Nullafi Privacy Policy

Last Updated February 15, 2022

Your privacy is of the utmost importance to Joinesty Inc., doing business as Nullafi ( “Nullafi”, or “us” or “we”) and we take our obligations regarding your privacy seriously.

This Privacy Policy describes how we collect, use and disclose, and share, or otherwise process your personally identifiable information (“PII” or “personal data“) when you access or use our website www.Nullafi.com (“Website“), access or use our services, interact or participate in our programs, training, events and our other services offerings (collectively, the “Services”). 

For clarity, this Privacy Policy does not apply to your use of our licensed on-prem software (“Software”) once it is downloaded to your servers. Our licensed software does not communicate with Nullafi and we have no means to connect to the Software or means to extract any information from the Software.  

Otherwise, the categories of information we collect will depend on your interactions with us.

  1. Consent

By using our Services, you agree to the terms and conditions contained in this Privacy Policy and you expressly consent to the processing of your data in accordance with this Privacy Policy. If you do not agree to any of these terms and conditions, or approve of Nullafi’s data practices as explained herein, then you should immediately cease all use of our Services. To the fullest extent permitted by applicable law, you agree that any dispute over privacy or the terms contained in this Privacy Policy and Terms of Use, or any other agreement we have with you, will be governed by the laws of the state of Illinois or federal law if applicable. This section does not apply if you are based in the European Economic Area ("EEA") or Switzerland.

  1. What Data We Collect

Nullafi collects the following types of personally identifying information (“PII”):

  1. Information Provided by Website Visitors.

    If you decide to sign up for information from us, schedule a demo, attend a virtual event, or create an account to use the Services, Nullafi may collect the following PII from you: (1) first and last name, (2) organization name, (3) job title, (4) email address, (5) phone number, (6) location information including state/province and country, and (7) if applicable, a user-generated password for your account. If you provide us with feedback or contact us via email (e.g., in response to an employment opportunity posted on our Website), we will collect your name and email address, as well as any other content or information included in or attached to your email, in order to send you a reply. If you purchase Services or license Software from us, our third-party payment processor will collect payment account and other financial information which will be used to process your authorized payment.We may combine the information we collect directly from you with information we obtain from public sources, partners, and other third parties and use such combined information in accordance with this Privacy Policy.

  2. Information We May Collect through Technological Means.

    Our servers, which may be hosted by a third-party service provider, may collect certain technical data about your device and software, including your browser type, operating system, IP address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a time stamp of your visit. We automatically gather this data and store it in log files each time you visit our Website or access any other online Services we may make available from time to time.. We may also directly collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends in connection with the Services. We collect and use this analytics information in aggregate form such that it cannot reasonably be used to identify any particular individual user.

  3. Cookies, web beacons and other tracking technologies.

    We use various technical mechanisms such as cookies, web beacons and similar tracking technologies to monitor how users use our Services. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing a website. “Web beacons” refer to various tracking technologies used to check whether you have accessed some content on our Services. We use cookies for the following purposes, specifically:

    • Performance Cookies: These cookies allow us to count visits and traffic sources, so we can measure and improve the performance of our site. They help us know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies, we will not know when you have visited our site.
    • Functional Cookies: These cookies allow the provision of enhanced functionality and personalization, such as videos and live chats. They may be set by us or by third-party providers whose services we have added to our pages. If you do not allow these cookies, then some or all of these functionalities may not function properly.
    • Strictly Necessary Cookies: These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you that amount to a request for services, such as setting your privacy preferences, logging in, or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site may not work then.

We may link the information we store in cookies or through other mechanisms to the PII you submit while using our Services. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Services. You can remove persistent cookies at any time by following the directions in the “Help” section of your Internet browser. You can also disable all cookies on your Internet browser. If you choose to disable cookies, be advised that some components of our Services may not work properly.

Our partners, affiliates, and other service providers may use cookies and other technologies to improve the quality of your experience when you interact with our Services. We may receive reports based on the use of certain technologies by these companies on an individual and aggregated basis.

  1. How We Use the Data We Collect.

In summary, we use your PII to respond to your requests, provide, secure, and enhance the Services, make the licensed Software you order available to you, and comply with our legal obligations. In particular, Nullafi uses your PII for the following purposes as necessary and as permitted by applicable law:

  • Facilitate the creation of and secure any account on our Services;
  • Identify you as a user of our Software and Services;
  • Provide and administer your use of the Software and Services;
  • Personalize and improve the quality of your experience when you interact with our Services;
  • Send you a welcome e-mail to verify ownership of the e-mail address provided when your account was created;
  • Send you administrative e-mail notifications, such as security or support and maintenance messages;
  • Respond to your inquiries and requests;
  • Provide you with electronic newsletters, or surveys;
  • Determine which of our products and services may be of interest to you or your business;
  • Send you information about upgrades and special offers related to our Software or Services;
  • Comply with applicable laws and regulatory requirements;
  • Respond to lawful requests, court orders and legal process; and
  • Protect our legal interests or those with whom we do business.

We may generate reports that contain aggregate data about usage of our Services and similar topics. In such instances, we use aggregate data that cannot be used to reasonably identify any individual and does not contain PII.

We may also compile, use statistical or anonymized, non-personally identifiable information and use or transfer such information for any purposes; provided, however, that such data has been fully de-identified and cannot in any way be traced back to the customer or user and does not contain any personally identifiable information. We may also use such anonymized information publicly to show trends about the general use of our services.

Third-Party Online Analytics Services

In connection with our Website and emails, we use third-party online analytics services, such as those of Google Analytics. These analytics services use automated technologies to collect information (such as email address, IP address, and device identifiers) to evaluate, for example, use of our products and services and to diagnose technical issues. To learn about how Google Analytics collects and processes data, you can visit www.google.com/analytics/learn/privacy.html and https://policies.google.com/technologies/partner-sites.

  1. Information Sharing and Disclosure

To the extent permitted by applicable law, Nullafi may disclose your PII in the following circumstances:

  1. Service Providers.

    We may engage third-party companies or individuals to support us in connection with the purposes listed above, such as vendors to provide IT services and process payments.

  2. Law Enforcement.

    It may be necessary − by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence − for Nullafi to disclose your PII. We may also disclose your PII if we determine disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users.

  3. Business Transfer.

    We may share your PII if Nullafi engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of Nullafi’s assets, financing acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities (e.g. due diligence).

  4. Third Party Access.

    Our Software facilitates interactions between our it and other services and data sources you use. Third parties whose products or services you use in connection with our Software and Services, or third parties whose websites we link to, may have data information practices that are different from ours. This Privacy Policy does not apply to the activities of third parties when they are collecting or using data for their own purpose or on behalf of others. We are not responsible for the activities of these third parties. We encourage you to review their privacy policies to understand how they use your information.

  5. Prior Consent.

    We may also disclose your PII with your prior informed consent. Service providers acting on our behalf are obliged to adhere to confidentiality requirements no less protective than those set forth herein and will only receive access to your PII as necessary to perform their functions.

  1. How We Protect Your Data – Security

We are committed to protecting the security of information received through the Services, including PII. We provide reasonable and appropriate administrative, technical, and physical security controls to protect your PII from unauthorized access, use, or disclosure. For example, we use secure socket layer technology (SSL) in connection with our Services. We also require you to enter a password to access your account information. Please do not disclose your account password to anyone else. Despite our efforts, no security controls are 100% risk-free, and Nullafi does not warrant or guarantee that your PII will be secure in all circumstances. 

  1. Your Data, Your Choice

Please note if you are a California resident, please see Section IX “Additional Information for California Residents” below for more information about your privacy rights under California law.

  1. Opt-Out

    We offer you choices regarding the collection, use, and sharing of your PII. Where permitted by applicable law, we may periodically send you free newsletters and e-mails that directly promote the use of our products or services. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly. Despite your indicated e-mail preferences, we may send you notices of any updates to our Terms of Use or Privacy Policy.

  2. Ability to Edit or Delete Your Personal Information.

    You may request that we delete your account information by sending an email to privacy@nullafi.com, but please note that we may be required (by law or otherwise) to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). Nullafi will respond to such requests within thirty (30) days or sooner if required by applicable law. When we delete account information, it will be deleted from the active database, but may remain in our archives for a limited amount of time. We will otherwise retain your information for as long as your account is active, as needed to provide you with the Services you have requested, or as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

  3. Information Processed Under the Direction of Customers.

    If an organization has registered for the Services (a “Customer“) and your PII has been collected by Nullafi as a result of such organization’s use of the Services, Nullafi collects and processes any such PII of yours under the directions of the relevant Customer. If these circumstances apply to you and you wish to access, edit, delete or exercise any rights you may have under applicable data protection laws with respect to any PII that we have collected about you, please direct your query to the relevant Customer as this may expedite the completion of your request. We nevertheless provide reasonable assistance to our Customers to give effect to data subject rights as appropriate and required by applicable laws.

  1. Links to Third-Party Sites

Our provision of a link to any website or location outside of the Services is for your convenience and does not signify our endorsement of such other website or location or its contents. When you click on such a link, you will leave our site and go to another site. During this process, a third party may collect data, including PII, from you. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of data after you click on a link to a third party. We encourage you to carefully read the privacy statement of any other website you visit.

  1. Cross Border Data Transfers

Nullafi is located in the United States. By accessing or using the Services, or otherwise providing information to us, you understand that your information may be subject to processing, transfer, and storage in other locations. In the event that Nullafi transfers your Personal Data from the EEA to a country which is not subject to an adequacy decision by the European Commission or which may not provide for the same level of data protection as the EEA, Nullafi will ensure that the recipient of your Personal Data offers an adequate level of protection. This may include such measures as entering into standard contractual clauses for the transfer of data as approved by the European Commission, gaining prior consent, or other appropriate measures in accordance with applicable law.

  1. Additional Information for California Residents

If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and share your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)).

  1. How We Source, Use, and Disclose Information for Business Purposes

    The following chart details the categories of personal information we collect through our Services, the sources of such personal information, and how we use and share such information for business purposes.

{{TABLE}}

  1. Your California Privacy Rights.

    If you are a California resident, the CCPA allows you to make certain requests about your personal information. Specifically, the CCPA allows you to request us to:

    • Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we share/disclose personal information.
    • Provide access to and/or a copy of certain personal information we hold about you.
    • Delete certain personal information we have about you.
    • Provide you with information about the financial incentives that we offer to you, if any.

The CCPA further provides you with the right not to be discriminated (as provided for in applicable law) for exercising your rights. Please note that certain information may be exempt from such requests under California law. For example, we need certain information in order to provide our services to you. We also will take reasonable steps to verify your identity before responding to a request. In doing so, we may ask you for verification information so that we can match at least two verification points with information we maintain in our files about you. If we are unable to verify you through this method, we shall have the right, but not the obligation, to request additional information from you.Please also note that if your personal information has been collected by Nullafi as a result of a Customer’s (as defined above) use of our services, Nullafi collects and maintains your personal information under the directions of the relevant Customer. If these circumstances apply to you and you wish to access or delete any personal information that we have collected about you, please direct your query to the relevant Customer as this may expedite the completion of your request. We nevertheless provide reasonable assistance to our Customers to give effect to consumer choices as appropriate and required by applicable laws.If you would like further information regarding your legal rights under California law or would like to exercise any of them, or if you are an authorized agent making a request on a California consumer’s behalf, please contact us at privacy@nullafi.com.The CCPA provides certain rights if a company "sells" personal information, as such term is defined under the CCPA. We do not engage in activities that would be considered "sales" under the CCPA.Shine the Light Disclosure: The California "Shine the Light" law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes.

  1. Additional information for Nevada residents

Under Nevada law, certain Nevada consumers may opt out of the sale of “personally identifiable information” for monetary consideration (as such terms are defined under Nevada law) to a person or that person to license or sell such information to additional persons. We do not engage in such activity; however, if you are a Nevada resident and you have purchased products or services from us, you may submit a request to opt out of any potential future sales under Nevada law by emailing us at privacy@nullafi.com. Please note we may take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.

  1. Information about Children.

Our Services are not intended for use or access by children or minors. Nullafi does not knowingly collect or solicit information from anyone under the age of eighteen (18). If you believe Nullafi has inadvertently collected information about a child under the age of eighteen (18), please contact us at privacy@nullafi.com immediately.

  1. Changes to Our Privacy Policy

Nullafi reserves the right to change this Privacy Policy. Nullafi will provide notification of the material changes to this Privacy Statement through our Website and, where appropriate, by email to any email address of yours we may have on file, at least thirty (30) days prior to the change taking effect.

  1. Contact Us

Nullafi welcomes your comments, questions, and concerns regarding our Privacy Policy. Please contact us at privacy@nullafi.com or at our mailing address below:

Nullafi, Inc.

500 Lake Cook Road, Suite 350
Deerfield, IL 60015
USA

Supplemental GDPR Privacy Statement

This Supplemental GDPR Privacy Statement is relevant to any individual located in the EEA who uses the Services where these services directly link to this Supplemental GDPR Privacy Statement.

This Supplemental GDPR Privacy Statement does not cover any other data collection or processing, including, without limitation, through other Nullafi websites or online services that do not display a direct link to this Supplemental GDPR Privacy Statement, or through third-party websites.

European Union Regulation 2016/679 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 (“GDPR“), requires Nullafi to provide additional and different information about its data processing practices to data subjects in the EEA. If you are accessing the Services from a member state of the EEA, this Supplemental GDPR Privacy Statement applies to you.

For purposes of the GDPR, Nullafi, Inc., 500 Lake Cook Road, Suite 350, Deerfield, IL 60015, USA, is the data controller of your personal information. Where processing of personal information is undertaken by our affiliates, subsidiaries or related entities, they are a joint controller with Nullafi.

Legal Basis of Processing.

In general, the legal basis for Nullafi’s processing of your personal data in connection with the Services is Article 6(1)(b) of the EU GDPR, which allows processing of personal data as necessary for the performance of a contract. When you access, use or register for our Services, you form a contract with us based on the applicable terms of use or terms of service, and Nullafi needs to process your personal data to provide the requested Services.

As exceptions, Nullafi relies on your consent with respect to cookies that are not strictly necessary and direct marketing emails per Article 6(1)(a) of the EU GDPR; and pursues legitimate interests under Article 6(1)(f) of the EU GDPR with respect to situations where Nullafi needs to process your personal data to comply with applicable laws (as a U.S.-based company, Nullafi is subject to U.S. laws and must comply with them) or processes your personal data to improve our business and Services.

Personal Data Transfers outside of the EEA. Nullafi may transmit some of your personal data to a country where the data protection laws may not provide a level of protection equivalent to the laws in your jurisdiction, including the United States. As required by applicable law, Nullafi will provide an adequate level of protection for your personal data using various means, including, where appropriate:

  • relying on a formal decision by the European Commission that a certain country ensures an adequate level of protection for personal data (a full list of such decisions may be accessed online here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm);
  • entering into appropriate data transfer agreements based on language approved by the European Commission, such as the Standard Contractual Clauses (2010/87/EC and/or 2004/915/EC), which are available upon request at privacy@nullafi.com;
  • implementing appropriate physical, technical and organizational security measures to protect Personal Data against accidental or unlawful destruction, accidental loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing; and
  • taking other measures to provide an adequate level of data protection in accordance with applicable law.

Any onward transfer is subject to appropriate onward transfer requirements as required by applicable law.

Data Retention. Nullafi keeps personal data as long as required to provide the Services you have requested or registered for and comply with applicable laws.

Data Subject Rights. You have a right to request from Nullafi access to and rectification or erasure of your personal data or restriction of processing concerning you, as well as the right to data portability under the GDPR. You also have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data by us and we can be required to no longer process your personal data. In general, you have the right to object to our processing of your personal data for direct marketing purposes. If you have a right to object and you exercise this right, your personal data will no longer be processed for such purposes by us. You can exercise such rights by accessing the information in your account, submitting request by email to privacy@nullafi.com.

If you have provided consent for cookies that are not strictly necessary, direct marketing emails or other data processing based on your consent, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. You have the right to lodge a complaint with a supervisory authority.

Your Choices. You are not required to provide any personal data to Nullafi but if you do not provide any personal data to Nullafi, you cannot use the Services. You can use the Services without consenting to cookies that are not strictly necessary; the only consequence is that our Services will be less tailored to you or you will not receive our marketing emails. 

Profiling. Nullafi does not use in connection with the Services automated decision-making, including profiling, in a way that produces legal effects concerning you or which significantly affects you.

Categories of Personal Information Collected by Our Services
Sources of Personal
Information
Purposes for Use of Personal Information (see “How We Use the Data We Collect” for more information)
Disclosures of Personal Information for Business Purposes (see “Information Sharing and Disclosure” for more information)
Contact information (e.g., name, email address, phone number, mailing address including state/province, country)
  • You
  • Public Sources
  • Provide the Services and customer service
  • Communicate with you
  • Analyze use of and personalize the services
  • Improve the Services and Software
  • Provide security, prevent fraud, and for de-bugging
  • Comply with legal requirements
  • Service providers
  • Law enforcement in the event of a lawful request
  • With entities in the event of a business transaction
  • With your consent
  • Third-party services you select
Financial and transactional information (e.g., payment account information and purchase history)
  • You
  • Payment processors
  • Provide the Services and customer service
  • Facilitate your payments
  • Communicate with you
  • Analyze use of and personalize the Services
  • Improve the Services and Software
  • Provide security, prevent fraud, and for de-bugging
  • Comply with legal requirements
  • Payment processors
  • Law enforcement in the event of a lawful request
  • With entities in the event of a business transaction
  • With your consent
Login information (e.g., your account name and password)
  • Log in
  • Provide the Services and customer service
  • Provide security, prevent fraud, and for de-bugging
  • Comply with legal requirements
  • Service providers
  • Law enforcement in the event of a lawful request
  • With entities in the event of a business transaction
  • With your consent
Device and online identifier information (e.g., IP address, browser type, operating system, general location inferred from IP address, and similar information)
  • You, through your device
  • Provide the Services and customer service
  • Analyze use of and personalize the services
  • Improve the Services and Software
  • Provide security, prevent fraud, and for de-bugging
  • Comply with legal requirements
  • Service providers
  • Law enforcement in the event of a lawful request
  • With entities in the event of a business transaction
  • With your consent
Service usage information (e.g., the dates and times you use the Services, how you use the Services, and the content you interact with on the Services)
  • You, through your device
  • Provide the Services and customer service
  • Analyze use of and personalize the Services
  • Improve the Services and Software
  • Provide security, prevent fraud, and for de-bugging
  • Comply with legal requirements
  • Service providers
  • Law enforcement in the event of a lawful request
  • With entities in the event of a business transaction
  • With your consent
©Nullafi 2022. All rights reserved.
By clicking “Accept All Cookies”, you agree to the storing of cookies on your device to enhance site navigation, analyze site usage, and assist in our marketing efforts. View our Privacy Policy for more information.