We collect information through two means:
Directly from you – On some of the pages we may ask for personal information in order to provide you a service or carry out a transaction. You are not required to provide this information and in case you do not, it will not be possible for us to provide you the requested service or transaction.
Automatically – We collect information about your visit to our sites, what pages you view and other actions taken within JKL Technologies’ sites. When you visit our site, a cookie may be placed on your machine or may be read if you have visited the site previously. Cookies are used to remember the information provided by you so that you do not have to fill it again when you download the same product or any other JKL Technologies product. Cookies will be placed only for the specified purpose and your information will not be used otherwise. You have the option to disable cookies on your computer.
When most of the data collected are used for the betterment of the gameplay, some are used to provide better targeted Ads with 3rd party SDKs. As part of the Google’s privacy program, the 3rd party SDKs use the Advertising IDs for this, which you can opt out using Google settings for the same.
Our App/Game itself uses the unique Android ID and other unique identifiers to provide better game play, such as providing hints, free virtual currencies, game play variances for relevant users as and when needed. This is also used by our APertain SDK integration which provides App Support and other related features.
Collecting Personal Data and why?
Personal Data we collect and process for our own purposes: Collected Data
When you visit our Websites or participate in JKL Technologies’s events, WentoEvents may collect information, which may include Personal Data, from Individuals as set forth below (collectively referred to as “Collected Data”). For the purposes of General Data Protection Regulation (GDPR), JKL Technologies shall be the controller for the Collected Data – this means that JKL Technologies decides what Collected Data is processed and why.
Data we process on your behalf: Service Data
We only process Service Data as per our Customer’s instructions. For purposes of the GDPR and the Swiss Federal Act on Data Protection, we are the processor and not the controller of the Service Data. Service Data, as defined in the Terms, means all electronic data, text, messages or other materials, including Personal Data of Users and End-Users, submitted to the Product(s) or Service(s) by our Customers through Customer’s Account in connection with Customer’s use of the Service(s), including data collected under “Other Information” and “Mobile Applications” below. Our EEA or Switzerland based Customers are the “controllers” of that data and are responsible for compliance with the applicable data protection law. We work with our Customers to help them provide notice to their customers concerning the purpose for which Personal Data is processed by JKL Technologies.
If you are our Customer from EEA or Switzerland, then in your role as a controller, you are authorizing, on behalf of you and your authorized agents and End-Users, and representing that you have the authority to provide such authorization to the processing and transfer of Personal Data in and to the United States and other countries which may have different privacy laws from your or their country of residence. We will take all steps reasonably necessary to ensure that the Service Data is treated securely and in accordance with this Notice.
We do not own, control or direct the use of Service Data, and in fact we are largely unaware of what information is being stored on our platform and only access such information as reasonably necessary to provide the Service(s) (including to respond to support requests), as otherwise authorized by Customers or as required by law. Unless we explicitly agree otherwise in writing, you will not process sensitive personal data (such as health data) on our platform.
As the controller, it shall be your responsibility to inform the End-Users about the processing, and, where required, obtain necessary consent or authorization for any Personal Data that is collected as part of the Service Data through your use of the Product(s) or Service(s). As the processors of Personal Data on behalf of our Customers, we follow Customer’s instructions with respect to the Service Data to the extent consistent with the functionality of our Service(s). In doing so, we implement technical, physical and administrative measures against unauthorized processing of such information and against loss, destruction of, or damage to, Personal Data.
We use your personal information for the following purposes:
- To ensure our site is relevant to your needs.
- To deliver services, such as newsletters, events, training or software, that you request or purchase.
- To help us create and publish content most relevant to you.
- To alert you to product upgrades, special offers, updated information and other new services from JKL Technologies, if you so request.
We do not sell, rent, or lease our customer lists to third parties.
When collecting contact information that might be used to intimate you about our products and services, we will always give you the opportunity to opt-out of receiving such communications. Each e-mail we send includes an unsubscribe link allowing you to stop delivery of that type of communication. If you elect to unsubscribe, we will remove you from the relevant list within 10 business days.
When does WentoEvents process Collected Data?
1) Sign-up, billing and Account information:
When you subscribe and sign-up to any of our Service(s), we may collect your (i) contact information such as name, e-mail address, mailing address, IP address, geographic location, or phone number of the Account admin; (ii) billing information, such as credit card number and billing address; (iii) name and email address when Account admin/Agent(s) provide feedback from within the Service(s); and (iv) unique identifiers, such as username, account number or password.
Subject to this Notice and the Terms, we will use such data, including without limitation, to (i) provide you the Service(s); (ii) send you communication from the Service(s); (iii) assess needs of your business to determine or suggest suitable Service(s); (iv) send you requested information about the Service(s); (v) respond to customer service requests, questions and concerns; (vi) administer your Account; (vii) send you promotional and marketing communications (where you have requested us to do so); and (viii) facilitate your transactions with other users when you use our Service(s).
When you attend an event conducted by JKL Technologies, including webinars or seminars, we may collect your contact information such as name, e-mail address, designation and company name.
Subject to this Notice, we will use such data, including without limitation, to (i) assess needs of your business to determine or suggest suitable Product(s) or Service(s); (ii) send you requested information about the Product(s) or Service(s); (iii) send you promotional and marketing communications (where you have requested us to do so); and (iv) respond to your questions and concerns.
3) Program Registrations:
When you register for any of our programs through a registration form on our Websites, we may collect information such as name, e-mail address, company name and website URL, company details, location and contact information. Subject to this Notice, we will use such data, including without limitation, to (i) facilitate your use of the program portal for which you have registered; (ii) send you communication from within the Service(s); (iii) send you requested information about our Service(s); (iv) respond to your requests, questions and concerns; and (v) send you promotional and marketing communications (where you have requested us to do so).
4) Public forums and Newsletters:
When you visit our publicly accessible community forums and blogs, you should be aware that any information you provide in these areas may be read, collected, and used by others who access them. Further, we may collect your (i) contact information such as name, e-mail address, mailing address, or phone number; (ii) information about your business, such as company name, company size, business type; and (iii) a short bio about you to identify you as the author of the post. When you actively subscribe to our newsletters, we collect your email address to share our newsletters with you.
Subject to this Notice, we will use such data, including without limitation, to (i) assess needs of your business to determine or suggest suitable Service(s); (ii) send you requested information about the Service(s); (iii) send you promotional and marketing communications (where you have requested us to do so); and (iv) respond to your questions and concerns.
5) Clear Gifs and Log Files:
We and our third party advertising partners use technologies such as web beacons in analyzing trends, administering the website, tracking users’ movements around the site, and gathering demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis.
As is true of most websites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We link this automatically collected data to other data we collect about you.
Apart from the aforementioned information collected by us, we automatically receive and record certain Personal Data of yours when You visit our Websites. This includes device model, IP address, the type of browser being used, usage pattern through cookies and browser settings, query logs and product usage logs. We also collect clicks, scrolls, conversion and drop-off on our Product(s), Websites and Services to render user journey at real-time. Subject to this Notice, we will use such data, including without limitation, to (i) assess needs of your business to determine or suggest suitable Product(s) or Service(s); (ii) send you requested information about the Service(s); (iii) respond to customer service requests, questions and concerns; and (iv) for analytical purposes.
You authorize JKL Technologies and its service providers to perform analytics on such Collected Data, to (i) improve, enhance, support and operate the Websites; and (ii) compile statistical reports and record insights into usage patterns. You acknowledge that JKL Technologies uses Collected Data, as the case may be, for the aforementioned purposes.
We may post your testimonials/comments/reviews on our Websites which may contain your Personal Data. Prior to posting the testimonial, we will obtain your consent to post your name along with the testimonial. If you want your testimonial removed, please contact us at email@example.com.
8) Marketing communications:
We may use your e-mail address, collected as part of Collected Data, to send our newsletters and/or marketing communications about our products and services. Where you have so requested, we will also send you marketing communications about our third party partners. If you no longer wish to receive these communications, you can opt out by following the instructions contained in the emails you receive or by contacting us at firstname.lastname@example.org.
Sharing Personal Data
Personal Data contained in Collected Data and Service Data will never be sold to or shared with other companies or organizations for commercial purposes. We process Personal Data in the United States and the European Economic Area (“EEA”) and in other countries through third parties that we may use. You may refer to the page here for more information on hosting options. Third parties with whom Collected Data is shared may include third-party payment processors who process your credit card and other payment information for JKL Technologies but are otherwise not permitted to store, retain or use such information. Third parties that we utilize to assist in providing the Product(s) or Service(s) with whom Service Data may be shared are listed here (“Sub-Processors”). Further, we may transfer Personal Data to our Group Companies for the purposes identified in the Terms and this Notice. All such transfers are covered by the service agreements with the relevant recipients and we have taken appropriate safeguards to ensure that your Personal Data will remain protected in accordance with this Privacy Notice. Further details can be provided upon request.
Subject to the Terms and this Notice, we and our Group Companies shall have the right to access Customer’s Account and to process Service Data solely to the extent necessary to provide, enhance and improve the Product(s) or Services, including, without limitation, in response to Customer’s support requests. Our Sub-Processors will only be given access to Customer’s Account and Service Data as is reasonably necessary to provide the Service(s) and will be subject to confidentiality obligations in their service agreements.
Your personal information and other information related to your online activity at the JKL Technologies website will not be given to any outside organization for any purpose other than those below:
To Service Providers:
JKL Technologies hires other companies to provide services on our behalf, for instance web hosting, processing transactions, and analyzing our websites. We provide these companies with only those parts of your information they require to deliver those services. These companies and their employees are prohibited from using that personal information for any other purpose.
In case of legal compliance, with regard to certain transactions, we may disclose some or all of your information to financial institutions, government entities or other entities involved in legal compliance administration.
To third party websites:
Our Websites contain links to other websites that are not owned or controlled by JKL Technologies. Please be aware that we are not responsible for the privacy practices of such other websites or third parties. We encourage you to be aware when you leave our Websites and to read the privacy policies of each and every website that collects Personal Data.
Certain information may be shared with our partners only for purposes described in ‘Information Use’ above. For example, if you request that a sales person contact you, we may pass your request to a local reseller partner, if that is appropriate.
How does JKL Technologies keep Personal data secure?
We use appropriate technical and organizational measures to protect the Personal Data that we collect and process. The measures we use are designed to provide a level of security appropriate to the risk of processing your Personal Data.
If you are an individual resident in EEA, you have the following data protection rights regarding Collected Data:
- If you wish to access, correct, update or request deletion of your Personal Data, you can do so at any time by contacting us.
- You can object to processing of your Personal Data, ask us to restrict processing of your Personal Data or request portability of your Personal Data. Again, you can exercise these rights by contacting us.
- You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), please contact us.
- Similarly, if we have collected and process your Personal Data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority.
If you seek access to, or wish to correct, update, modify or delete Personal Data (hereinafter referred to as a “Request”) which forms a part of Collected Data, please contact us at email@example.com. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
If you seek access to, or wish to correct, update, modify or delete Personal Data (hereinafter referred to as a “Request”) which is part of the Service Data and processed by us on behalf of our Customer, you should direct your query to our Customer i.e, the controller. If you are a Customer of our Product(s) or Service(s) and wish to raise a Request on behalf of your Users and End-Users in connection with Service Data, you may raise a ticket on the support portal of the relevant Service. Please note that if a Customer has subscribed to more than one Service, a Request on a particular Service support portal is specific to that Service only and separate Requests need to be raised across other relevant Service support portals.
Changes to this policy