to update this Privacy Policy from time to time in order to reflect any changes to our products or services or to comply with changes in our legal and/or regulatory obligations. If we modify our Privacy Policy, we will post the revised version on the Website, with an updated revision date. Where such changes are substantial, we will also notify you by other means prior to the changes taking effect, such as by sending you an email notification. By continuing to use our website thirty days after such revisions are in effect, you will be deemed to accept and agree to the revisions and to abide by them.