Privacy Policy

Last Updated: 30 June 2019

This Privacy Policy explains how Aiisma, Inc and its affiliates ( “Aiisma”, “us” or “we”), collects, uses, shares, transfers and protects the information relating to you as a natural person (“Personal Information”, as that term is defined by the privacy laws applicable to you). We encourage you to read this Privacy Policy carefully to understand how we collect and use your information. In some cases, we may provide additional notices about our privacy practices, each of which will be considered to form part of this Privacy Policy.

This Privacy Policy applies to your use of the AiiSocial platform (“AiiSocial”) and www.aiisma.com and other websites we own or operate (the “Site”), as well as all products, and services and channels that link to this Privacy Policy (collectively, with AiiSocial and the Site, the “Services”). This Privacy Policy DOES NOT apply to information collected through a website or platform not owned or controlled by Aiisma.

This Privacy Policy also provides information specific to residents of California, the European Union, and Canada.

CONSENT

By accessing or using AiiSocial, visiting the Site, or using any of our other Services, you consent to this Privacy Policy and understand that your use of our Services is subject to this Privacy Policy and our Terms of Use, including applicable limitations on damages and the provisions regarding resolution of disputes. If you do not agree with this Privacy Policy, do not access or use any of our Services.

COLLECTION AND USE OF PERSONAL INFORMATION

We collect Personal Information directly from you, from others, and automatically from your use of the Services. We will only collect your Personal Information (a) when applicable, with your consent, (b) if we have a legitimate interest in doing so, or (c) as authorized or required by law. The types of Personal Information we collect about you and the manner of collection depends on how you interact with Aiisma. We only collect Personal Information as reasonable and necessary. If you do not provide the relevant information, we may not be able to provide you with certain Services or features.

Categories. During the preceding 12 months, we have collected these categories of Personal Information:

  • Identifiers (e.g., name, address, phone, and email address)

  • Biometric information (e.g. images, keystrokes, physical characteristics)

  • Sensitive personal information (e.g., payment information, identification numbers)

  • Internet or similar activity (e.g., geolocation, browsing history, device ID, network)

  • Employment-related information (e.g., current or past employment)

  • Commercial information (e.g., products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)

Sources. We collect Personal Information from these sources:

  • Directly from you, with your consent. When you register for an AiiSocial account, we collect your username, gender, phone number, email, mailing address, zip code, consignee information, method of payment and bank account information, etc. We also collect any photos, reviews, or experiences and other Personal Information you choose to post or submit via AiiSocial. If you participate in one of Aiisma’s offline product experience events, we will also ask for your name, gender, email address, and phone number and will collect any other Personal Information you choose to provide. When you contact us for customer service or to make inquiries via our forms, surveys or other means, we ask for your name, phone number, and transaction information, and we record the date, frequency, and other details about your inquiry. We collect this information with your consent, and we use it to provide you with AiiSocial, respond to your inquiries, and to communicate with you including sending you direct marketing materials.

  • Automatically from your use of AiiSocial, with your consent. If you opt-in to AiiStream, you consent to Aiisma sharing your geolocation and other Personal Information from your account and posts in order to serve you targeted ads and offer you Aii tokens that you can exchange for discounts with the businesses, brands and influencers in our network (“Businesses, Brand & Influencers”). You can opt-out of AiiStream at any using the deactivate button on your AiiSocial dashboard. We collect this information with your consent and we use it to provide you with AiiStream and for other purposes that you consent to or are permitted by law.

  • Automatically from your use of AiiSocial or the Site, with a legitimate interest of providing and improving our Services. When you navigate to and through AiiSocial or the Site, we collect information about your device, software, and network including: IP address, browser type, device name and model, device ID, operating system version number, language selected for device, time zone, telecom operator information, error logs, certain user behavior, and other information collected through cookies and other similar technologies. We collect this information to achieve our legitimate interest of monitoring and improving our Services. Please read our Cookie Notice for more information about our use of these technologies.

  • From third parties, with a legitimate interest, such as other websites and social networks that you may link to your AiiSocial account, marketing companies, and other third parties that may lawfully provide us with Personal Information. When you link from another website or social network, we may obtain information from your account, such as account ID, e-mail address, and profile picture. We reserve the right to collect information about you from our Service Providers and third-party sources. We may combine this data with information we already have about you. This helps us to update, expand and analyze our records, identify new users and Businesses, Brand & Influencers, and improve and expand our Services.

Children’s Privacy. AiiSocial and our other Services are designed for users 12 and older, and we require verified parent or guardian consent for children age 12 to 16 to use AiiSocial. Aiisma does not knowingly collect Personal Information from children under 16 or from minors subject to heightened privacy protections according to the laws of their jurisdiction (in each case, a “Minor”) without first obtaining the applicable required parent or guardian consent. If we discover that a Minor has provided us with Personal Information through an unauthorized submission, we will delete that information from our systems. If you believe we might have any information from or about a Minor, or if you become aware of an unauthorized submission of information to Aiisma, please contact us at privacy@aiisma.com.

Other Ways Aiisma Uses Personal Information. In addition to the uses specified above, Aiisma may use your Personal Information:

  • To provide our Services that you request, such as order processing, maintenance, electronic security implementation, push system upgrades, and other similar purposes for the legal basis of fulfilling our contractual obligations to AiiSocial users, Businesses, Brand & Influencers, and other parties.

  • For authentication, security, fraud monitoring, archiving and backup purposes to ensure the security of products and services provided to you by Aiisma to achieve our legitimate interest of ensuring security for the processing of your Personal Information.

  • To performance analytics to make user-friendly adjustments to our operations, track regional use of Services to ensure our personnel, language, and after-sales resources are distributed appropriately, and for other purposes related to our legitimate interest of improving our Services.

  • To protect or enforce this Privacy Policy, our Terms of Use, and other agreements.

  • To respond to legal requests and prevent harm, such as if we receive a subpoena or other legal request.

  • If we believe it is necessary, to identify, contact or bring legal action against persons or entities who may be causing injury to you, to Aiisma, or to others.

  • Comply with a law, regulation, legal process or court order.

  • For any other purpose with your consent.

We may process Personal Information for one or more stated purposes at a time. We will obtain your consent prior to using your Personal Information beyond the purposes described in this Privacy Policy or outside the scope allowed by the law.

SHARING YOUR PERSONAL INFORMATION

Categories. In the preceding 12 months, Aiisma has disclosed the following categories of Personal Information for a business purpose:

  • Identifiers

  • Biometric information

  • Sensitive personal information

  • Internet or similar activity

  • Employment-related information

  • Commercial information

Recipients. Aiisma may disclose Personal Information for a business purpose to the following recipients:

  • Businesses, Brand & Influencers. When you opt-in to AiiStream, you consent to Aiisma sharing your Personal Information with our Businesses, Brand & Influencers. Some Businesses, Brand & Influencers may use behavioral advertising by collecting and analyzing your use of AiiSocial (e.g., click stream information, browser type, time and date, subject clicked or scrolled over) in order to serve you targeted ads and deliver Aii tokens to you. Aiisma will not share your Personal Information to advertisers outside of our Businesses, Brand & Influencers.

  • Service Providers. Vendors that provide us with services (collectively, “Service Providers”) may have access to your Personal Information while they are performing their contractual obligations. These Service Providers include but are not limited to payment processors, marketing companies, IT service providers, and email and data hosting providers. We prohibit our Service Providers from selling or disclosing the Personal Information we provide, and we require all Service Providers to maintain confidentiality standards that are commercially reasonable to ensure the security of your Personal Information. Aiisma requires our Service Providers to comply with relevant cybersecurity laws and regulations. The type of information that we provide to a Service Provider will depend on the purpose of the service that they provide to us.

  • Affiliates. We disclose the information we collect from you to our affiliates or subsidiaries. If we do disclose your Personal Information to our affiliates or subsidiaries, their use and disclosure of your Personal Information will be subject to this Privacy Policy.

  • Law enforcement, and other governmental agencies, as permitted or required by law.

  • Cookie information recipients, subject to their respective privacy policies.

  • Other third parties, as permitted by applicable law, for example: if we go through a business transition (e.g., merger, acquisition, or sale of a portion of our assets); to comply with a legal requirement or a court order; when we believe it is appropriate in order to take action regarding illegal activities or prevent fraud or harm to any person; to exercise or defend our legal claims; or for any other reason with your consent.

  • Aggregated and Deidentified Information. We reserve the right to share aggregate, anonymized, or deidentified information about any individuals with nonaffiliated entities for marketing, advertising, research or other purposes, without restriction.

PERSONAL INFORMATION ACCESS AND CONTROL

Depending on where you reside, your options to control your Personal Information may include some or all of the following:

  • Changing your AiiSocial account and preferences.

  • Changing your preferences for how and about what we communicate with you.

  • Correcting, updating, and deleting the Personal Information in your account. Please note that certain legal obligations may limit or prevent our ability to fullfil these requests, and that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Site or Software for a period of time.

  • Requesting access to the Personal Information we hold about you.

  • Choosing whether to receive marketing communications from us, including promotions, surveys, and information about products and services that may be of interest to you.

  • Controlling how the cookies we use interact with your browser.

Do Not Sell My Personal Information. Aiisma does not share your Personal Information in direct exchange for money, so we don’t sell your Personal Information in the literal sense. We do share your Personal Information with Businesses, Brand & Influencers with your consent as part of the AiiStream program. In exchange for your participation in AiiStream, you receive Aii tokens reflecting the value of your participation in AiiStream for use with our Businesses, Brand & Influencers. Privacy laws define “sell” very broadly and, in some cases, sharing data for these purposes may be viewed as a “sale” under applicable laws. You can opt out of these “sales” of your Personal Information anytime by deactivating your participation in AiiStream on your AiiSocial account dashboard. If you deactivate AiiStream, you will no longer be eligible to receive Aii tokens in exchange for your data sharing, but you may still use other features available through the AiiSocial platform.

Do Not Track. Do Not Track signals are signals sent through a browser informing us that you do not want to be tracked. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed below.

In addition, privacy rights specific to residents of California, the European Union, and Canada are detailed below. See Consumer Privacy Requests for instructions to exercise these controls and choices, express concerns, lodge a complaint, or obtain additional information about the use of your Personal Information.

CALIFORNIA PRIVACY RIGHTS

This section provides residents of the State of California (“California Consumers”) with the disclosures and notices required under the California Consumer Privacy Act of 2018 (“CCPA”). The following paragraphs apply solely to California Consumers and describe the specific rights afforded under the CCPA.

Employee Data Exception. In some cases, the Personal Information we collect about you is in a business-to-business context when you are acting as an employee in the context of performing due diligence regarding potential procurement of our Services on behalf of your employer, or in the performance of other job duties. Please note that Personal Information collected and used in this context is not protected Personal Information under the CCPA.

Without limiting the foregoing, California Consumers may exercise the following rights over their Personal Information, subject to our receipt of a verifiable Consumer Privacy Requests, as well as any exceptions and limitations that may apply.

  • Right to Disclosure. You have the right to request that we disclose information to you about our collection and use of your Personal Information over the past 12 months, such as (i) the categories of Personal Information we have collected about you; (ii) the categories of sources for the Personal Information we have collected about you; (iii) our business purpose for collecting or selling that Personal Information; (iv) the categories of third parties with whom we share that Personal Information; and (v) if we sold or disclosed your Personal Information for a business purpose, two separate lists stating (a) sales, identifying the Personal Information categories that each category of recipient purchased; and (b) disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained. Aiisma is only required to respond to two disclosure requests within a 12-month period.

  • Right to Disclosure.

  • Right to Access. You have the right to request that we provide you with access to specific pieces of Personal Information we have collected about you over the past 12 months (also called a data portability request). If you submit a right to access request, we will provide you with copies of the requested pieces of Personal Information in a portable and readily usable format. Please note that Aiisma is prohibited by law from disclosing copies of certain pieces of Personal Information (e.g., government identification numbers, financial account information, and passwords or security questions and answers) because the disclosure would create a substantial, articulable, and unreasonable risk to the security of the information, our business systems, or your account. Aiisma is only required by law to respond to two access requests within a 12-month period.

  • Right to Deletion. You have the right to request that we delete any of your Personal Information that we collected from you and retained, with certain exceptions. Aiisma may permanently delete, deidentify, or aggregate the Personal Information in response to a request for deletion. If you submit a right to deletion request, we will confirm the Personal Information to be deleted prior to its deletion, and we will notify you when your request is complete.

  • Right to Nondiscrimination. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by law, we will not (i) deny you goods or services, (ii) charge you different prices or rates for goods or services, (iii) provide you a different level or quality of goods or services, or (iv) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services, because you exercised a right under the CCPA.

  • Right to Disclosure of Marketing Information. California’s Shine the Light Act (Civil Code sections 1798.83-1798.84) entitles California residents to request certain disclosures regarding Personal Information sharing with affiliates and/or third parties for marketing purposes.

We endeavor to respond to a verifiable Consumer Privacy Request from a California Consumer within 45 days of receipt. If we require more time, we will notify you in writing of the reason and extension period. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding receipt of the verifiable consumer request. If we cannot comply with part or all of your request, we will explain the reasons in our response.

EUROPEAN PRIVACY RIGHTS

We adopted this section to comply with the European Union’s General Data Protection Regulations (“GDPR”). This section applies solely to residents of the European Union (“EU Residents”). Aiisma offers AiiSocial and other Services to individuals located in the EU as a data processor. However, if an EU resident interacts with Aiisma to become one of our Businesses, Brand & Influencers or to otherwise contract with us, Aiisma collects and processes their Personal Information as a data controller. If you are an EU Resident, you have the following rights in relation to the Personal Information we hold about you:

  • Right to know how we process your Personal Information. We have set the required notices in this Privacy Policy. We may provide you with additional notices about other ways we process your Personal Data, such as by sending you a notice via email or by other means of communication.

  • Right to access your Personal Information. You can request to access your Personal Information. Upon request, we will provide you with a copy of your Personal Information, along with details about the types of Personal Information we process, why we process it, and any third parties we work with to collect Personal Information on our behalf. We may have one or more legally valid reasons to refuse your request in whole or in part, for example in order to protect the rights of other individuals.

  • Right to restrict processing of your Personal Information. You can request that we restrict the processing of your Personal Information if (i) the data is inaccurate, (ii) the processing is unlawful, (iii) we no longer need the Personal Information, or (iv) you exercise your right to object.

  • Right to rectify your Personal Information. If you become aware that the Personal Information that we hold about you is incorrect, or if your situation changes (e.g., you change address), please inform us and we will update our records.

  • Right to data portability. In some circumstances, we are required to provide your Personal Information to another organization at your request and in a structured, commonly used machine-readable format, so that the other organization can use it.

  • Right to erasure (a.k.a. the “right to be forgotten”). Upon your request, and in certain circumstances and where we are required to do so by law, we are required to delete your Personal Information. This right is not absolute, and we may be entitled to retain and process your Personal Information despite your request. If you make this request, we balance certain legal, contractual and business interests against your right to request the deletion of your Personal Information.

  • Right to object to certain processing of your Personal Information. Upon your request, and in certain circumstances and where we are required to do so by law, we will limit our processing of your Personal Information as you request.

  • Right to not be subject to automated decision-making Aiisma does not use Automated Decision-Making (“ADM”) as part of the Services. If we engage in this activity in the future, you will have the right to object to a decision we make wholly by a computer or algorithm without human input and to receive information about this type of processing.

EU Residents may exercise these rights over their Personal Information, subject to our receipt of a verifiable Consumer Privacy Request, as well as any exceptions and limitations that may apply.

How Aiisma will use your Personal information

We adopted this section to provide supplemental information in compliance with Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”). This section applies solely to residents of Canada where PIPEDA applies (“Canadian Consumers”). PIPEDA gives Canadian Consumers specific rights regarding Personal Information offering details on an identifiable person without the inclusion of name, title, telephone number and business address of an employee of a business or organization. The following paragraphs describe PIPEDA rights and explain how to exercise those rights.

  • Right to know why we collect, use and distribute the Personal Information we process. We have set the required notices in this Privacy Policy. We may provide you with additional notices about other ways we process your Personal Data, such as by sending you a notice via email or by other means of communication.

  • Right to expect us to collect, use or disclose Personal Information responsibly and not for any other purpose other than which you consented. We set your expectations in this Privacy Policy, and collect express or implied consent at various stages of collection or processing. If we collect or use your Personal Information based on your consent, we will also notify you of any changes and will request your further consent as needed. You may withdraw your consent at any time with reasonable notice by contacting us at privacy@Aiisma.com.

  • Right to accuracy of your Personal Information. We take steps to reasonably ensure that your Personal Information we are using is accurate. In most cases, we rely on you to ensure that your information is current, complete and accurate. We provide methods for you to correct, update, and delete inaccurate Personal Information in your account, and we will provide you with reasonable assistance to ensure that your Personal Information is accurate in our systems and with our service providers.

  • Right to access your Personal Information. Upon written request and identity authentication, we will provide you with your Personal Information under our control, information about the ways in which that information is being used and a description of the individuals and organizations to whom that information has been disclosed. We will make the information available within thirty (30) days or provide written notice where additional time is required to fulfil the request. If limited by law or potential infringement on another’s privacy rights, we may not be able to provide access to some or all of the Personal Information you request. If we must refuse an access request, we will notify you in writing, document the reasons for refusal and outline further steps that are available to you.

Canadian Consumers may exercise the above rights over their Personal Information, subject to our receipt of a verifiable Consumer Privacy Request, as well as any exceptions and limitations that may apply.

CONSUMER PRIVACY REQUESTS

Through the Services, Aiisma provides methods for you to directly access, edit, delete or export certain Personal Information Aiisma processes in your use of the Services. If you wish to exercise your rights under applicable privacy laws beyond these methods, please submit a verifiable Consumer Privacy Request:

Aiisma may only legally fullfil a Consumer Privacy Request when we have sufficient information to verify that the requester are the person or an authorized representative of the person about whom we have collected Personal Information, and to properly understand, evaluate, and respond to the request. We do not charge a fee to process or respond to a verifiable request unless we have legal grounds to do so, such as requests that are excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

AIISMA PROTECTS YOUR PERSONAL INFORMATION

Aiisma only retains your personal information for the time period necessary for the purposes described in this Privacy Policy and as required by applicable laws and regulations.

Data Security. Aiisma implements technical, organizational and physical safeguards in place to help protect your information from unauthorized access, processing or disclosure. We adopt and adhere to various policies, such as information security systems, confidentiality agreements with information management employees, and limiting information access to employees only as necessary. We use technical safeguards to protect information online and stored on our systems, such as password protection, access control isolation, and monitoring computer use to prevent the loss of information, improper use, and unauthorized reading or disclosure. For some services, Aiisma uses encryption technology (such as TLS) to protect Personal Information. Please note, however, that no transmission of data over the Internet or mobile platforms is 100% secure, and we cannot guarantee that unauthorized third parties will not defeat our security measures or use your Personal Information for improper purposes.. Systems and communication networks you use to access Aiisma services may be subject to problems and vulnerabilities that are beyond Aiisma’s control. We are not responsible for the security of information you transmit to us over networks that we do not control, including the internet and wireless networks, or the data that is stored on your device. You should only access the Site and Services within a secure environment.

Your Account. When you sign up or create an account with us, you will have a login and password. We encourage you to take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your login and password private. We are not responsible for any lost, stolen, or compromised passwords, or for any activity on your account via unauthorized activity.

Consent to Cross-Border Data Transfer. Aiisma is headquartered and operated in the United States. If you visit the Site or use our other Services, know that your Personal Information may be transmitted and transferred across national and regional borders, and stored and processed a different country form where you reside and remain there indefinitely. This may require the transfer of your Personal Information out of your country of origin with laws governing data collection and use that may differ from or be more restrictive than the law of the receiving country, or may result in governments, courts, law enforcement or regulatory agencies having access to or obtaining disclosure of your Personal Information pursuant to the laws of the applicable foreign jurisdiction. By allowing us to collect Personal Information about you, you consent to the transfer and processing of your Personal Information as described in this paragraph.

Social Networking. If you access our Site from a social networking website, we may receive Personal Information about you from such social networking website, as governed by the terms of use and privacy policy of that website. We may retain this Personal Information with the information we collect from you by other means. Your use of social networks via a link from our is entirely optional and subject to the privacy policy and terms of use of the social networking website you choose to use.

GENERAL

Third Party Websites. This Privacy Policy only applies to information collected by Aiisma, and does not apply to products or services provided by third parties. We may provide links to third-party websites from our Services for the convenience of our Site visitors and users, but we have no ability to control, and we are not responsible for, the privacy and data collection, use, and disclosure practices of third-party websites. Any access to and use of linked websites is not governed by this Privacy Policy, but instead is governed by the privacy policies of those websites. We are not responsible for the information practices of such websites. We encourage you to review and understand the privacy policies of such websites before providing them with any information.

Changes. We may amend or update this Privacy Policy at any time and in our sole discretion. You will be able to see our last updated privacy policy, along with its revision date. The revised privacy policy will take immediate effect on the date of publication. Your continued access or use of the Services after we make changes is deemed to be your acceptance of those changes. Please check the Privacy Policy from time to time to confirm whether we have made any changes with reference to use of Personal Information.

Notifications. If you would like to receive a copy of this Privacy Policy, or if you have any questions, comments, or complaints related to this Privacy Policy or our Services, please contact us at privacy@aiisma.com

If you are an EU resident, Aiisma’s EU representative is Consu LLC. You can contact our EU representative via email at eu.aiisma@aiisma.com.

Any notice from Aiisma will be sent to the email address, phone number, and/or mailing address listed on your AiiSocial account or otherwise provided to Aiisma as part of your most recent communication with us. If sent electronically, a notice is deemed served when your device or the electronic system receives the message. If sent by mail or courier, a notice is deemed served on the third day after the notice was sent.

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