Gamalon Inc.

This Privacy Policy (the “Privacy Policy”) applies to our website at https://newgamalon.staging.wpengine.com/ (the “Website” or “Site”) operated by Gamalon, Inc. (“Gamalon”, “we”, “our”, or “us”), as well as to the services and information available on the Website (collectively, the “Services”). This Privacy Policy describes how we collect, use, and disclose information, governs how we treat this information, and lets you know your associated rights. Please read this Privacy Policy carefully; once you consent to this Privacy Policy and its terms, it creates legal obligations on you and on Gamalon.

Our Website contains links to other websites for your convenience and reference. We are not responsible for the privacy practices or the content of those sites.

To help you navigate our Privacy Policy, we have divided it into numbered sections and provided a set of definitions in Section 18 (Definitions) to allow easy reference to key concepts.

Our Privacy Policy applies to any visitor to the Website (collectively, “you”). We ask you to show your consent to this Privacy Policy in different ways.

2.1 Consent by Site User.

We have structured our Website so that, you are able to come to our Website and review selected information about our Services without providing us with any Personally Identifiable Information. By accessing and using our Website or Services as a visitor, you are acknowledging that you have read and understood this Privacy Policy and agree to be legally bound by it.

If you are agreeing to our Privacy Policy on behalf of a company or other legal entity (“Your Organization”), then (i) you represent and warrant that you have authority to act on behalf of, and to bind Your Organization, and (ii) for all purposes in this Privacy Policy, the term “you” means Your Organization on whose behalf you are acting.

You have the right to withdraw your consent at any time, in accordance with Section 11 (Your Right to Opt-Out; Object to Processing; Deleting Information).

3. The Information We Collect.

To provide our Services, and to otherwise conduct our business via the Website, we rely on information provided by, and collected from, our users. This information consists of the following:

3.1 Personally Identifiable Information.

We collect certain information that identifies you as an individual (collectively, “Personally Identifiable Information”). The Personally Identifiable Information we collect may include the following:

  • Your name;
  • Your phone number;
  • Your email address; and
  • Your company name
3.2 Non-Personally Identifiable Information.

We also collect technical and device-related information that is not Personally Identifiable Information, but instead identifies or may reasonably be used to identify a particular user device (collectively, “Non-Personally Identifiable Information”). Non-Personally Identifiable Information is typically collected automatically by technical means and, subject to Section 3.4 (Treatment of Combined Information), for purposes of our Website and Services, consists of the following:

  • Device identifiers, such as cookies;
  • Device information, such as hardware and software settings;
  • IP addresses and log information, such as your device’s name, the type and version of your web browser, and referrer addresses that can function to identify a user device; and
  • Tracking information that we, or a third party, may collect.
3.3 Anonymous Information.

Our Website also collects, processes, and/or uses information that does not identify you or your devices, including Personally Identifiable Information that has been made anonymous by: (i) removing identifying fields and aggregating the information with other information so that individual subjects of the information cannot be re-identified, or (ii) anonymizing the information with techniques that remove or modify the identifying data so as to prevent re-identification of the anonymized information (collectively, “Anonymous Information”). Information that meets these criteria might include, for example, demographic information, statistical information (e.g. page views and hit counts), and general tracking information.

3.4 Treatment of Combined Information.

If we combine Non-Personally Identifiable Information or Anonymous Information with Personally Identifiable Information, we treat the resulting combination as Personally Identifiable Information.

4. How We Collect this Information.

We collect the above information through the following means and technologies:

4.1 Contacting Gamalon.

You can contact us with questions or comments – for example, you can contact us to learn more about our services and products, to request a demo, or to inquire about career opportunities at Gamalon. In order to communicate with us, you must provide certain Personally Identifiable Information.

4.2 Job Applications and Inquiries.

You may submit information associated with a potential application for employment with us, and this information may include Personally Identifiable Information. In each instance, we collect the information you submit to us for various purposes, including to respond to your inquiries or to consider your candidacy for our employment opportunities.

4.3 Information Provided to Third Parties.

As explained further in Section 6.1 (Our Service Providers), we may engage third parties to perform certain services for us or on our behalf. The forms on our Website may be managed by such third parties, and we may obtain from the applicable service provider your information that you provide using such forms.

4.4 Newsletters.

We may offer newsletters and other content about Gamalon, our services and products, and other issues that we believe may be of interest to you. We will use your Personally Identifiable Information to provide you with this content. You can opt-out of receiving this content, by following the instructions set out in Section 11 (Your Right to Opt-Out; Object to Processing; Deleting Information).

4.5 Device Identifiers; Logs; IP Addresses.

To determine whether your device is supported by our Website and Services, we may collect certain information about your device and network, including your IP address, your operating system and browser, your device model, information about your use of the Website or Services, as well as the presence of any software that our Website or Services may require to operate with your device, or other third party software or mobile apps on your device. We automatically receive and record this information in log files, and this is generally Non-Personally Identifiable Information.

4.6 Cookies.

A cookie is a small amount of data that is sent to your browser from a website’s computers and stored on your computer’s hard drive. Cookies can be used to provide you with a tailored user experience and to make it easier for you to use a website upon a future visit. We may include cookies on our Website and use them to recognize you when you return to our Website. You may choose not to accept cookies; however, you may need to enable cookies if you wish to access certain personalized features of our Services. Cookies alone are typically Non-Personally Identifiable Information.

4.7 Beacons and Tags.

The Website may use certain data collection technologies that rely on (i) beacons; (ii) pixel tags and object hyperlinking tags, and (iii) other means to link an object to an Internet address, a remote software application, a remote database, or other remote means of receiving or processing information. We may use these technologies to tell us what parts of our Website have been visited or to measure the effectiveness of searches that users perform on our Website. These technologies also enable us to send email messages in a format users can efficiently read, to learn whether these email messages have been opened, and to help ensure, for example, that our messages are of interest to our users. These technologies provide us with Anonymous Information, Non-Personally Identifiable Information and, in certain instances, Personally Identifiable Information.

4.8 Click-Throughs.

We may send email messages or display links that use a “click-through URL” linked to our Website or to another resource. When you click one of these URLs, you pass through our web server before arriving at the destination website page or other resource. Click-throughs may use and collect Anonymous Information and Non-Personally Identifiable Information. We may track this click-through data to help determine interest in particular topics and measure the effectiveness of our user communications.

4.9 Other Technologies and Data Sources.

We may combine Personally Identifiable Information that you provide to us with other data, including demographic information (such as age, job industry, or job title) for purposes of responding to your inquiries or interest in employment opportunities, and for other purposes specified in this Privacy Policy. If information we combine in this manner includes your Personally Identifiable Information, we will treat the combined information as your Personally Identifiable Information for all purposes under this Privacy Policy.

5. How We Use this Information.

We use the information we collect or process, including Anonymous Information, Non-Personally Identifiable Information, and Personally Identifiable Information, as permitted under Applicable Law, including where the use is based on (i) the consent you provide to us at the point of collection; (ii) performance of our agreement to provide you with the Services; (iii) compliance with our legal obligations; and/or (iv) our Legitimate Interests, as well as a third party’s Legitimate Interests. More specifically, we use the information we collect for some or all of the following:

Our Uses of the Information Bases for Our Use
To provide you with the Services you request and, specifically, to allow us to send you email with information
  • Performance and management of our agreement with you
To conduct fraud monitoring, prevention, and detection activities
  • Our Legitimate Interests
To respond to your inquiries
  • Performance and management of our agreement with you
  • Our Legitimate Interests
To consider your submittals and other expressions of interest in connection with our career opportunities
  • Our Legitimate Interests
To customize your visit to and use of the Website and Services
  • Our Legitimate Interests
To determine which of our products, services, and content (including, if applicable, our newsletter) might interest you and, upon making this determination, to provide you with the associated information
  • Your consent
  • Our Legitimate Interests
To track access to and use of our Website and Services, and conduct data and other analyses, including anonymization and aggregation of Personally Identifiable Information
  • Our Legitimate Interests
To perform internal administration, auditing, operation, and troubleshooting for our Website and Services
  • Our Legitimate Interests
To engage in the activities specified in Section 6 (How We Share This Information)
  • Our Legitimate Interests
  • Compliance with our legal obligations
  • Performance and management of our agreement with you
To evaluate and improve our Website, Services, and our communications, and to develop and test new services and content
  • Our Legitimate Interests
To comply with Applicable Law
  • Compliance with our legal obligations

Note that when determining the bases for our use of your information, we rely on what we consider to be the most appropriate basis, even if there are multiple bases available in connection with our use.

6. How We Share this Information.

We value your privacy, and we share the information we collect only in the manner set out below.

6.1 Our Service Providers.

We engage third parties to perform functions on our behalf, and these may include functions such as maintaining the Website, collecting information, responding to and sending email or other messages, and other functions useful to our business. In this capacity, we may provide service providers with Personally Identifiable Information, Non-Personally Identifiable Information, and Anonymous Information as applicable. The following are examples:

  • We may use service providers to provide customer service (where applicable) or marketing support, such as to process and distribute email. These service providers generally require access to your Personally Identifiable Information in order to perform these services.
  • We may use analytics service providers to assist us in understanding and using Non-Personally Identifiable Information and other information that we collect via the Site. A service we use in this regard is Google Analytics, and information concerning how Google uses the information is available at https://policies.google.com/privacy/partners, and opt-out options specific to Google Analytics are available at https://tools.google.com/dlpage/gaoptout.
  • Our Site includes links to third party websites offering services that augment those services offered on our Site. For example, when you submit information in connection with indicating your interest in career opportunities at Gamalon, our third party service provider collects this information on our behalf, and then compiles and shares this information with us.
  • We may use service providers to anonymize and aggregate Personally Identifiable Information in order to generate Anonymous Information.
  • We may engage service providers to analyze the interests and attributes of our users and, using techniques based on Anonymous Information and Non-Personally Identifiable Information, identify others who might share those interests and attributes. We then use this information to reach out to relevant market segments to provide them information concerning the Website or Services.

We require our service providers to contractually commit to protect the privacy and security of the Personally Identifiable Information they process on our behalf.

We may disclose your Personally Identifiable Information and Non-Personally Identifiable Information to third parties, including law enforcement agencies, attorneys, and private investigator organizations, where it is necessary, or where we have a good faith belief that it is necessary:

  • To comply with legal process;
  • To protect and defend our rights and property, including the Website and associated content;
  • To protect against misuse or unauthorized use of our Website or Services;
  • To protect the personal safety or property of Website users or the public, including your personal safety or property (it being understood that we assume no duty to provide, or monitor the need for, such protections); and
  • To cooperate with public and government authorities including, where required, authorities outside your jurisdiction.

While you are not able to opt out of this use of information, we will take reasonable steps to limit such use, and disclose only the information we reasonably believe is necessary for the above purposes. If we receive legal process calling for the disclosure of your Personally Identifiable Information, we will attempt to notify you within a reasonable amount of time, unless such notification is not permitted.

6.3 Transfer of the Website.

We shall be entitled to transfer information that we collect (including Personally Identifiable Information) to a third party in connection with a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition (including a disposition in connection with a bankruptcy or similar proceedings) of all or substantially all assets or stock of the business unit or division responsible for the information under this Privacy Policy; provided the acquiring third party has agreed to safeguard your Personally Identifiable Information with protections that are compatible with those set out in this Privacy Policy.

6.4 Our Affiliates.

We may choose to rely on and share the information we collect with our affiliates. By “affiliate” we mean an entity that is closely related to us, such as an entity that controls, is controlled by, or is under common control with, Gamalon, Inc. Our affiliates will be bound by the terms of this Privacy Policy.

7. How We Safeguard the Information We Collect.

We recognize the sensitivity of our users’ Personally Identifiable information and we have put in place security systems designed to prevent unauthorized access to or disclosure of this information. Our security systems include physical, technical, and administrative information security controls, and we take commercially reasonable steps to secure and safeguard such Personally Identifiable Information in accordance with Applicable Law.

8. Our Retention of Data.

We retain Personally Identifiable Information for the period of time necessary to fulfill the purposes for which we obtained the Personally Identifiable Information and consistent with Applicable Law. We use the following criteria to set our retention periods: (i) the duration of our relationship with you; (ii) the existence of a legal obligation as to the retention period; and (iii) the advisability of retaining the information in light of our legal position (for example, in light of applicable statutes of limitations, litigation, or regulatory investigations).

9. Accuracy and Minimization of Data.

We take reasonable steps (i) to maintain the accuracy of the Personally Identifiable Information we process, and (ii) to limit the Personally Identifiable Information that we process to that which is reasonably necessary for the purposes for which we obtained the information.

10. Accessing and Updating Your Information.

If you would like to review, correct, or update the Personally Identifiable Information that you have provided to us, or if you would like to request an electronic copy of this Personally Identifiable Information for purposes of transmitting it to another company (to the extent Applicable Law provides you with this right to data portability) you may make such requests by us as provided in Section 17 (Contact Us).

11. Your Right to Opt-Out; Object to Processing; Deleting Information.

11.1 Unsubscribing to Email.

If you no longer wish to receive email messages from us, you can opt out of this Service by either (i) following the “unsubscribe” instructions located near the bottom of each email message, or (ii) contacting us as provided in Section 17 (Contact Us).

11.2 Deleting Information.

If you request, we will take reasonable steps to remove your name and email address from our databases, within the time frames (if any) set out in Applicable Law. Please understand, however, that if you request the deletion of your information, you will no longer be able to receive certain Services. In addition, it may be impractical (or essentially impossible) to remove the requested information completely, due to requirements promulgated by Applicable Law, and/or data backups and records of deletions. As such, certain Personally Identifiable Information may remain in our databases following the deletion of your account; we will continue to treat the remaining information (if any) in accordance with this Privacy Policy and Applicable Law.

11.3 Objections.

If you object to our processing of your Personally Identifiable Information, and a request for us to delete this information is not, in your view, sufficient, please contact us as provided in Section 17 (Contact Us).

11.4 Anonymous Information.

We will not delete Anonymous Information from our database, and nothing in this Privacy Policy restricts our use of Anonymous Information.

11.5 Your “Right to be Forgotten.”

If you are protected by the GDPR with respect to our use of your information, upon proper request, we will take the steps set out in the GDPR to erase your Personally Identifiable Information, including information that has may be publicly available via our Website.

12. Advisory Regarding Participation by Children and Teens.

Under U.S. Federal Law (as reflected in the Children’s Online Privacy Protection Act), WE DO NOT COLLECT OR STORE ANY PERSONALLY IDENTIFIABLE INFORMATION FROM INDIVIDUALS THAT WE KNOW ARE UNDER THE AGE OF 13. If you wish further information concerning privacy policies in general, and concerning online social networking and safety, you should visit the following website: http://www.ftc.gov/privacy/index.html.

13. Notice of Privacy Rights to California Residents.

California law requires certain businesses to respond to requests from California users who ask about business practices related to disclosing Personally Identifiable Information to third parties for direct marketing purposes. The California “Shine the Light” law further requires us to allow California residents to opt out of certain disclosures of Personally Identifiable Information to third parties for their direct marketing purposes.

14. Do Not Track Notice.

Our Website does not change its behavior when receiving “Do Not Track” signals from browser software.

15. Complaints.

We want your feedback. If you have a suggestions on how we can improve our Services or complaints you would like us to address, please contact us at the address set out in Section 17 (Contact Us). If you are a California resident, you may report complaints to the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs. Other states may provide similar avenues for lodging complaints. Please check with your state’s consumer protection authority.

If you are protected by the GDPR with respect to our use of your information, you may lodge a complaint with a data protection authority for your country or region. A list of EU data protection authorities is available at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

16. Changes to this Privacy Policy

From time to time, we may change this Privacy Policy for our business purposes and to comply with changes in Applicable Law. In the event of any substantive or material changes, we will communicate these changes to you by posting the updated Privacy Policy on the Website and/or notifying you of the change via the Website, email, or other methods. Your continued use of the Website following such notice constitutes your agreement to follow and be bound by the updated Privacy Policy.

17. Contact Us

If you have any questions about this Privacy Policy, our Website, or Services, please contact us at [email protected].

18. Definitions

Below are definitions applicable throughout this Privacy Policy. Additional terms are defined in context.

  • 18.1 “Anonymous Information” has the meaning set out in Section 3.3 (Anonymous Information). If you are protected by the GDPR with respect to our use of your information, the term “Anonymous Information” has the same meaning as information generated by a “pseudonymisation” processes, as that term is defined under the GDPR.
  • 18.2 “Applicable Law” means statutes, regulations, and any other laws that apply to the Website or the Services. For example, if you are protected by the GDPR with respect to our use of your information, the term “Applicable Law” includes the GDPR.
  • 18.3 “GDPR” means the European Union General Data Protection Regulation.
  • 18.4 “Legitimate Interest” means, for purposes of the GDPR, that there is a good reason for processing your Personally Identifiable Information, and that the processing is carried out in a way that minimizes impacts (if any) on your privacy rights and interests. The term “Legitimate interest” also refers to our use of information in ways that you would reasonably expect, based on your relationship to us. For example, there is a Legitimate Interest in collecting and processing your Personally Identifiable Information: (i) to safeguard our Website, Services, networks, content, and related information and resources; (ii) to administer and generally conduct our business; and (iii) to prevent fraud.
  • 18.5 “Non-Personally Identifiable Information” has meaning set out in Section 3.2 (Non-Personally Identifiable Information).
  • 18.6 “Personally Identifiable Information” has meaning as set out in Section 3.1 (Personally Identifiable Information). If you are protected by the GDPR with respect to our use of your information, the term “Personally Identifiable Information” has the same meaning as the term “personal data” under the GDPR.

The effective date of this Privacy Policy is April 9, 2019.