PRIVACY POLICY
We’re committed to ensuring that your privacy is protected
PRIVACY POLICY
May 18, 2018

July Systems, Inc. (“July Systems”, “our”, “us” or “we”) provides this Privacy Policy to inform you of our policies and procedures regarding the collection, use and disclosure of personal information we receive from users of www.julysystems.com (this “Site” or “Website”) and our corresponding Solutions and interactive services for devices (each an “App”).

This Privacy Policy may be updated from time to time. We will notify you of any material changes by posting the new Privacy Policy on the Site. You are advised to consult this policy regularly for any changes. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms of Service, accessible at https://julysystems.com/privacy-policy/.

This Privacy Policy is intended to provide adequate and consistent safeguards for the handling of personal information in accordance with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“the General Data Protection Regulation”), the Privacy Shield, and any other privacy laws, regulations and principles concerning the collection, storage, use, transfer and other processing of personal data transferred from the European Economic Area or Switzerland to the United States.

Principles of Processing Personal Information

We respect your privacy and are committed to protecting your personal information in compliance with the applicable legislation. This compliance is consistent with our desire to keep you informed and to recognize and respect your privacy rights. We agree to observe the following principles when processing personal information:

  • Data will be processed fairly and in accordance with applicable law.
  • Data will be collected for specified, legitimate purposes and not processed further in ways incompatible with those purposes.
  • Data will be relevant to and not excessive for the purposes for which they are collected and used. For example data may be rendered anonymous if deemed reasonable, feasible and appropriate, depending on the nature of the data and the risks associated with the intended uses.
  • Data subjects in the EU will be asked to provide their clear and unequivocal consent for the collection, processing and transfer of their personal data by our customers (data controllers).
  • Data will be accurate and, where necessary kept up up-to-date. Reasonable steps will be taken to rectify or delete personal information that is inaccurate or incomplete once we receive such requests received from our customers (data controllers).
  • Data will be kept only as it is necessary for the purposes for which it was collected and processed. Those purposes shall be described in this policy.
  • Data will be deleted or amended following a relevant request by the concerned data subject, should such notice comply with the applicable legislation each time.
  • Data will be processed in accordance with the individual’s legal rights (as described in this Policy or as provided by law).
  • Appropriate technical, physical and organizational measures will be taken to prevent unauthorized access, unlawful processing and unauthorized or accidental loss, destruction or damage to data. In case of any such violation with respect to personal data, we will inform data controllers and will take appropriate steps to end the violation and determine liabilities in accordance with applicable law and will inform data controllers to cooperate with the competent authorities.

Information Collected

July Systems may collect information from you in several ways.

Personal Information

“Personal Information” is any information that can be used to identify an individual, and may include name, address, email address, phone number, and social media account information. If we link other data with your personal information, we will treat that linked data as personal information. The personal information is collected, processed only on behalf of our customers (data controllers).

Usage Information

When you visit our Website, Solution or use an App, some information will be automatically collected. For example, when you visit our Website your computer’s operating system, Internet Protocol (IP) address, access times, browser type and language, and the website you visited before our site are logged automatically (“Usage Information”). In addition, when you use an App, the following types of Usage Information may all be logged automatically:

  • Type of mobile device you use
  • Operating system of your mobile device
  • Wireless carrier
  • Browser type; and
  • Precise geographic location (Technical information about your device, system, App software, and peripherals.)
Cookies

We also place “cookies” on your computer’s hard drive. A cookie is a small data file that we transfer to your computer or mobile device’s hard disk for record-keeping purposes. We use cookies for two purposes. First, we utilize persistent cookies to save your login information for future logins to the Site and App. Second, we utilize session ID cookies to enable certain features of the Site and App, to better understand how you interact with the Site and App and to monitor aggregate usage by users and web traffic routing on the Site and App. Unlike persistent cookies, session cookies are deleted from your computer when you log off from the Site, App and Service and then close your browser.

Third-party advertisers on the Site and App may also place or read cookies on your browser. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions of the Site and App or all functionality of the applicable Service. While most browsers are set up to automatically accept cookies, you may change your settings to prevent this from happening. Please note that not accepting cookies may prohibit our Site and other Web pages from operating properly in providing you with a personalized experience.

Use of Information

We use Personal Information and Usage Information to:

  • operate and improve our Website, Apps, products, and services;
  • understand you and your preferences to enhance your experience and enjoyment using our Website, Apps, products, and services;
  • track, collate, and analyze your use of the Website and/or App, and your progress in
  • respond to your comments and questions and provide customer service;
  • provide and deliver products and Services you request;
  • to send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages; and
  • link or combine it with other personal information we get from third parties, to help understand your needs and provide you with better service.

Sharing of Information

We do not share your Personal Information with third parties other than as follows:

  • with your consent, for example, when you agree to our sharing your information with other third parties for their own marketing purposes subject to their separate privacy policies;
  • our resellers, distributors, and other service providers who work with us and need access to your information to do that work;
  • to (i) comply with laws or to respond to lawful requests and legal process, (ii) to protect the rights and property of July Systems, our agents, customers, members, and others including to enforce our agreements, policies and terms of use or (iii) in an emergency to protect the personal safety of July Systems, its customers, or any person; and
  • in connection with or during negotiation of any merger, financing, acquisition, or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets to another company.

We may also share aggregated anonymous or de-identified information.

Children

We do not knowingly collect personal information from children under the age of 16. If you are the parent or guardian of a person under the age of 16 and believe that such person has provided us with personal information, you may request that it be deleted from our files by contacting our customers (data controllers).

Privacy Shield

July Systems complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States.

July Systems has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit http://www.privacyshield.gov.

Our participation in the Privacy Shield applies to all Personal Information that is received from the European Union and European Economic Area. July Systems will comply with the Privacy Shield Principles in respect of such Personal Information.

July Systems remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the Personal Information on its behalf do so in a manner inconsistent with the Principles, unless July Systems proves that it is not responsible for the event giving rise to the damage.

For complaints left unresolved by all other available mechanisms, you may invoke binding arbitration the Privacy Shield Panel, which consists of a pool of 20 arbitrators designated by the Department of Commerce and the European Commission, from which the parties will be able to select either one or three arbitrators.

If you believe that we have not adhered to this Policy, please contact us by e-mail at privacy@julysystems.com. We will do our best to address your concerns. If you feel that your complaint has been addressed incompletely, we invite you to let us know for further investigation. For any complaints that cannot be resolved with July Systems directly, July Systems has chosen to settle the dispute exclusively under the JAMS Streamlined Arbitration Rules or JAMS International Mediation Rules). To file a complaint via JAMS, please visit https://www.jamsadr.com/eu-us-privacy-shield. July Systems is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

Your Rights

July Systems will be called to assist our customer (data controller) in fulfilling customer’s obligations to respond to requests from you.

You have the right to be provided with information as to the nature of the personal information stored or processed about you by July Systems and may request deletion or amendments with our customers (data controllers).

If access is denied, you have the right to be informed about the reasons for denial with our customers (data controllers). You may resort to the dispute resolution described in this policy as well as in any competent regulatory body or authority. July Systems shall handle in a transparent and timely manner any type of internal dispute resolution procedure about personal information with the assistance of our customers (Data controllers).

If any information is inaccurate or incomplete, you may request that the data be amended with our customers (data controllers). It is your responsibility to provide use with accurate personal information about yourself and to inform of any changes. (e.g. new home address or change of name).

If you demonstrate that the purpose for which the data is being processed in no longer legal or appropriate, the data will be deleted, unless the applicable law requires otherwise. You also have the right to request the deletion of your personal data for any reason with our customers (data controllers)

Additional Enforcement Rights and Mechanisms

If at any time, you believe that your personal information has been processed in violation of this Policy, you may report the concern to the competent July Systems official. In particular, if you have any inquires or complaints about the use or limitation of use of your personal information, you may contact our corporate headquarters:

The Physical Address is located at “Contact us” page. Or email us at privacy@julysystems.com.

California Privacy Rights

If you are a California resident, you have the right to request information from us regarding the manner in which July Systems shares certain categories of personal information with third parties for their direct marketing purposes, in addition to the rights set forth above. Under California law, you have the right to send us a request at the designated address listed below to receive the following information:

  • The categories of information we disclosed to third parties for their direct marketing purposes during the preceding calendar year;
  • The names and addresses of the third parties that received the information; and
  • If the nature of the third party’s business cannot be determined from their name, examples of the products or services marketed.

This information may be provided in a standardized format that is not specific to you. The designated email address for these requests is: privacy@julysystems.com.

Also, please note that we have not yet developed a response to browser “Do Not Track” signals, and do not change any of our data collection practices when we receive such signals. We will continue to evaluate potential responses to “Do Not Track” signals in light of industry developments or legal changes.

Obligations to Data Protection Authorities

We will respond diligently and appropriately to requests from DPAs about this policy or compliance with applicable data protection privacy laws and regulations. We will, upon request, provide DPAs with names and contact details of the individuals designated to handle this process. With regard to transfers of personal information, we will (i) cooperate with inquiries from the DPA responsible for the entity exporting the data and (ii) respect its decisions, consistent with applicable law and due process rights. With regard to transfers of data to third parties, we will comply with DPAs’ decisions relating to it and cooperate with all DPAs in accordance with applicable legislation in case we receive such requests from our customers (data controllers).

The physical address is located at “Contact us” page.

Information Security

We take reasonable steps to help protect Personal Information against loss, misuse, unauthorized access or disclosure. July Systems is now Service Organization Control (SOC) 2 Type 1 Compliant. Service Organization Control (SOC) 2 report is covered for the evaluation of July’s Information Systems relevant to Trust Service principles viz. Security, Availability, Processing Integrity, Confidentiality. Controls over the security of a system prevent or detect the breakdown and circumvention of segregation of duties, system failure, incorrect processing, theft or other unauthorized removal of data or system resources, misuse of software, and improper access to, or use of, alteration, destruction, or disclosure of information. A SOC2 report based on the ISO 27001 Control Objectives has the same look and feel as a SOC1 report (ISAE 3402 report, formerly known as SAS70 report) and provides our clients with sufficient information (independent service auditor’s opinion, management assertion, system description, tests performed by service auditor and test results) to meet their assurance needs.

Except for the foregoing statement to be SOC 2 Type 1 Compliant, July Systems expressly disclaims any representation or warranty, whether express or implied, with respect to offering any definitive promise of security. These steps include utilizing appropriate technical, physical, and administrative safeguards.

Your Consent and Updates to this Policy

You acknowledge that this Privacy Policy is part of the Terms of Service for your use of the Sites and solutions, and you agree that using the Sites signifies your assent to July Systems’ Privacy Policy. July Systems reserves the right to change this Privacy Policy at any time. If we decide to change our Privacy Policy, we will post those changes on this page so that you are always aware of what information we collect, how we use it and under what circumstances we disclose it. As we may make changes from time to time without notifying you, we suggest that you periodically consult this policy. Your continued use of the Sites and solutions after the effective date of any modification to the policy will be deemed to be your agreement to the changed terms.

If you have any questions about your privacy or security on our Sites, please email us at privacy@julysystems.com or the physical address is located at “Contact us” page.

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