Privacy Notice

 

  1. Policy Statement. Vayafi (“We”, “our”, or “us”’) is committed to protect and respect the privacy and confidentiality of personal data in our possession or under our control. This Privacy Notice is intended to inform website visitors (“you”) regarding our policies with respect to the collection, use, and disclosure of personal data online. In general, we will not process personal data unless:
    • It is for a lawful purpose directly related to our business activity and the processing is necessary for, or directly related to, that purpose and
    • the personal data is adequate but not excessive in relation to that purpose

  2. Scope of Notice. This Privacy Notice applies to all processing activities related to personal data disclosed through the website https://vayafi.com
  3. Consent. By clicking “I Agree”, you accept the policies and procedures that we employ in relation to the collection and use of any personal data that you may disclose through this website. We may update this Privacy Notice from time to time as we improve our website and Services. We will notify you of any changes that would substantially affect your data privacy rights and ask for your consent to such changes.
  4. Personal Information Controller. Social Light, Inc. operates the https://vayafi.com website. It is the personal information controller of any personal data that you may disclose through the use of this website and through any of your interactions with us through any of our social media accounts, which means that it determines the purposes for which your personal data is being collected and processed. It may also be that, with your consent, your personal data is disclosed to third parties pursuant to a data sharing agreement, in which case, such third parties are also the personal information controllers of your personal data.
  5. Method of Collection.
    1. Use of the Website. Information is collected through the use by the user of the website.  The general types of user information gathered are: anonymous information gathered from cookies and log files; information received from third parties; and/or personal data you provide us for certain services.
    2. Use of Third Party Websites. We may collect your personal data from third party websites which are not affiliated with or connected to us, whether directly or indirectly.

  6. Legal Basis for Processing

    Social Light Inc. will process your personal data to meet our legitimate business interests, or where it is necessary to comply with a legal obligation.

  7. Categories of Data Collected and Processed
    1. Social Light Inc. may collect the following information automatically through this website:
      1. Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser-plug-in types and versions, operating system and platform;
      2. Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from this site (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
      3. Google Analytics Data
    2. Social Light Inc. may acquire personal data from this website such as your name, company, email address, contact number, and country only when it is voluntarily submitted to us. While collecting the personal data about you, Social Light Inc. will inform you whether the requested information is obligatory or voluntary. If you choose not to provide certain information, this may impact your use of certain resources and could make it impossible for Social Light Inc. to provide certain services to you.
    3. Social Light Inc. may also work with third parties (including, for example, business partners, sub-contractors in technical services, advertising networks, analytics providers and search information providers) and may receive information about you from them. In particular, advertising of our products found on other websites may be serviced by our service providers, who may use cookies to collect information about your visits to said websites. We do not make an attempt to link this information to the identity of the User.

  8. How We Use Your Personal Data

    
Social Light Inc. will use personal data collected via this website within the scope of the following purposes:

    • to improve our level of service
    • to improve the content of our website
    • to respond to your requests, queries and complaints
    • for the purposes of maintaining our relationship with you if you are a customer, supplier or business partner
    • To comply with statutory and regulatory requirements, including directives, issuances by, or our obligations to any competent authority, regulator, supervisory body, enforcement agency, exchange, court, quasi-judicial body, or tribunal;
    • To enable us to exercise sound corporate governance over its businesses, ensure that risks arising therefrom are duly identified, measured, managed and mitigated, and enhance risk assessment and prevent fraud;
    • To conduct company audits or investigate a complaint or security threat;
    • Other legitimate business purposes;
    • Establish, exercise, or defend legal claims;
    • Fulfill any other purposes directly related to the above-stated purposes.

  9. To Whom We Share Your Personal Data

    We may share personal data about you with our affiliates where necessary to fulfill a legitimate business purpose or to comply with applicable legal requirements. We may also share your information with selected third parties including:

    • Business partners, suppliers and sub-contractors who provide services to Social Light Inc or on its behalf; and
    • Analytics and search engine providers that assist us in the improvement and optimization of this site.
    • In the event that we sell or buy any business or assets, we may disclose your personal data to the prospective seller or buyer of such business or assets;
    • If all or substantially all of our assets are acquired by a third party, in which you’re your personal data may be one of the transferred assets; or
    • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply its Terms of Use and other agreements, or to protect the rights, property, or safety of Social Light Inc, its customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and compliance risk management and also exchanging information with regulatory and health authorities for the purposes of adverse event and product quality issue reporting.

    We only share your personal data with other entities or individuals outside of the company in limited circumstances. When information is disclosed to third parties or when the processing of personal data is outsourced by us to a third party, the processing will be subject to written agreements between us and the third parties processing the data, in accordance with the requirements of the Data Privacy Act of 2012. These written agreements specify the rights and obligations of each party and will provide that the third party has adequate security measures in place and will only process personal data on our specific written instructions.

    We will not sell, rent, share, trade, or disclose any of your personal data to any other party without your prior written consent, with the exception of entities within our company and any third-party service provider which we have engaged whose services necessarily require the processing of your personal data.

  10. How Long We Will Retain Your Personal Data

    Personal data will only be stored as long as necessary for the purposes for which it was collected subject to local laws and regulations and legitimate business needs.

  11. How We Protect Your Personal Data

    
We will take reasonable and appropriate physical, administrative and technical safeguards to protect the personal data about you from loss, misuse, unauthorized access, disclosure, alteration or destruction. Although we will do our best to protect your personal data, we cannot guarantee that loss, misuse or alteration to data will not occur, and any transmission of data is at your own risk, it’s important to note that the security of information transmitted over the Internet cannot be guaranteed.

  12. Your rights

    Please be informed that you have the following rights under the Data Privacy Act of 2012:

    1. Access Personal Data. You may request access to any of your personal data held by the company, subject to certain restrictions. A request for disclosure of such information is called a subject access request. Any such requests should be addressed to the Data Protection Officer.
    2. Make Corrections to Personal Data. It is your responsibility to inform us of any changes to the personal data that you have supplied during the course of your engagement.
    3. Object to the Processing of Personal Data. You have the right to object to the processing of your personal data, including processing for direct marketing, automated processing, or profiling. You shall also be notified and be given an opportunity to withhold consent to the processing in case of changes or any amendment to the information supplied or declared to you in this privacy notice.
    4. Erasure or Blocking of Personal Data. You shall have the right to suspend, withdraw or order the blocking, removal or destruction of your personal information from our systems. Please note that depending on the type of personal information involved, you may be restricted from accessing any of our Services.
    5. Be Informed of the Existence of Processing of Personal Data. You have a right to be informed whether personal data pertaining to you shall be, are being or have been processed, including the existence of automated decision-making and profiling.
    6. Damages. Upon presentation of a valid decision, you have the right to be indemnified for any damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of personal data, taking into account any violation of your rights and freedoms as data subject.
    7. Lodge a complaint before the National Privacy Commission

    If you wish to exercise one of the above mentioned rights, please use the contact information below. 

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by informing us at any time that you do not wish to receive such marketing communications. Where you wish to exercise this right please send us an email at privacy@sociallightinc.com.

  13. Other Important Information

    Our website provides links to other third party web sites. The privacy policy described here does not apply to those sites. Please ensure you check the legal and privacy policy sections of any site you access.

  14. Google Analytics

    We make use of Google Analytics which is a web analytics tool that helps website owners understand how visitors engage with their website. Google Analytics customers can view a variety of reports about how visitors interact with their website so they can improve it. Google Analytics collects information anonymously. It reports website trends without identifying individual visitors.

    1. Google Analytics Cookies. Like many services, Google Analytics uses first-party cookies to track visitor interactions. These cookies are used to store information, such as what time the current visit occurred, whether the visitor has been to the site before, and what site referred the visitor to the web page. Browsers do not share first-party cookies across domains.
    2. Use of IP Address. Every computer and device connected to the Internet is assigned a unique number known as an Internet protocol (IP) address. Since these numbers are usually assigned in country-based blocks, an IP address can often be used to identify the country, state, and city from which a computer is connecting to the Internet. Google Analytics collects the IP address of website visitors in order to provide website owners a sense of where in the world their visitors come from. This method is known as IP geolocation.

    Google Analytics does not report the actual IP address information to Google Analytics customers. Additionally, using a method known as IP masking, website owners that use Google Analytics have the option to tell Google Analytics to only use a portion of the IP address, rather than the entire IP address, for geolocation. Whether or not website owners use Google Analytics, they have access to IP addresses for visitors to their sites.

  15. Changes to This Data Protection Policy

    We may update this Privacy Notice from time to time. We will notify you of any changes by posting the Notice on this page. Please revisit this page periodically for any changes. Changes to this Notice are effective when they are posted on this page. Contact us if you have any questions about our collection, use, and/or disclosure of personal data about you; feedback regarding this Notice, or any complaint you have.

  16. How to Reach Us
    You can contact us in order to exercise your rights, make inquiries or submit complaints concerning our processing of your personal. We will take appropriate steps to address requests, inquiries and complaints. We will respond to such requests within thirty (30) business days.

  17. Contact Details:
    Mailing Address: 214 Wilson Street Greenhills San Juan Philippines
    Email Address:privacy@sociallightinc.com

    Last Updated: July 5, 2018

PRIVACY POLICY

Social Light Inc. (the “Service Provider”, “us” and/or “We) is committed to protecting and respecting your privacy.

SCOPE OF POLICY

This policy (together with the End-User License Agreement as set out through the link in the Service Provider’s log in page (EULA) and any additional terms of use incorporated by reference into the EULA, together with the Terms of Use, applies to your access and use of the Vayafi wireless service (the Service).

This policy sets out the basis on which any personal data we collect from you, or that you provide to us will be processed accordingly. Please read the following carefully to understand our views and practices regarding your personal data and how the Service Provider will treat it.

  1. INFORMATION THAT MAY BE COLLECTED FROM YOU

    Personal information is information that identifies you or could identify you. During your dealings with us, we may collect personal information such as:

    1. Submitted Information: The log in information which you provide, and/or information we receive from your social media account (e.g. Twitter, Facebook), subject to your privacy settings) through which you access the Service, and/or the information you provide to questions, surveys, competitions, promotions etc., including but not limited to: name, address, birthday, gender, mobile phone number, email address, and preferences.
    2. Additional information: If you contact the Service Provider Service Center, the Service Provider will collect information you provide about the problem you are reporting about the Service and may keep a copy of that information;
    3. Some information requested from you (e.g. surveys, opt-in advertising), will be optional and you do not have to respond to them;
    4. Details of transactions you carry out through the use of the Service;
    5. Details of your use of our Service including, but not limited to, location data, weblogs and other communication data and the resources that you access.
    6. Device information: Information about the mobile telephone, smart phone, hand held device, laptop, computer or any other device used by the End-User to access and use the Services (Device), including, where available, the Device’s unique Device identifiers, operating system, browser type and mobile network information as well as the Device’s telephone number if applicable, for system administration and to report aggregate information to our advertisers. The Device information may be associated with Submitted Information and such combined information will be treated as personal data in accordance with this policy for as long as it is combined.
    7. Location information: The information about your actual location may likewise be collected and processed.
    8. Log information: When the End-Users use the Service, certain information are automatically collected and stored in server logs, including but not limited to internet protocol (IP) addresses, internet service provider (ISP), clickstream data, browser type and language, viewed and exit pages and date or time stamps.
  2. COOKIES AND SIMILAR TECHNOLOGIES

    Vayafi uses cookies (small text files placed on your device) and similar technologies to distinguish you from other users of the Service, and to help collect data. The text in a cookie often consists of a string of numbers and letters that uniquely identifies your computer, but it can contain other information as well. These cookies are used to provide you with a good experience when you use the Service, and to also allow the improvement of the Service. Cookies and similar technologies are used for several purposes including:

    1. Sign-in and Authentication: When you sign in to Vayafi, we store a unique ID number, and the time you signed in, in an encrypted cookie on your device. This cookie allows you to move from page to page without having to sign in again on each page.
    2. Interest-Based Advertising: Bayafi uses cookies to collect data about your online activity and identify your interests so that we can provide advertisements that are most relevant to you. You can also opt out of receiving interest-based advertising from Vayafi
    3. Analytics: Vayafi AdWiFi uses cookies and other identifiers to gather usage and performance data
  3. WHERE WE STORE YOUR INFORMATION

    All information you provide to us is stored on our secure servers. By joining and using the Service, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

  4. TRANSMISSION VIA THE SERVICE

    Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted via the Service; any transmission is at your own risk. Once any information is received, strict procedures and security features are implemented accordingly to prevent unauthorized access. These involve RSA-based encryption and authentication and use of SSL certificates for data transmission.

    As access to the Service is through your chosen social media platform you should ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.

  5. USES MADE OF THE INFORMATION

    The information collected and/or held about you may be used in the following ways:

    1. To provide you with information regarding the venue in which you are using the Service including information relating to their goods and services;
    2. To provide it to the venue owner or sponsor to enable them to see how the venue is being used and by whom;
    3. To report aggregate or individual information to our advertisers or selected third parties that we work with (Third Parties) for consumer analysis and/or marketing.
    4. To provide you with information about goods and services that may be of interest to you, including those goods and services of Third Parties.

    You may only be contacted by us and/or Third Parties by electronic means (e-mail, SMS, or phone call) with information about goods and services.

    If you do not want your data to be used this way, or to pass your details on to Third Parties for marketing purposes, you have the option not to use or partake in the Service. Access to the Service is only allowed when the End-User/s does so in accordance with the Terms of Use and this Privacy Policy, therefore if the End-User/s do not accept them then we will cease to provide the Services to them until and unless the same is duly accepted.

  6. DISCLOSURE OF YOUR INFORMATION
    1. Service Provider may disclose the information collected from you to any member of its group, subsidiaries, ultimate holding company and its subsidiaries, if any.
    2. Service Provider may disclose your personal information to third parties:
      • To our Customers who operate and own the venue where you access the Services
      • To the sponsors of the venue where you access the Services
      • To the Third Parties detailed at point 4 above
    3. In the event that the Service Provider sell or buy any business or assets, in which case the Service Provider may disclose your personal data to the prospective seller or buyer of such business or assets.
    4. In case all or substantially all of the Service Provider’s assets are acquired by a third party, personal data held by it about its customers will be one of the transferred assets.
    5. In case the Service Provider is under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request. In order to:
      1. Enforce or apply the EULA, terms and other agreements or to investigate potential breaches; or
      2. Protect the rights, property or safety of the Service Provider, its other customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
  7. THIRD PARTY SITES

    The Services we offer may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which the Services are advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that both the Customer and the Service Provider shall be free and harmless and do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.

  8. CHANGES TO PRIVACY POLICY

    Any changes made to this privacy policy in the future will be posted on this page and, where appropriate, notified to you by SMS or e-mail or notifying you of a change when log onto one of the Services Sites. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the Services.

  9. CONTACT

    Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to info@vayafi.com.

Cookie Policy

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Social Light Inc. (“we” or “us” or “our”) may use cookies, web beacons, tracking pixels, and other tracking technologies when you visit sociallightinc.com, and Vayafi.com, including any other media form, media channel, mobile website, or mobile application related or connected thereto (collectively, “websites”) to help customize the websites and improve your experience.

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