Last Updated: April 26, 2022
iPolipo, Inc. dba Jifflenow (“Jifflenow”) values the privacy of our clients, their employees, their customers, and others (individually or collectively, “User” or “Users”) that visit our websites and/or use Jifflenow to manage meetings at B2B events such as trade shows, user forums, and that otherwise use www.Jifflenow.com and its associated websites, products, and services (collectively, the “Service”).
1 | The Information Jifflenow Collects
- Personal Information: In its course of business, Jifflenow collects Personal Information from its Users. This information includes contact information, such as their name, company name, address, business contact information, phone number, image such as your profile picture (optional), and e-mail address. Personal Information may not, however, include social security number, driver’s license number bank account information, credit rating, or other personal financial data.
- User Information: Users have the opportunity to share various types of information amongst themselves through use of the Service. You can upload and post meeting details, your bio, photo, personal links and other documents you wish to have accessible to other users. This content along with all other information related to your use of the Service, including, but not limited to, meeting times, meeting occurrences and meeting logistics is stored and maintained on Jifflenow’s third-party server hosting partners. Providing your Personal Information and any other information about you via the Services, is voluntary and this information will be visible to other users and should correlate with the degree of interaction you want to have with other users. Please be aware that any information that you choose to share on any publicly available portion of the Service or with third parties, including without limitation your personal page, calendar page, links to social network pages, blogs, may be collected and used by others without restriction.
- “Cookies” Information: When you access the Service, we may send one or more cookies – small text files containing a string of alphanumeric characters – to your computer. Jifflenow may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Service. Persistent cookies can be removed. Please review your web browser “Help” file to learn the best way to modify your cookie settings. Please note that disabling cookies may prevent you from accessing some of the functionality available via the Service.
- Log Information: When you visit the service, like many website’s our servers automatically record information that your browser sends whenever you visit a website (“Log Information”). This Log Information may include information such as your IP address, date and time, browser type and the domain from which you are visiting. For most users accessing the Internet from an Internet service provider (or “ISP”), the IP address will be different every time you log on. We do not use this information to identify you personally. We use it to analyse usage trends, administer the Site and the Service and for the Site’s technical maintenance.
2 | Children’s Privacy
Consistent with the federal Children’s Online Privacy Protection Act of 1998 (COPPA), we will never knowingly request personally identifiable information from anyone under the age of thirteen (13) without requiring parental consent, and no part of the Service is directed to persons under 13. Any person who provides their personal information to Jifflenow represents that they are 13 years of age or older.
3 | The Way Jifflenow Uses Information
- Jifflenow uses the information that we collect to provide you all of the features and services found on the Service. We will use your email address, without further consent, for non-marketing or administrative purposes such as notifying you of major site updates.
- Jifflenow may use all of the information that we collect from our Users to understand the usage trends and preferences, to improve the way the Service works and looks, to improve our marketing and promotional efforts, and to create new features and functionality.
- Jifflenow may use automatically collected information and cookies information to remember your information so that you will not have to re-enter it during your visit or the next time you use the Service.
- Jifflenow will not use your email address or other personally identifiable information to send promotional or marketing messages without your consent or except as part of a specific program or feature for which you will have the ability to opt-in.
4 | When Jifflenow Shares Information
- As a service provider, we do not independently use or disclose Personal Information transferred to us by, or on behalf of, a Client or an User for any purpose other than to process that information in order to fulfil our contractual business processing functions, except as required or permitted by law. Furthermore, we take all commercially reasonable steps to safeguard the Personal Information we hold against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, regardless of the format in which the Personal Information is held. The precise nature of the safeguards we employ will vary depending on (i) the sensitivity of the Personal Information at issue, (ii) the format in which it is held, and (iii) the manner in which it is stored.
- Compliance with Laws and Law Enforcement. Jifflenow cooperates with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including subpoenas), to protect the property and rights of Jifflenow or a third party, to protect the safety of the public or any person, or to prevent or stop any illegal, unethical or legally actionable activity. If a user elects to use our referral service for informing a friend about our site, we ask them for the friend’s name and email address. Jifflenow will automatically send the friend a one-time email inviting them to visit the site. Jifflenow does not store this information.
5 | Our Commitment to Data Security
- We use secure server software and firewalls to protect your personally identifiable information from unauthorized access, disclosure, alteration, or destruction. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of such firewalls and secure server software.
- No data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk. Once we receive your transmission, we make reasonable efforts to ensure security on our systems.
- If Jifflenow learns of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. Jifflenow may post a notice on the Service if a security breach occurs. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive a free written notice of a security breach you should notify us at email@example.com.
6 | Change of Ownership or Other Business Transition
7 | Log Files and Backups
- Like most Internet services, we use log files, both on the client and server side. The data held in log files includes your IP address, browser type, e-mail application, Internet service provider (“ISP”), referring/exit Web pages, computer platform type, date/time stamp, and user activity. Jifflenow uses server log data to analyse trends, administer the Services and the Site, and improve service levels. IP addresses are not tied to any Personally Identifiable Information.
- The Software has associated log and temporary files that are stored on your local hard drive and on Jifflenow’s servers. These files store Your Account Information, your permissions, preference settings, system notifications as well as other data necessary to operate the Jifflenow services.
Your Information may also exist temporarily within regularly performed server backups
- We do not and will not, at any time, request your credit card information, your Jifflenow user name, login password, or national identification numbers in a non-secure or unsolicited e-mail or telephone communication.
- Identity theft and the practice currently known as “phishing” are of great concern to Jifflenow. Safeguarding information to help protect you from identity theft is our priority.
8 | Your Choices: Providing, Changing or Deleting Your Information
You may, of course, decline to share your personally-identifiable information with Jifflenow, in which case Jifflenow will not be able to provide to you some or all of the features and functionality found on the Service. All Users may review, update, correct or delete the Personal Information in their registration profile. Non-Users may also request deletion of their Personal Information from our servers. If Users completely delete any such information, their use of the Services may be limited or terminated. If you would like us to delete your records in our system, please contact us and we will attempt to accommodate your request. See below for privacy contact information.
9 | Data Retention
We reserve the right to retain your Personal Information or other data collected from you as a result of your use of the Services to prevent fraud and misuse of the Services.
10 | Security and International Transfer
Jifflenow is very concerned with safeguarding your information. We employ administrative, physical and electronic measures designed to protect your information from unauthorized access. Your information may be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. Jifflenow transfers Personal Information to the United States and maintains and processes it there. You consent to such transfer.
11 | Links
12 | Government Authority
13 | How do we train and manage our associates?
We educate our associates about our information security policies and practices, and use reasonable efforts to help ensure that our associates comply with these policies and practices. These efforts include: Conducting appropriate background checks of all newly-hired associates; Including information on Jifflenow’s policies in our associate orientation process; Requiring associates to execute appropriate non-disclosure agreements; Including information on our policies and practices on the Jifflenow website; Disseminating information on our policies and procedures to associates at appropriate intervals; Limiting access to Personal Information to associates with a business need for seeing it; Promptly ending associate access to systems and facilities upon termination of associate services; Monitoring associates for compliance with policies; and imposing appropriate disciplinary measures for breaches of policies and procedures.
14 | How do we ensure the security of our facilities?
We use third-party server hosting partners’ highly secure to host all our applications. We may also host your Personal Information on our servers. Please contact us at firstname.lastname@example.org for further information about security at our third-party server hosting partner or our servers.
15 | How do we ensure the security of our information systems?
Information systems include network and software design, as well as information processing, storage, transmission, retrieval and disposal. We employ policies and practices to protect Personal Information throughout its life cycle – from data entry to data disposal. These policies and practices include, among other things:
- Requiring use of virus protection software on all computer systems attached to Jifflenow client server network;
- Limiting all access to Jifflenow resources and networks to approved configurations and utilizing appropriate identification and authentication methods;
- Utilizing firewalls (which are configured and maintained in accordance with industry-standard procedures and specifications);
- Requiring appropriate disposal of all documents and electronic media containing Personal Information;
- Employing appropriate intrusion detection, monitoring, and logging capabilities to enable detecting and responding to potential security breaches;
- Maintaining appropriate incident handling procedures for responding to any breaches;
- Regularly obtaining and installing patches to address software vulnerabilities;
- Developing Client applications utilizing appropriate security methods including multiple-factor authentication, strong passwords, session time-outs, and access controls;
- Encrypting of Data in transit, rest and backups.
- Maintaining adequate disaster recovery and business continuity plans for all core functions.
16 | What additional safeguards do we have in place to protect Personal Information?”
Due to the constantly changing nature of technologies and security concerns, we conduct appropriate, periodic reviews of our security policies and practices. Additionally, periodic assessments are conducted as appropriate. All allegations of system or data misuse (by associates, contractors or any third parties) are thoroughly investigated by Jifflenow in accordance with our policies, and reported to law enforcement authorities where appropriate.
17 | How long will we retain Personal Information?
We may keep a record of User’s Personal Information, correspondence or comments in a file specific to the Client, to which access by our associates and by any third parties with whom we contract will be strictly limited on a business need-to-know basis. We will retain User’s Personal Information for as long as necessary to fulfil the purposes for which it was transferred to us, or as required or permitted by law. We have established minimum and maximum retention periods, as well as appropriate procedures for the destruction and disposal of Personal Information.
18 | How do we update Personal Information such that it is sufficiently accurate for processing purposes?
As a service provider of business processing functions, we rely on our Users to provide us with updated Personal Information on an ongoing basis, as necessary in relation to our provision of the services. Upon receipt of updated Personal Information, we will amend the User’s Personal Information that we hold where such amendment is reasonably necessary to enable us to continue providing the services to the Client in accordance with our contractual obligations as a service provider. This updating of Personal Information is rarely performed.
19 | Copyright Infringement/DMCA Notice
If you believe that any content on our website violates your copyright, and wish to have the allegedly infringing material removed, the following information in the form of a written notification (pursuant to the Digital Millennium Copyright Act of 1998 (“DMCA Takedown Notice”) must be provided to our designated Copyright Agent. It is our policy to terminate the accounts of repeat infringers.
- Your physical or electronic signature;
- Identification of the copyrighted work(s) that you claim to have been infringed;
- Identification of the material on our services that you claim is infringing and that you request us to remove;
- Sufficient information to permit us to locate such material;
- Your address, telephone number, and e-mail address;
- A statement that you have a good faith belief that use of the objectionable material is not authorized by the copyright owner, its agent, or under the law; and
- A statement that the information in the notification is accurate, and under penalty of perjury, that you are either the owner of the copyright that has allegedly been infringed or that you are authorized to act on behalf of the copyright owner.
Ipolipo’s Copyright Agent to receive DMCA Takedown Notices is Sridhar Ranganathan, Sridhar.email@example.com, at Ipolipo Inc., Attn: DMCA Notice, 1245, S. Winchester Blvd., Suite 201, San Jose, CA 95128. You acknowledge that for us to be authorized to take down any content, your DMCA takedown notice must comply with all the requirements of this Section. Please note that, pursuant to 17 U.S.C. § 512(f), any misrepresentation of material fact (falsities) in a written notification automatically subjects the complaining party to liability for any damages, costs and attorney's fees incurred by us in connection with the written notification and allegation of copyright infringement.
20 | California Consumer Privacy Act
- Right to Request Personal Information. Upon request, we will provide you with (i) a list of all Personal Information that we have collected on you, (ii) from whom we obtained such Personal Information, (iii) the reason why we collected such Personal Information, and (iv) with whom (if any) we have shared such Personal Information. We do not sell your Personal Information, but if we sell or disclose your Personal Information to third parties, upon request, we will provide you with (i) a list of the Personal Information that we have collected on you, (ii) a list of the Personal Information that we sell or disclose to others on you, and (iii) to whom we have sold or disclosed your Personal Information. A consumer can make such a request only twice in a 12-month period. We require such Personal Information to be able to provide to you our Services. Unless otherwise specified, we only collect Personal Information from you. We do not use others to provide us with your Personal Information.
- Disclosure of Personal Information. We only share your Personal Information with service providers, who enable us to provide our Services to you. We do not sell or give your Personal Information to third parties for purposes unrelated to our provision of Services to you.
- Right to have Personal Information Deleted. Upon request, we will delete all of your Personal Information that we have collected on you and will direct our Service Providers to also delete all of your Personal Information. But note that if we do delete all of this Personal Information, you will no longer be able to use our Services.
- Non-Discrimination Right. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, if you exercise any of your CCPA rights, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
- Financial Incentives. However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
- Under 16. We will not sell your Personal Information if you are under the age of 16 unless we have the consent of your parent or your guardian nor will we sell it if you ask us not to do so.
- Opt Out Right. Upon your request, we will stop selling your Personal Information (sometimes called your Opt Out Right). You may send the request to Opt Out (i) to firstname.lastname@example.org, or (ii) by writing to us at Privacy Officer, 3300 Douglas Blvd., Suite 260, Roseville CA 95661
- Personal Information that We Store. For your information, we store/collect the following Personal Information on you:
- First Name
- Last Name
- Business Email
- Job Title
- Business Phone
- Image such as your Profile Picture (Optional)
- Personal Information. We do not want you to enter your personal home address, your personal email, or any other “personal” information.
21 | LGPD for Brazilian Individuals
Data Breach: In the event of a personal data breach, we will notify the User within 72 hours via (i) email, and/or (ii) our Platform notification system on our Website/Platform. We agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.
22 | GDPR
For our European visitors, consumers, and customers:
If you are a resident of or a visitor to Europe, you have certain rights with respect to the processing of your Personal Data, as defined in the GDPR.
Please note that in some circumstances, we may not be able to fully comply with your requests, or we may ask you to provide us with additional information in connection with your request, which may be Personal Data, for example, if we need to verify your identity or the nature of your request.
In such situations, however, we will still respond to let you know of our decision. As used herein, “Personal Data” means any information that identifies you as an individual, such as name, address, email address, IP address, phone number, business address, business title, business email address, company, etc.
To make any of the following requests, contact us using the contact details referred to in the “Contact Information” section of this Policy.
- Access: You can request more information about the Personal Data we hold about you. You can also request a copy of the Personal Data.
- Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by logging into your service account. Please contact us as soon as possible upon noticing any such inaccuracy or incompleteness.
- Objection: You can contact us to let us know that you object to the collection or use of your Personal Data for certain purposes.
- Erasure: You can request that we erase some or all of your Personal Data from our systems.
- Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
- Portability: You have the right to ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another entity where technically feasible.
- Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, it may limit your ability to use some/ all of our Services and you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
- Right to File Complaint: You have the right to lodge a complaint about our practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. Please go to https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm to locate your Data Protection Authority.
European Data Protection Officer. Pursuant to Article 27 of the GDPR, we have appointed European Data Protection Officer (“EDPO”) as our GDPR representative in the European Union. You can contact EDPO regarding matters pertaining to the GDPR by:
23 | EU Standard Contractual Clauses
Obligations of the data importer (processors)
The data importer agrees and warrants:
- to process the personal data only on behalf of the data exporter and in compliance with its instructions and the Clauses; if it cannot provide such compliance for whatever reasons, it agrees to inform promptly the data exporter of its inability to comply, in which case the data exporter is entitled to suspend the transfer of data and/or terminate the contract;
- that it has no reason to believe that the legislation applicable to it prevents it from fulfilling the instructions received from the data exporter and its obligations under the contract and that in the event of a change in this legislation which is likely to have a substantial adverse effect on the warranties and obligations provided by the Clauses, it will promptly notify the change to the data exporter as soon as it is aware, in which case the data exporter is entitled to suspend the transfer of data and/or terminate the contract;
- that it has implemented the technical and organizational security measures before processing the personal data transferred;
- that it will promptly notify the data exporter about:
- any legally binding request for disclosure of the personal data by a law enforcement authority unless otherwise prohibited, such as a prohibition under criminal law to preserve the confidentiality of a law enforcement investigation,
- any accidental or unauthorized access, and
- any request received directly from the data subjects without responding to that request, unless it has been otherwise authorized to do so;
- to deal promptly and properly with all inquiries from the data exporter relating to its processing of the personal data subject to the transfer and to abide by the advice of the supervisory authority with regard to the processing of the data transferred;
- at the request of the data exporter to submit its data processing facilities for audit of the processing activities covered by the Clauses which shall be carried out by the data exporter or an inspection body composed of independent members and in possession of the required professional qualifications bound by a duty of confidentiality, selected by the data exporter, where applicable, in agreement with the supervisory authority;
- to make available to the data subject upon request a copy of the Clauses, or any existing contract for sub-processing, unless the Clauses or contract contain commercial information, in which case it may remove such commercial information, with the exception of Appendix 2 which shall be replaced by a summary description of the security measures in those cases where the data subject is unable to obtain a copy from the data exporter;
- that, in the event of sub-processing, it has previously informed the data exporter and obtained its prior written consent;
Obligations of the data exporter
The data exporter agrees and warrants:
- that the processing, including the transfer itself, of the personal data has been and will continue to be carried out in accordance with the relevant provisions of the applicable data protection law (and, where applicable, has been notified to the relevant authorities of the Member State where the data exporter is established) and does not violate the relevant provisions of that State;
- that it has instructed and throughout the duration of the personal data processing services will instruct the data importer to process the personal data transferred only on the data exporter's behalf and in accordance with the applicable data protection law and the Clauses;
- that the data importer will provide sufficient guarantees in respect of the technical and organizational security measures;
- that after assessment of the requirements of the applicable data protection law, the security measures are appropriate to protect personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access, in particular where the processing involves the transmission of data over a network, and against all other unlawful forms of processing, and that these measures ensure a level of security appropriate to the risks presented by the processing and the nature of the data to be protected having regard to the state of the art and the cost of their implementation;
- that it will ensure compliance with the security measures;
- that, if the transfer involves special categories of data, the data subject has been informed or will be informed before, or as soon as possible after, the transfer that its data could be transmitted to a third country not providing adequate protection within the meaning of Directive 95/46/EC;
- to make available to the data subjects upon request a copy of the Clauses, with a summary description of the security measures, as well as a copy of any contract for sub-processing services which has to be made in accordance with the Clauses, unless the Clauses or the contract contain commercial information, in which case it may remove such commercial information; and
- that, in the event of sub-processing, the processing activity is carried out in at least the same level of protection for the personal data and the rights of the data subject as the data importer under the Clauses.
- The parties agree that any data subject, who has suffered damage as a result of any breach of the obligations referred above by any party or sub-processor is entitled to receive compensation from the data exporter for the damage suffered.
- If a data subject is not able to bring a claim for compensation in accordance with paragraph a against the data exporter, arising out of a breach by the data importer or his sub-processor of any of their obligations referred to above, because the data exporter has factually disappeared or ceased to exist in law or has become insolvent, the data importer agrees that the data subject may issue a claim against the data importer as if it were the data exporter, unless any successor entity has assumed the entire legal obligations of the data exporter by contract of by operation of law, in which case the data subject can enforce its rights against such entity.
iPolipo, Inc. DBA Jifflenow
3300 Douglas Blvd., Suite 260, Roseville CA 95661