Effective Date: July 25, 2023
Your privacy is important to us at Nami ML Inc. and its affiliates (collectively “Nami,” “we,” “us,” or “our”), and we are committed to safeguarding, preserving, and respecting your privacy rights. This online privacy statement (the “Statement” or “Policy”) describes how we collect, use, disclose, and secure the personal information we gather about you through our website, www.namiml.com (the “Site”), our application, when you view or interact with Nami social media accounts or any social media accounts or content affiliated with us, and when you interact with us as a customer or otherwise (collectively, the “Services”).
For purposes of this Statement, personal information means data that classifies as personal information, personal data, personally identifiable information, or similar terms under applicable data privacy and security laws and regulations. It does not include data excluded or exempted from those laws and regulations. Nothing in this Statement will constitute an admission or evidence that any particular data privacy or information security law or regulation applies to Nami generally or in any specific context.
This Policy expressly incorporates any privacy notices we may issue to supplement this Policy, for example if required by law. Depending on your residency, a supplemental privacy notice may apply to you.
You should read this Statement carefully, so that you understand our privacy practices. By accessing, browsing, downloading, or otherwise using the Services, you confirm that you have read, understood, and agreed with this Statement. If you do not agree to this Statement, you may not use the Services.
This Statement applies regardless of how the Services are accessed and will cover any technologies or devices by which we make the Services available to you.
We may provide you with additional privacy notices where we believe it is appropriate to do so. It is important that you read this Statement together with any other privacy notice or terms we may provide on specific occasions, so that you are fully aware of how and why we are using your data.
If you have any questions or concerns about our personal information policies or practices, you can contact us in the methods described in the “Contact Us” section below.
We collect information you voluntarily provide directly to us, information that we collect automatically when you interact with the Services, and information collected from third parties. The categories of personal information that we collect and the purposes for which we collect that information are described below.
Categories of Personal Information We Collect
The following list describes the categories of personal information we collect.
· Account Information includes first name, last name, email address, and password. We collect this information when you provide it directly to us. We collect this information for the purposes of account creation and management, advertising and marketing, analytics and research, customer service, and website security and maintenance.
· Analytics Information. We collect certain analytics information automatically as you navigate our Services. This includes cookies, tracking pixels, tags or similar tools, which may collect information about your browser, device, geolocation, and interactions with the Services, Site, or emails. For more information, please view the “How Do We Use “Cookies” and Other Tracking Technologies?” section below. We collect this information for the purposes of account creation and management, advertising and marketing, analytics and research, customer service, and website security and maintenance.
· Contact Information includes name and email address. We collect this information when you provide it directly to us such as signing up for newsletters, requesting information, creating an account, or filling out a form. We collect this information for the purposes of account creation and management, advertising and marketing, analytics and research, customer service, and website security and maintenance.
· Commercial History includes information regarding the purchases you have made through our Services and your subscription information. We collect this information for the purposes of account creation and management, advertising and marketing, analytics and research, customer service, and website security and maintenance.
· Chat Information includes the contents of the conversation. We collect this information when you engage with the Site’s chat services. If you interact with the chat services we will record the conversation. Please not that information relating to your communications may be shared with our service provider. We collect this information for the purposes of account creation and management, customer service, and website security and maintenance.
· Payment Information includes name, address, phone number, and debit or credit card information. We, or our service providers, collect this information for the purposes of account creation and management, analytics and research, customer service, and website security and maintenance.
· Responses to Surveys and Questionnaires includes any information you provide to us when you voluntary market research surveys such as email address, age, and interested activities. We collect this information for the purposes of advertising and marketing, analytics and research, customer service, and website security and maintenance.
· Social Media Information includes information that you post by sharing on a blog or another social media platform. We collect this information when you provide it directly to us. Please note that your comments will be visible to the public, so you should never share personal information that you would like to keep private. We collect this information for the purposes of advertising and marketing, analytics and research, customer service, and website security and maintenance.
· User-Generated Content. If you post, upload, comment, or otherwise submit content on the Services, we may collect certain information about you such as your name and email address and products you may have purchased. Be aware that as a default, any information you post on the Services, including without limitation review, comments, and text, may be available to and searchable by all users of the Services. We collect this information for the purposes of account creation and management, advertising and marketing, analytics and research, customer service, and website security and maintenance.
Other Ways We May Collect, Use, or Share the Information
We may also reserve the right to collect, use, or share personal information for the following purposes:
· For Legal Purposes. We reserve the right to cooperate with local, provincial, state, federal and international officials in any investigation requiring either personal information or reports about lawful of unlawful user activity on this site. We also reserve the right to share your personal information to establish, exercise, or defend our legal and property rights, including providing information to others for the purposes of fraud prevention. We may also share your personal information with any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
If we are ordered by a legal process or government to provide data about one or more individual users, we will notify those users of our compliance with that order, to the extent permitted by law.
· To Present the Site. We will use personal information to present our Site and its contents in a suitable and effective manner for you and your device.
· To Provide the Services. We will use personal information to provide the Services, including to improve operations and for security purposes.
· Customer Service. We will use your personal information to provide you with customer service, troubleshoot issues, and respond to requests, questions or comments.
· Provide Information and Opportunities. We will use your personal information to advertise travel opportunities, promotions, products, events, or Services that we think may be of interest to you.
· Business Transactions or Mergers. We reserve the right to share your personal information to third parties as part of any potential business or asset sale, merger, acquisition, investment, round of funding, or similar type of transaction. Additionally, if we are entering into a corporate transaction with a third party, we may receive personal information in connection with the diligence. If we close a transaction, the third party may transfer personal information, which we would use as described in this Policy.
· Bankruptcy or Insolvency. In the event of bankruptcy, insolvency, or dissolution proceedings, we may share your personal information with third parties as part of the sale or reorganization process.
· Information From Our Partners. We may collect information from our partners, our affiliates, subsidiaries, joint ventures, or other companies under common control. We may combine that information with other information we collect about you, but we will always use the information as described in this Policy. We may also share information with our affiliates, subsidiaries, joint ventures or other companies under common control.
We may send one or more cookies to your computer or other device. We may also use other similar technologies such as tracking pixels, tags, or similar tools when you visit our Services. These technologies can collect data regarding your operating system, browser type, device type, screen resolution, IP address, and other technical information, as well as navigation events and session information as you interact with our Services. This information allows us to understand how you use the Services.
Our Site also contains embedded applications, widgets, plug-ins, and links to other websites, such as Facebook, Twitter, LinkedIn, YouTube, and other social media and sharing websites. You consent to the collection, use, and sharing of your personal information when you utilize these features.
What Are Cookies?
Cookies are small files created by websites, including our Services, that reside on your computer’s hard drive and that store information about your use of a particular website. When you access our Services, we use cookies and other tracking technologies to:
· Estimate our audience size and usage patterns;
· Store information about your preferences, allowing us to customize our Services according to your individual needs;
· Contact you to provide you with information or services that you request from us;
· Advertise new content, events, and services that relate to your interests;
· Provide you with more personalized content that is most relevant to your interest areas; and
· Recognize when you return to our Services.
We set some cookies ourselves and others are set by third parties. You can manage your cookies preference as described in the “Managing Your Cookies” section below.
What Types of Cookies Do We Use and Why?
The following chart lists the different types of cookies that we and our service providers use on the Services, examples of who serves those cookies and links to the privacy notices and opt-out information of those cookie servers. Because the specific cookies we use may vary over time, as well as differ by the specific page you are browsing, the below chart is illustrative only.
We do not use analytical tools in a manner that discloses to third parties that a specific person viewed specific video materials.
How Long Do Cookies Stay on My Device?
Some cookies operate from the time you visit the Services until the end of that particular browsing session. These cookies, which are called “session cookies,” expire and are automatically deleted when you close your Internet browser.
Some cookies will stay on your device between browsing sessions and will not expire or automatically delete when you close your Internet browser. These cookies are called “persistent cookies” and the length of time they will remain on your device will vary from cookie to cookie. Persistent cookies are used for a number of purposes, such as storing your preferences so that they are available for your next visit and to keep a more accurate account of how often you visit the Services, how your use of the Services may change over time, and the effectiveness of advertising efforts.
Managing Your Cookies
It may be possible to block cookies by changing your Internet browser settings to refuse all or some cookies. If you choose to block all cookies (including essential cookies), you may not be able to access all or parts of the Services.
You can find out more about cookies and how to manage them by visiting www.AboutCookies.org.
Does the Site Respond to “Do Not Track” Signals?
There is currently no industry agreed-upon response to a Do Not Track signal. At this time, our Site does not respond differently based on a user’s Do Not Track signal.
This section of our Privacy Policy is applicable to persons located in the European Union (“EU”), an European Economic Area member state (“EEA”), United Kingdom (“UK”), or Switzerland as well as to persons whose personal information is processed in or transferred from the EU, EEA, UK, or Switzerland. You are entitled under the EU General Data Protection Regulation and UK General Data Protection Regulation (collectively, the “GDPR”), to the information in this section of our Privacy Policy.
Your Rights
You are entitled by law to access, correct, amend, or delete personal information about you that we hold. A summary listing these rights appears below. Please note that these rights are not absolute and certain exemptions may apply to specific requests that you may submit to us.
To exercise these rights, please contact us using the information below in the “Contact Us” section or view our “Manager Privacy Settings” page located in the footer of our website. For your protection, we may need to verify your identity before responding to your request. In the event that we refuse a request, we will provide you a reason as to why.
Asking us to access your personal information
You have the right to obtain from us confirmation as to whether or not we are processing personal information about you, and if so, the right to be provided with the information contained in this Policy. You also have the right to ask us for copies of your personal information. When making a request, please provide an accurate description of the personal information to which you want access. Where requests are repetitive or manifestly unfounded or excessive, we may charge a reasonable fee based on administrative cost.
Asking us to rectify your personal information
You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Asking us to delete your personal information
You have the right to ask us to erase your personal information if:
· We no longer need it for the purposes for which we collected it;
· We have been using it with no valid legal basis;
· We are obligated to erase it to comply with a legal obligation to which we are subject;
· We need your consent to use the information and you withdraw consent; or
· You object to us processing your personal information where our legal basis for doing so is our legitimate interests and there are no overriding legitimate grounds for the processing.
However, this right is not absolute. Even if you make a request for deletion, we may need to retain certain information for legal or administrative purposes, such as record keeping, maintenance of opt-out requirements, defending or making legal claims, or detecting fraudulent activities. We will retain information in accordance with the “How Long Is Your Personal Information Kept” section below.
If you do exercise a valid right to have your personal information deleted, please keep in mind that deletion by third parties to whom the information has been provided might not be immediate and that the deleted information may persist in backup copies for a reasonable period (but will not be available to others).
Asking us to restrict our use of your personal information
You have the right to ask us to place a restriction on our use of your personal information if one of the following applies to you:
· You contest the accuracy of the information that we hold about you, while we verify its accuracy;
· We have used your information unlawfully, but you request us to restrict its use instead of erasing it;
· We no longer need the information for the purpose for which we collected it, but you need it to deal with a legal claim; or
· You have objected to us using your information, while we check whether our legitimate grounds override your right to object.
The right to transfer your personal information to another service provider
You have the right to ask that we transfer the personal information you gave us from one organization to another, or give it to you (i.e. data portability). This applies to personal information we are processing to service a contract with you and to personal information we are processing based on your consent.
The right to withdraw consent
If we obtain your written consent to collect and process your personal information, you can subsequently withdraw such consent as to any further processing of such information.
The right to lodge a complaint with a supervisory authority
If you believe your rights under the GDPR have been violated, the GDPR gives you the right to file a complaint with your supervisory authority. A list of supervisory authorities is available here: EEA and EU Data Protection Authorities (DPAs); Swiss Federal Data Protection and Information Commissioner (FDPIC); UK Information Commissioner’s Office (ICO).
Rights related to automated decision-making
To the extent that we engage in decision-making based solely on automated processing, including profiling, which produces legal effects concerning you or which significantly affects you, you have the right not to be subject to such decision-making.
Right to object to processing
You have the right to object to the processing of your personal information that is based on legitimate interests or your consent (rather than when the reason for using it is to perform an obligation due to you under a contract with us). If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or we can demonstrate the processing is for the establishment, exercise, or defense of legal claims. You can object to the processing of your personal information by contacting us using the information in the “Contact Us” section below.
Legal Bases for Processing Your Personal Information
Nami collects your personal information to provide our products and Services to you; otherwise, we may not be able to process the transactions you request. We will only process your personal information when we have a lawful basis for doing so. If you are in a country in the EU, EEA, UK, or Switzerland, you are entitled to an explanation of the legal bases we rely on to process your personal information. The legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it, which is discussed below.
· Consent. We may process your personal information based on your consent such as when you purchase a service or ask us to send you certain kinds of marketing communications. You have the right to withdraw your consent at any time without affecting the lawfulness of the processing based on consent before its withdrawal.
o Children’s Consent. We do not knowingly process data of EU, EEA, UK, or Swiss residents under the age of 16 without reasonably verified parental consent.
· Our Legitimate Interests. We may process your personal information if doing so is necessary for our legitimate interests relating to our business purposes arising from your relationship with us, and your rights as an individual do not override those legitimate interests. For example, our legitimate interests include but are not limited to when we process your personal information to carry out fraud prevention activities and activities to increase network and information security, identify usage trends, determine the effectiveness of promotional campaigns, expand our business activities and improve our services and the content and functionality of our Services. Our legitimate interests also include providing you with the products and services you request, view, engage with, or purchase and communicating with you regarding your account or transactions with us.
· To Perform a Contract. We may process your personal information to administer and fulfill contractual obligations to you. We will also collect and process your personal information as necessary for the performance of a contract to which you are a party.
· To Enable Us to Comply With a Legal Obligation. We may process your personal information to comply with legal obligations to which we are subject. This may include any requirement to produce audited accounts, any legal obligation to share information with law enforcement agencies, public or governmental authorities, and to comply with legal process.
· Necessary for the Exercise or Defense of Legal Claims. If you bring a claim against us or we bring a claim against you, we may process your personal information in relation to that claim.
Depending on the situation, we may be the controller or the processor for personal information collected from residents of the EU, EEA, UK or Switzerland. If you have any questions about or need further information concerning the legal basis on which we collect and use your personal information for any specific processing activity, please contact us using the “Contact Us” section below.
Cross-Border Transfers of Personal Information
Our Services are operated in the United States. Personal information about you provide while in the EU, an EEA member state, the UK, or Switzerland may be transferred to the United States. The United States does not have an adequacy decision or adequacy regulation. The GDPR permits such transfers when necessary for the performance of a contract between you and us, if we obtain your explicit consent to such transfer, or if it is in our legitimate interest to transfer the personal information. The laws in the United States may not be as protective as the GDPR or the laws of other jurisdictions where you may be located. If we transfer personal information from the EU, EEA, UK, or Switzerland, or another country with cross-border transfer obligations, we will provide an appropriate safeguard, such as using standard contractual clauses.
To obtain a copy of the safeguard(s), please contact us using the information provided in the “Contact Us” section below.
We respect your rights in how your personal information is used and shared. If at any time you would like to unsubscribe from receiving future emails, you can email us at privacy@namiml.com or follow the instructions at the bottom of each email, and we will promptly remove you from marketing correspondence. Please note, however, that we may still need to contact you regarding other matters.
We will retain your personal information until the personal information is no longer necessary to accomplish the purpose for which it was provided. We may retain your personal information for longer periods for specific purposes to the extent that we are obliged to do so in accordance with applicable laws and regulations, to protect you, other people, and us from fraud, abuse, an unauthorized access, as necessary to protect our legal rights, or for certain business requirements.
We will delete your personal information when it is no longer necessary for the purpose for which it was collected, or upon your request, subject to exceptions as discussed in this Statement or under applicable law, contract, or regulation.
If you use our mobile application, you can delete your account by submitting a request to privacy@namiml.com or by deleting your account through the application itself. If you delete your account from within the application, we will delete the accompanying personal data subject to legal and contractual requirements.
The security of your personal information is important to us. We take various reasonable organizational, administrative, and technical measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. If required by law to do so, we will notify you and/or the relevant supervisory authority in the event of a data breach.
However, we cannot and do not guarantee complete security, as it does not exist on the Internet.
We process personal information on our servers in the United States of America, and may do so in other countries. If you use our Services or otherwise provide us with information from outside of the United States, you expressly consent to the transfer of your data to the United States, the processing of your data in the United States, and the storage of your data in the United States.
Nami’s Services may contain links to third-party websites. When we provide links, we do so only as a convenience and we are not responsible for any content of any third-party website or any links contained within. It is important to note that this Statement only applies to Nami’s Services. We are not responsible and assume no responsibility for any personal information collected, stored, or used by any third party as a result of you visiting third-party websites. We also advise that you carefully read the privacy notice of any third-party websites you choose to visit.
Protecting the privacy of the very young is especially important. Our Services are not intended for children under 13 years of age, and we do not knowingly collect personal information from children under 13. In the event that we learn that we have collected personal information from a child under age 13 without verification or parental consent, we will immediately delete that information. If you believe that we might have any information from or about a child under 13, please contact us using the information provided in the “Contact Us” section below.
This Statement may change from time to time. If we need to change this Statement at some point in the future, we will post any changes on this page. If we make a significant or material change to this Statement we will notify you via email. You should check these terms when you use the Site. Your continued use of the Site constitutes acceptance of the most current version of this Statement.
If your personal information changes, you may correct or update it by notifying us of the change using the contact information listed below or be clicking “Managing Privacy Settings” in the footer at www.namiml.com.
If you have any questions about this Privacy Policy, please contact us at:
Nami ML Inc.
1630 Welton Street, Suite 708
Denver, CO 80202 USA
+1 321 754 6264
privacy@namiml.com
Please be aware that Nami is based in and operates from the United States. When accessing our Site, you consent to and authorize us to transfer your information from the country in which you are located to the United States. The United States may not have laws consistent with privacy and data protection laws in other countries.
The Site and Services are not designed to solicit or collect PII from children under the age of 13 years. If you are under 13, you should not use or enter information on the Site or Services.
Information Collection & Use
We may collect your personally identifiable information (“PII”) when you voluntarily provide us with such PII at several different points on the Site and Services, such as when you request access to our platform, subscribe to our newsletter, or sign up for an account. You may provide us with PII in the form of contact information, such as name and email address. We use your PII to provide our services, to conduct other legitimate business functions as permitted by law, and for other purposes described in this Privacy Policy.
We use this information to respond to and communicate with you about your requests. For example, if you subscribe to our newsletter, we will use your name and email address to send the newsletter to you. Please note that out of respect for your privacy, we provide you a way to unsubscribe from a newsletter within each email. We may also send you service and billing related announcements on those occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email. Generally, you may not opt-out of these service and billing communications, which are not promotional in nature.
As is true of most websites, we gather certain information automatically about the users of our Site and Services and store such information in log files. This information includes browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, which may be linked to PII, to analyze trends, to administer the Site, to track users’ movements around the Site, to improve our products, and to provide customer service on your account. This information enables us to conduct analytics in order to improve the overall design, use, and performance of our Site.
Additionally, the Nami Platform may track any web events produced, record screen sessions, and may request additional PII to facilitate billing and purchases. All data collected are used to provide and improve the Site and Services.
Our Site and Services also uses cookies, small text files that are stored on our users’ computers for recordkeeping purposes. If you reject cookies, you may still use our Site, but your ability to use some areas of our Site may be limited. Rejecting cookies on the Nami Platform may result in the Nami Platform being unusable. Please note that if any third parties use cookies on our Site or Services, we have no access to or control over these cookies. Such third party cookies may allow these companies to collect PII about your online activities over time and across different websites when you use the Nami Site or Services. This Privacy Policy covers the use of cookies by Nami only and does not cover the use of cookies by any third parties.
We may also employ other software tracking technology, including clear gifs (a.k.a. web beacons / tracking pixels), that help us better manage content on our Site and Services by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of our users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on webpages and are about the size of the period at the end of this sentence. Information gathered via clear gifs may be tied to PII on the Site. We may also use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns.
The Site and Services does not recognize or respond to browser-initiated Do Not Track signals.
Information Sharing
We reserve the right to disclose your PII as required by law and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on our Site or Nami. We may also share your PII as appropriate to carry out other legitimate business functions as permitted by law.
We also reserve the right in the event Nami goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, to share your PII, as appropriate, among the assets transferred.
We may use other third party service providers to enhance your online experience and may share information about you as necessary for these third parties to provide the services. For example, one of the third party service providers that we use is Google Analytics, which is a service provided by Google. Google utilizes the data collected to track and examine the use of our Site and may share this data with other Google services. You can learn more about Google’s privacy practices by visiting their website at http://www.google.com/policies/privacy/partners/.
Third Party Links to Other Sites
This Site contains links to other websites that are not owned or controlled by Nami. Please be aware that we are not responsible for the privacy practices of such other websites. We encourage you to be aware when you leave our Site and to read the privacy statements of each and every website that collects PII. This Privacy Policy applies only to information collected by this Site.
Our Site also contains embedded applications, widgets, plug-ins, and links to other websites, such as Facebook, Twitter, LinkedIn, YouTube, and other social media and sharing websites. You consent to the collection, use, and sharing of your personal information when you utilize these features.
The websites to which we link may have different privacy policies and practices from those disclosed here. We assume no responsibility for the policies or practices of linked websites and encourage you to become acquainted with them.
Security
The security of your PII is important to us. We follow generally accepted industry standards to protect the PII submitted to us, both during transmission and once we receive it. However, please be aware that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your PII, we cannot guarantee its absolute security.
We have implemented physical, technical, and administrative safeguards to protect against unauthorized access to your PII. However, you can submit requests to access your PII, correct or update any incorrect PII that we may have, or delete your PII (in limited circumstances), by contacting us as described below.
We retain your PII as long as necessary to conduct our business and as permitted by law. Once we no longer need your PII, we will ensure that it is disposed of securely using reasonable measures to ensure that the PII is deleted or any information that we retain no longer personally identifies you.
Privacy Policy Changes
We reserve the right to modify this Privacy Policy at any time, so please review it frequently. If we decide to change our Privacy Policy, we will post those changes to this Site’s homepage and other places we deem appropriate.
European Union Users
We provide the users of our Site that are located in the European Union (“EU”) with additional choices with regard to their PII, or personal data. Under the EU General Data Protection Regulation (“GDPR”), you have the following rights:
California Users
We provide the users of our Site that are located in California with additional choices with regard to their PII, or personal data. Under applicable law, you have the following rights with respect to your personal information, subject to certain exceptions and limitations. For example, we tailor the rights made available to you based on applicable law in the place where our systems believe your computer or device is currently located:
To exercise any of these rights, please submit your request(s) by contacting us as described below.
Contact Us
If your PII changes, you may correct or update it by notifying us of the change using the contact information listed below or be clicking “Managing Privacy Settings” in the footer at www.namiml.com.
If you have any questions or suggestions regarding our Privacy Policy, please contact us at:
Nami ML Inc.
1630 Welton Street, Suite 708
Denver, CO 80202 USA
+1 321 754 6264
privacy@namiml.com