Privacy Policy

Effective as of November 1, 2021, Dozuki, Inc., (“Dozuki”) and its subsidiaries (collectively, the “Dozuki” or “we” or “us” or “our”) have updated our Privacy Policy (“Policy”). See the previous policy here.

This Policy details our commitment to protecting the privacy of individuals:

• who visit our Websites (as herein defined) (“Website Visitors”),
• who are authorized to use our Services through a Subscriber’s Account (“Users”), or
• who attend or register to attend events which we organize or co-organize (“Attendees”).

For the purposes of this Policy, the following terms are defined as:

“Websites” shall refer collectively to www.dozuki.com, portal.dozuki.com as well as the other websites that Dozuki operates and that link to this Policy.

“Services” shall refer to our on-demand work instruction and training platform, and tools and services made available from the Websites.

“Subscriber” shall refer to an individual or an entity that has agreed to a Service Agreement for use of our Services, including an individual representing the Subscribing company.

“Account” shall mean all Dozuki accounts or instances created by or on behalf of Subscriber within the Service.

“User” shall refer to individuals associated with an Account.

“Personal data” means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or by reference to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

“Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether by automated means or not, such as collecting, recording, organizing, structuring, storing, adapting or altering, retrieving, consulting, use, disclosing by transmission, disseminating or otherwise making available, aligning or combining, restricting, erasing or destroying.

“Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and methods of the processing of personal data.

“Recipient” means a natural or legal person, public authority, agency or another body, to which the personal data is disclosed, whether a third party or not.

In this Policy, personal information means information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to one or more factors specific to his/her physical, physiological, mental, economic, cultural or social identity.

Personal information does not include “Usage Data” which we define as encoded or pseudonymized information or aggregated data we collect about a group or category of services, features or users. Usage Data helps us understand trends in usage of the Service so that we can better consider new features or otherwise tailor the Service. In addition to collecting and using Usage Data ourselves, we may share Usage Data with third parties, including our customers, partners and service providers, for various purposes, including to help us better understand our customers’ needs and improve the Service as well as for advertising and marketing purposes. We do not share Usage Data with third parties in a way that would enable them to identify any user personally.

Our Websites may contain links to other websites; the information practices and the content of such other websites are governed by the privacy statements of such other websites. We encourage you to review the privacy statements of any such other websites to understand their information practices.

If you have purchased a subscription to our Services additional terms relating to data rights are set forth in and governed by our Terms of Service, available here: Dozuki Terms and Conditions, or such other applicable agreement between you and any member of Dozuki relating to your access to and use of such Services (“Service Agreement”).

We may process certain personal data as a data processor for our Subscribers. Subscribers to our Services act as data controllers and are solely responsible for establishing policies for and ensuring compliance with all applicable laws and regulations, as well as any and all privacy policies, agreements or other obligations, relating to the collection of personal information in connection with the use of our Services by individuals with whom our Subscribers interact. If you are an individual who interacts with a Subscriber using our Services, then you will be directed to contact our Subscriber for assistance with any requests or questions relating to your personal information processed in connection with such interaction.

We may transfer personal information to companies that help us provide our Services to Subscribers. Our processing of personal data under the direction of our Subscribers and transfers to subsequent third parties for these purposes are governed by the Service Agreements with our Subscribers, including the data processing agreement.

Account and Registration Information:

If you are Subscriber, we ask for and collect personal information about you such as name, address, phone number, email address, address, company name, website name, and billing information. A third-party intermediary is used to manage credit card processing.

If you are a User within a subscriber’s account, we ask for and collect personal information about you such as name, email address and alias.

We refer to any information described above as “Account Information” for the purposes of this Policy. By voluntarily providing us with Account Information, you represent that you are the owner of such personal data or are otherwise authorized to provide it to us, specifically. If you as a Subscriber provide us Account Information related to the User, you represent that the User has not objected to such processing.

Submissions by the Website Visitor:

We ask for and collect personal information such as your name, address, phone number and email address from you when you submit web forms on our Websites or as you use interactive features of the Websites, including, participation in surveys, contests, promotions, sweepstakes, providing user feedback, requesting customer support, or communicating with us.

Attendee Information:

We ask for and collect personal information such as your name, address, phone number and email address when you register for or attend an event as an Attendee.

Cookies and Other Tracking Technologies:

We and our authorized partners use cookies and other information gathering technologies for a variety of purposes. These technologies may provide us with information about devices and networks you utilize to access our Websites, and other information regarding your interactions with our Websites for purposes of making our Websites more user-friendly, effective, and secure.

We partner with third parties to manage our advertising on other sites. Our third party partners may use technologies such as cookies to gather information about your activities on our Websites and other sites in order to suggest advertisements based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the EEA or the United Kingdom click here). Please note this does not opt you out of being served ads and you will continue to receive generic ads. If you do not wish to accept any cookies, you can configure your browser to prevent cookies from being stored on your device or so that a message always appears before a new cookie is created; however, if you disable cookies, you may not be able to use all the features of our website.

Web beacons, tags and scripts may be used on our Websites or in email or other electronic communications we send to you. These assist us in delivering cookies, counting visits to our Websites, understanding usage and campaign effectiveness and determining whether an email has been opened and acted upon. We may receive reports based on the use of these technologies by our third-party service providers on an individual and aggregated basis.

Logs:

As is true with most websites and services delivered over the Internet, we gather certain information and store it in log files when you interact with our Websites and Services. This information includes internet protocol (IP) addresses as well as browser type, internet service provider, URLs of referring/exit pages, operating system, date/time stamp, information you search for, locale and language preferences, identification numbers associated with your devices, your mobile carrier, and system configuration information. Occasionally, we connect personal information to information gathered in our log files as necessary to improve our Websites and Services. In such a case, we would treat the combined information in accordance with this Policy.

Analytics:

We collect analytics information when you use the Websites to help us improve them. We may also share pseudonymized or aggregated data about your actions on our Websites with third-party service providers of analytics services.

We use the information we collect about you (including personal information, to the extent applicable) to (a) provide, operate, maintain and improve the Services (including delivering Website Visitor’s feedback to our Users); (b) enable you to access and use the Services; (c) process and complete transactions, and send you related information, including purchase confirmations and invoices; (d) send transactional messages, including responses to your comments, questions, and requests; provide customer service and support; and send you technical notices, updates, security alerts, and support and administrative messages; (e) send promotional communications, such as providing you with information about products and services, features, surveys, newsletters, offers, promotions, contests, and events; and provide other news or information about us and our partners. (f) process and deliver contest or sweepstakes entries and rewards; (g) monitor and analyze trends, usage, and activities in connection with the Websites and Services and for marketing or advertising purposes; (h) investigate and prevent fraudulent transactions, unauthorized access to the Services, and other illegal activities; (i) personalize the Websites and Services, including by providing features or advertisements that match your interests and preferences; and (j) comply with our legal obligations, including our obligations related to personal data protection.

Learn more about your rights as a data subject of the European Union.

We process your information for the purposes described in this Policy, based on the following legal grounds:

(i) When we’re pursuing legitimate interests

We process your information for our legitimate interests and those of third parties. This means that we process your information for things like: Providing, operating; maintaining, and improving our Services (including delivering Website Visitor’s feedback to our Users); enabling you to access and use the Services; promoting the Services; sending promotional communications, monitoring and analyzing trends, usage, and activities in connection with the Websites and Services; investigating and preventing fraudulent transactions, unauthorized access to the Services, and other illegal activities; personalizing the Websites and Services.

(ii) When we’re providing a service

We process your data to provide a service you’ve asked for under the Service Agreement or other contract between you and us. This means that we process your information for things like: Enabling you to access and use the Services; processing transactions, and sending you related information; providing customer service and support; personalizing the Websites and Services.

(iii) When we’re complying with legal obligations

We’ll process your data when we have a legal obligation to do so, for example, if we’re responding to legal process or an enforceable governmental request.

(iv) With your consent

We may ask for your agreement to process your information for specific purposes and you have the right to withdraw your consent at any time. For example, we ask for your consent to publish your testimonial, if it includes your identification. If you wish to withdraw your consent, you can contact us at legal@dozuki.com.

Third-Party Service Providers:

We share information, including personal information, with our third-party service providers that we use to provide hosting for and maintenance of our Websites, application development, backup, storage, payment processing, analytics and other services for us. These third-party service providers may have access to or process your personal information for the purpose of providing these services for us. We do not permit our third-party service providers to use the personal information that we share with them for their marketing purposes or for any other purpose than in connection with the services they provide to us.

Compliance with Laws and Law Enforcement Requests; Protection of Our Rights:

In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may disclose personal information to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. We may also share such information if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Service Agreement or Website Terms, or as otherwise required by law.

Testimonials:

From time to time, we may post testimonials on the Websites that may contain personal information. We obtain your consent to post your name along with your testimonial. If you wish to update or delete your testimonial, you can contact us at legal@dozuki.com.

Referrals:

If you choose to use our referral service to tell a friend about our products and services, we will ask you for your friend’s name and email address. We will automatically send your friend an email inviting him or her to visit the Websites and will store this information for the purpose of sending this initial email, tracking the success of our referral program and other marketing activities. Your referral may contact us at legal@dozuki.com to request that we remove his/her information from our database.

Interactive Areas:

The Websites may offer feedback forms, comments sections, discussion forums, or other interactive features (“Interactive Areas”). You should be aware that any information that you post in an Interactive Area might be read, collected, and used by others who access it, in particular to Users who initiated the particular Interactive Area. To request removal of your personal information from an Interactive Area, contact us at legal@dozuki.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

Dozuki Sharing:

We may share information, including personal information, with any member of the Dozuki.

With Your Consent:

We may also share personal information with third parties when we have your consent to do so.

We primarily store personal information about Website Visitors and Subscribers within the European Economic Area (the “EEA”) and in the United States. To facilitate our global operations, we may transfer and access such personal information from around the world, including from other countries in which the Dozuki Group has operations. If and when transferring your personal data from EEA, United Kingdom or Switzerland, we rely on the Standard Contractual Clauses adopted by the Commission as appropriate safeguards.

Dozuki complies with the EU-U.S. Privacy Shield Framework and the Swiss – 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 and Switzerland to the United States, respectively. Dozuki 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 https://www.privacyshield.gov/. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact JAMS, our U.S.-based third party dispute resolution provider (free of charge), at https://www.jamsadr.com/eu-us-privacy-sh....

For residual Privacy Shield disputes that cannot be resolved by the methods above, you may be able to invoke a binding arbitration process under certain conditions. To find out more about the Privacy Shield’s binding arbitration scheme, please see: https://www.privacyshield.gov/article?id...

If we have received your personal information under the Privacy Shield and subsequently transfer it to a third party service provider for processing, we will remain responsible if they process your personal information in a manner inconsistent with the Privacy Shield Principles, unless we prove that we are not responsible for the event giving rise to the damage.

The Federal Trade Commission has investigation and enforcement authority over our compliance with the Privacy Shield.

In July 2020, the Court of Justice for the European Union (EJC) issued a ruling in a case examining transfers of data from the EU. While the EJC’s ruling invalidates Privacy Shield as a mechanism for data transfer between the EU, United Kingdom, Switzerland and the U.S., it does not change your ability to transfer data and you may continue using Dozuki services leveraging Standard Contractual Clauses as the means to comply with the EU, United Kingdom and Switzerland data protection laws.

Dozuki maintains its participation in the Privacy Shield framework and continues to adhere to all core Privacy Shields privacy principles that support any approach to data transfers.

We offer those who provide personal contact information a means to choose how we use the information provided. You can opt-out of receiving marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of our marketing emails or you may send a request to legal@dozuki.com.

Upon request we will provide you with information about whether we hold and otherwise process, or process on behalf of a third party, any of your personal information. To request this information please contact us at legal@dozuki.com. Subscribers to our Services may update or change their Account Information by editing their profile or organization record or by contacting support@dozuki.com for more detailed instructions. To make a request to have personal information maintained by us returned to you or removed, please email support@dozuki.com. Requests to access, change, or remove your information will be handled within 30 days.

An individual who seeks access to, or who seeks to correct, amend, or delete inaccuracies in personal information stored or processed by us on behalf of a Subscriber should direct his/her query to the Subscriber (the data controller). Upon receipt of a request from one of our Subscribers for us to remove the data, we will respond to their request within thirty (30) days. We will retain personal information that we store and process on behalf of our Subscribers for as long as needed to provide the Services to our Subscribers. We will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

If you are a Subscriber or otherwise provide us with personal information in connection with your use of our Websites or Services, we will delete this information upon your request, provided that, notwithstanding such request, this information may be retained for as long as you maintain an account for our Services, or as needed to provide you with our Services (in particular for Accounts with multiple Users where we need to retain the interaction with Users who continue to use the Services), comply with our legal obligations, resolve disputes and enforce our agreements.

If you reside in EEA or the United Kingdom and provided us with your personal information based on a contract with us, you may ask us to export such personal information in a structured, commonly used and machine-readable format and you have the right to transmit those data to another controller. To request such export please contact us at support@dozuki.com.

If you reside in EEA or the United Kingdom, you may object to the way and scope how we process you personal data. To do so please contact us at legal@dozuki.com. You can object to receiving of marketing and non-transactional communications also by clicking on the “unsubscribe” link located on the bottom of our marketing emails.

If you reside in EEA or the United Kingdom, you may lodge a complaint with a local supervisory authority if you consider that our processing of your personal data relating infringes applicable data protection laws. We would be happy if you reach to us before filing the complaint.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdo....

The security of your personal information is important to us. We follow generally accepted, reasonable, and appropriate standards to protect the personal information submitted to us, both during transmission and once it is received. In deciding what is reasonable and appropriate we take into account the risks involved and the nature of the information. If you have any questions about the security of your personal information, you can contact us at legal@dozuki.com.

We do not knowingly collect any personal information from children under the age of 16. If you are under the age of 16, please do not use or submit any personal information through our Websites or Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide personal information through the Websites or Services without parental permission. If you have reason to believe that a child under the age of 16 has provided personal information to us through the Websites or Services, please contact us at legal@dozuki.com, and we will use commercially reasonable efforts to delete that information.

We may assign or transfer this Policy, as well as your account and related information and data, including any personal information, to any person or entity that acquires all or substantially all of our business, stock or assets, or with whom we merge.

If there are any material changes to this Policy, you will be notified by our posting of a prominent notice on the Websites prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of the Websites or the Services constitutes your agreement to be bound by such changes to this Policy. Your only remedy, if you do not accept the terms of this Policy, is to discontinue use of the Websites and the Services.

Your California Privacy Rights

As noted above, we do not share your information for direct marketing purposes. California Civil Code Section 1798.83 permits users of our website who are California residents to request and obtain from us a list of what personal information (if any) we have shared with third parties or corporate affiliates for those entities’ direct marketing purposes in the preceding calendar year, and the names and addresses of those third parties. Requests may be made only once a year and are free of charge.

If you are a California resident and would like a copy of this notice, please submit a written request to the following address: Dozuki, Attn: Privacy Agent, 1330 Monterey St, CA 93401. For all requests, you must put the statement “California Privacy Rights Notice” in the body of your request, as well as your name, street address, city, state, and zip code. You also need to attest to the fact that you are a California resident and provide a current California address for our response. Please note that we will not accept requests via telephone, email or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not contain complete information.

California Do Not Track Disclosures

California Business & Professions Code Section 22575(b) (as amended effective January 1, 2014) provides that California residents are entitled to know how a website operator responds to “Do Not Track” (DNT) browser settings. DNT is a feature offered by some browsers which, when enabled, sends a signal to websites to request that your browsing is not tracked, such as by third party ad networks, social networks and analytic companies. We do not currently take actions to respond to DNT signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a DNT standard once one is created. For information about DNT, visit All About DNT.

If you have questions regarding this Policy or about the privacy practices of Dozuki, please contact us by email at legal@dozuki.com, or at:

Dozuki, Inc.

Attn: Privacy Officer

1330 Monterey St

San Luis Obispo, CA 93401

United States of America

Subprocessors