Last updated: February 23, 2023
End Users of a Partner who has agreed to use our dedicated SDK for purposes of facilitating Services (“End Devices”).
Is Nimble Controller or Processor?
When providing the Services, Aliat serves as a Data Processor, and the controllers are the Partners on one hand and the Customers on the other.
With respect to the API Application and Website (i.e. with respect to Visitors and Users), Aliat is a Data Controller.
For the purpose of this policy, the “Service(s)” shall include any software licensed by the Company, application, API, SDK, or related services provided through such software, application, API, SDK, including updates, enhancements, new features, support or communication. Specifically, the Services include our API Application made accessible upon approval and screening process to Customers (“API Application”).
Special jurisdictions and data protection regulations
Data Protection Officer and Contact Options
Please include sufficient details about your inquiry or request, in order to allow us to verify your request and address it.
Changes, updates and modifications
Personal Data we Process
1. Type of data. Depending on your interaction with us, meaning, if you are a Visitor who just browsing our Website, or if you are a User who maintains an account in our API Application, a business Partner or Customer, or an End Device installing our software, we may collect one of two types of information about you, your device or your chosen activities with us:
You are not obliged by law to provide us with any information. You can always avoid providing us with certain Personal Information; and if you gave your consent to process certain Personal Information, you cannot always ask to withdraw such consent. However, you acknowledge that it may prevent us from providing certain Services.
In the event we combine Personal Information with Non-Personal Information, the combined information will be treated as Personal Information for as long as it remains combined.
2. Personal Data of Visitors of the Website
a. Contact details: if you contact us for support, feedback or other inquiries, requests, or questions either through an online form available on the Website, by sending us an email or by other means of communication we make available (such as submitting a bug report or filling in a survey) you will be requested to provide us with your name, your email address, and the subject matter of your inquiry.
If you want to become a business Partner or a Customer through our Website, you will be asked to provide us with your full name, business email address, company, website URL, phone number and country.
We will use this information for our legitimate interest and solely for the purpose of responding to your inquiries and providing you with the support or information you have requested. We retain such information for as long as needed to provide you with the inquiry requested or as required under applicable law.
b. Subscription: If you voluntarily subscribe to our beta program, email communications or newsletter, you will be asked to provide us with your email address. You can unsubscribe at any time using the unsubscribe option within the body of the email sent to you or rather by contacting us directly at: email@example.com.
We will use your email address in order to send you information related to our Services, our beta program or the subject matter regarding which you reached out to us or submitted your email address.
c. Online Identifiers: We process IP addresses, cookies, pixel tags and a user agent (namely, your browser’s type, version, language, and country).
We may either directly or indirectly collect our Visitors’ Online Identifiers. Such processing is subject to your consent which is obtained through the cookie notice displayed on our Website in which you can accept, decline or set your preference. Necessary cookies will be used as part of our legitimate interest and for purposes of the Website’s functionality.
In certain cases, and upon your consent, third-party cookies and tags will be used for advertising, marketing and retargeting purposes of the site or Services.
Device Information: we may collect certain information about the device from which you access the Website or Services, such as type (mobile/desktop).
Based on your consent, and in certain cases, our legitimate interest, we may process device information for compatibility purposes, and to uniquely connect your device with a license key of a software product you purchased.
e. Online activity: We also collect certain technical information which relates to your use of the Website such as your click stream, type of browser, time and date, etc. We use this technical data in order to operate and manage our Website.
f. Job Application: In the event that you are interested in joining our team, and wish to submit your CV, you will be required to provide us with your name, email address, phone number and your CV file. Options to submit links to your website or LinkedIn profile are also available.
Your provision of personal information in connection with recruiting is voluntary, and you determine the extent of information you provide us. We do not request or require sensitive personal information concerning religion, health, sexual orientation, or political affiliation in connection with recruiting. We will use the information you have provided solely to communicate with you, manage our recruiting and hiring processes, and comply with corporate governance and legal and regulatory requirements. If you are hired, the information may be used in connection with employment and corporate management.
3. Personal Data of Customers, Users and Partners
In addition to the Visitor information described above, the following may be processed about Users or Customers:
a. Work contact details. If you are a Customer or a prospective one, we may retain your full name, contact details and work information (such as role, title and company) for purposes of communicating with you, and at times, for the preparation of a contract and a Customer account maintenance.
b. Authentication and authorization. If you are an approved Customer you will receive access from us to our API Application. For authentication purposes, you will have to set up your own password. Your work email address is used as your username.
c. Account information. when you open an account with us, to access our API Application, you will be requested to provide us with certain information such as your full name, email address and any other information you choose to make available in your user account.
d. Analytics and Dashboard. the Services include a dashboard via which you can track and manage your activity with us. This information is presented in a statistics manner, based on the activity logs’ aggregation.
e. Usage data. In order to provide the Services, operation, maintenance and improvement of the Services, so as to monitor, screen and protect against abusive use of the Servies, we will process an online activity log, metadata of your activities via the Services (such as timestamps, target and origin IP addresses, (root)domain and geo-information), and metadata that is otherwise required, such as segment, country, length, size of data packets.
How we collect or process Personal Data
Depending on the nature of your interaction with us and the Services, we may collect information as follows:
Lawful basis for processing
In addition to the lawful basis explained respectively to each data processing activity above, we would like to explain the general lawful bases for processing your personal data (as defined under the General Data Protection Regulations “GDPR”):
In any other case, we will also process your personal data where you have provided us with consent to do so, or, where we have a legitimate interest and are not overridden by your data protection interests or fundamental rights and freedoms, such as when we use the data in order to provide the Services, or when used for anti-fraud purposes.
Cookies and web technologies
Retention of Data
1. Generally followed by retention principles. As a general rule, we strive to follow the following retention principles, wherever possible or allowed:
3. Users. We retain your Personal Data as long as you maintain the account (and respective engagement) with us. In some cases, and subject to local applicable legislation, we may have to retain some information for a longer period.
4. Customers and Partners. We retain your Personal Data for as long as you didn’t ask us to delete such data, via third-party CRM vendors.
2. As a Data Controller, we use it as a principle, to share Personal Data only as required to operate, maintain, provide and secure the Services. Below you can find the categories of third parties with whom we share Personal Data (whether directly, or using them to process Personal Data as part of a service they render to us). If you are a resident of Canada, California, the UK, the EU or the EEA, you may also reach out with a direct request to learn more about the third parties who process your Personal Data on the virtu of providing us their services.
a. Service providers: we may share your information with third parties that perform services on our behalf, such as storage, host, features providers, payment processors, analytics services, servers, service functionality, customer support, marketing and advertising. These third parties may be located in different jurisdictions; We require each to maintain adequate measures of information and privacy protection as required by applicable law. Examples:
b. Business Partners who combine their technological features with us may have access to certain Personal Information about your usage, as collected from you. In these cases, you will always be able to check their privacy policies before using the combined services.
c. Our affiliated companies. We may disclose Personal Information to any current or future affiliated company, parent companies, or subsidiaries to process for the purposes described in this Policy. Affiliated companies are companies controlling, controlled by, or under common control with us.
d. Legal Disclosure, Policy Enforcement, Third Party Rights: We reserve the right to disclose your personal information if required by law and/or to comply with a court order or similar legal process or when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
e. Business Transitions: if we become involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
Data Subjects Rights
1. If you are a resident of California (or the USA in general), the relevant section in our CCPA Statement applies to you.
2. If you are a resident of the EU, EEA or the UK, the following applies to you: Individuals have the following rights, when we are the Data Controller of their data. Otherwise, for cases we are the Data Processor, please seek to exercise your privacy rights directly with your data controller.
a. Right of access: You may ask us to access any Personal Data held about you.
b.Right to rectification: You have the right to ask us to correct the information we hold about you. This option will be available to Users via their account settings.
c. Right to erasure: You may ask us to delete your information or to stop using it. We can only do this when possible, and as allowed by applicable laws. Sometimes we need your information to complete a transaction based on an action you made, comply with the law (such as taxes laws) or simply provide you with the Services.
d. Right to the restriction of processing: You may ask us to temporarily cease the processing of your Personal Data, or, for a specific purpose or function. Please note that this too might cause us to not be able to provide you with the Products and Services or part thereof.
e.Objection to processing: You may request us to stop processing your Personal Data. Similar exceptions as mentioned above will apply to such a case as well.
f. Right to data portability: You may contact us to request an export of your Personal Data in a reusable format, or to directly transfer such data to another vendor offering related services;
g. Right to withdraw consent: Where you have given us your consent to use your information for a specific purpose, you may, at any time, decide to withdraw your consent and we will then stop using your information for that purpose, under the exceptions listed above.
h. Right to lodge a complaint: If You live in a country where the EU or UK GDPR applies (e.g. the EU, EEA or UK), you may lodge a complaint with the authority responsible for protecting Personal Data in your country of residence, if you believe that your rights have not been respected by us. In such a case, you are welcome to reach out to us first so we will be able to help you with such a matter, at firstname.lastname@example.org.
3. Exercising your rights. for more information about your rights regarding your privacy, and in order to exercise your choices and controls in connection with our treatment of your Personal Information, please reach out by email for more information or request regarding your Personal Information, at email@example.com.
If we are unable to provide you with the information you asked for, we will endeavor to explain the reasoning for this and inform you of your rights, including the right to complain to the supervisor’s authority.
Data privacy and related laws in your jurisdiction may provide you with different or additional rights related to the data we collect from you, which may also apply.
If you are under 16 years of age, you are not permitted to use this Website or our Services. If you are a minor, or a parent of a minor, who has a good reason to believe that we process the Personal Information of a Minor as a Data Controller, or a Data Processor, please reach out to us with the necessary verification information so we will take an action to immediately resolve and remove any such information from our systems.
For questions an inquiries you can reach out ot us by email at: firstname.lastname@example.org, or by post to: Aliat LLC .3315 E. Russell Rd. Ste A-4 #334 Las Vegas, NV 89120 USA.
California Consumer Privacy Act (CCPA) Notice
Last Updated: April 22, 2022
We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other applicable California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.
This statement refers to the information collected, either automatically or as submitted by you, when you access, use or visit our Website, consume the Services or when you are an end-user of one of our Partners, or otherwise engage with us.
1. Categories of Personal Information collected about you
2. Sharing Information
a. We do not sell your Personal Information or share it for monetary gain. We may disclose your Personal Information to a third party for business purposes. When we do so, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except for performing the contract.
b. In the preceding twelve (12) months, we have shared the following categories of personal information for a business purpose:
Third Party and Business Purpose
Our hosting, processing, infrastructure and security service providers in order to provide, facilitate, process and secure our App and Website, the data and our services
Contact Information/ Customer Relation Management Data
CRM and mailing list platforms
Internet and network data
Service providers, web platforms, analytics services and online marketing platforms
Cookies and certain online identifiers
Analytics, statistics, understanding how Visitor use the Website
3. Your Rights
The CCPA provides consumers who are California residents with certain rights regarding their Personal Information. Below we describe your CCPA rights and explain how to exercise those rights:
3.1. Access to Certain Information and Data Portability Rights
You have the right to request us to disclose certain information to you about our collection and use of your personal information over the past 12 months. You can make a request to us as described below. Once we receive and confirm your verifiable consumer request, we will disclose the information you have requested, which could be one of the following types:
3.2. Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and about you, and retained, subject to certain exceptions (see below). When applicable, 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 deletion request if retaining the information is necessary for us or our service providers to:
3.3. Exercising your rights and choices
3.4. Response Timing and Format
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
5. Do not Track Signals
Do Not Track is a privacy preference that can be configured in certain web browsers (the “DNT Feature”); the DNT Feature, when enabled on a web browser, signals the websites you visit that you do not want certain information about your visit collected. We do not currently respond or recognize DNT Feature signals.
6. Changes to this Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you as per the notification mechanism described in our Policy or as otherwise required by applicable laws.
7. Contact Information
If you have any questions or comments about this privacy notice or Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at: email@example.com.