The mobile application Just10, (the “Just10 App”) and website located at www.Just10.com (the “Site”) whereby hereinafter the Just10 App and the Site will be referred to as “Just10”, are a copyrighted work belonging to Just10 Inc., a Canadian corporation, and its affiliates (“Just10 Inc.”, “us” or “we”).
This Policy explains generally our practices, but in all respects this Policy and the application of our practices will be subject to and in accordance with the provisions of applicable privacy protection laws.
What Personal Information Do We Collect?
You may provide us, and we may collect the following types of information from or about you, your computer and your mobile device, which may include some information that can be used to identify you (“Private Personal Information”):
a) Information You Provide: You may provide us with certain Private Personal Information, such as your email address, your name, birthdate, your mobile identifier number, and any IP address uniquely associated with your mobile device or computer, when choosing to use Just10, such as when you register as a user.
b) Your Contact/Address Book: Should you decide to add a friend through the contact/address book features from your mobile device or your email provider, you will be prompted to allow Just10 to find which of your contacts in your contact/address book already have accounts in Just10. If you elect to use this feature Just10 will generate one-way SHA-1 hashes for each email address in your contact/address book, and compare them against the one-way SHA-1 hashes generated from the email addresses of other existing Just10 users. After this process is complete, Just10 will discard all the one-way SHA-1 hashes for the email addresses in your contact/address book, and we will only keep your email address in its normal state and in its SHA-1 hash state.
c) Cookies: We may, store one or more cookies (a small text file containing a string of alphanumeric characters) on your device that uniquely identifies your browser. These cookies may store your unique account ID, an API key, encoded profile information or a username, but no other personal information. Just10 uses persistent cookies. A persistent cookie remains after you close your browser, and may be used by your browser on subsequent visits to Just10. Persistent cookies can be removed by following your web browser help file directions. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, Just10 may not function properly if the ability to accept cookies is disabled. By using the Just10, you agree to accept the placement of cookies on your mobile device and/or desktop browser)
d) Site Logs: When you use Just10, our servers may log certain information that your web browser sends to us. These logs may include information such as your web request, Internet Protocol address, type of browser, browser language, referring / exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time of your request. When you use Just10, our servers log certain general information that our application sends whenever a message is sent or received, or if you update or request any status information, including time and date stamps and the Just10 users the messages were sent from and to.
Use of Personal Information
We may use your Personal Private Information that we collect for the following purposes:
- to administer and build your Just10 account, including but not limited to delivering your shared content to your intended Just10 friends;
- to communicate with you for the purpose of informing you of notifications, changes or additions to Just10;,
- to provide Just10 to you;
- to provide you with the notifications and messages that you have opted into;
- to respond to claims that any content violates the rights of third parties;
- to respond to your request for customer service;
- to protect our rights, property or personal safety of our users and the public; or
- as required or authorized by law.
We may delete your Private Personal Information when we determine in our sole discretion when such information ceases to be necessary (for example when you breach our Terms of Service and we terminate your account).
When you delete your Just10 account, all your Personal Private Information will be deleted from our servers and data backups normally within three days.
Disclosure of Personal Information
Your Just10 profile (including all Private Personal Information you may enter into your profile) will be visible to your friends on Just10. Your non-friends on Just10 will be able to see your username, name, profile and cover photo, and how many of your 10 friend spots are unfilled. As a general rule, we do not and will not sell, rent, share or disclose your Private Personal Information without first receiving your permission or as disclosed in this policy.
Under certain circumstances, we may disclose your Private Personal Information:
- when you have explicitly consented to the disclosure;
- to fulfill the purpose for which the Private Personal Information was collected;
- if we engage a third party to provide services to us (like computer back-up services or archival file storage), and the third party is obligated to us to keep such information confidential and/or not to disclose such information, even after our relationship with you has ended;
- to respond to claims that any content violates the rights of third parties or the laws or regulations of any jurisdiction;
- to respond to your request for customer service;
- to protect the rights, property or personal safety of Just10 Inc., its users and the public; or
- when we are required or authorized by law or legal process to do so or when we believe in good faith that such disclosure is required by and in accordance with the law or to respond to subpoenas or warrants served on us.
Disclosure of Message Contents and Posts.
Your messages and posts including associated photos, comments, and reactions are stored for a period of approximately 10 days by Just10 in the normal course of business. The contents of any messages and posts exceeding the period of approximately 10 days are not kept or retained by Just10. Other files, including but not limited to profile photos, cover photos, meactions, and collages, that are sent through Just10 will normally be deleted from Just10 and from our servers approximately 10 days after replacement. You understand that in all instances where Just10 in the normal course of business is expected to delete content or data in approximately 10 days, that we shall in no way be responsible if your messages and posts are unavailable or not deleted and remain visible on Just10 for a period longer or shorter than 10 days due to changes in daylight savings time, an application malfunction, a server malfunction, an internet and connectivity malfunction, technical error, or any other reason.
You understand that due to the functionality of modern day internet browsers, smart phones, and such devices that Just10 may be accessed from today or in the future, your messages and posts including associated photos, comments, and reactions on Just10 may be screen captured, copied, photographed, stored, or rebroadcast by any of your friends on Just10 (but not by using any functionality within Just10). We shall not in any way be responsible if any of your friends on Just10 copy, photograph, store, or rebroadcast any of your messages and posts including associated photos, comments, and reactions to sources outside of Just10.
Remnant Content: Due to limitations and attributes of certain mobile operating systems and email programs there may exist remnant data on your mobile device, that's related to Just10 and older than 10 days (For example, iOS notifications that are not dismissed can remain on your mobile device until they are dismissed by you).
Your Choices and Rights Regarding Your Personal Information
You have the right to access the Private Personal Information we have collected about you and, if such Private Personal Information is inaccurate, you have the right to request that we correct such Private Personal Information or erase it. Note that we have the right to deny your access to your Private Personal Information and we also have the right to refuse to correct such Private Personal Information but, if we deny you access or refuse to correct, we will provide a reason why. You also have the right to request that we attach to your Private Personal Information any statement you furnish to us that indicates how your Private Personal Information should be changed. Once a correction has been made or a statement of correction attached to your Private Personal Information, we will undertake to inform each person to whom such Private Personal Information has been disclosed of such correction or statement. We require at least 20 business days to correct your Private Personal Information, although we will acknowledge your request to correct your Private Personal Information within 10 working days of receiving your request.
If you wish to access the Private Personal Information we have collected about you, contact our privacy officer at the address listed at the end of these terms. We may request a reasonable fee to furnish you with the response you request.
If we provide your Private Personal Information to third parties other than those who assist us in providing Just10, we will notify you of the purpose for which the Private Personal Information is being shared. Your consent to such activity is implied because of our business relationship with you, but you may revoke your consent in the manner described above.
Transfer of Private Personal Information
Your Private Personal Information may be processed by us in the country in which it was collected and in other countries, including the United States and/or Canada and/or Ireland, where laws regarding processing of Private Personal Information may be different than the laws in your country. Our servers are located in the United States and Canada and Ireland, and as such, your Private Personal Information may be available to the Canadian and U.S. and Irish governments or its agencies under lawful orders made in Canada or the U.S or Ireland. Please be advised that through your continued use of Just10 we may be transferring your Private Personal Information to Canada and/or the U.S. and/or Ireland and you expressly consent to that transfer and consent to be governed by Canadian or U.S. or Irish law for these purposes.
We will never ever sell, lease, license, or in any other way commercially distribute your Private Personal Information to third parties. We promise this to you on pain of death and commercial ridicule in the industry press. However as you can understand, we want to make sure that Just10 meets your needs as best as possible, so to that end, we do reserve the right to use your Private Personal Information strictly and only in a limited fashion where it helps us improve the Just10 product. An example could be if we see that customers using a specific type of handset are having issues with certain pages - this could indicate to us that Just10 has a bug on that specific type of handset, and that we should investigate the usability of Just10 on that handset.
You may revoke any and/or all consents you have given to us; in order to revoke such consent(s), please contact our privacy officer in writing at the address listed at the end of these terms. At least 20 business days are required to effectuate your revocation of consent from the time we receive it. Please note, however, that revocation of any consent does not have retroactive effect.
You may wish to opt out of receiving certain information and communications from us. You may do so by opting out within the applicable settings of Just10 or using the “unsubscribe” functionality within all email notifications we may send.
Your Security and Private Personal Information
We take reasonable steps to ensure that your Private Personal Information is kept safe from loss, unauthorized access, modification or disclosure. However, due to the nature of wireless technology and potential security breaches, we cannot ensure the security or privacy of information you submit through the Service, including Private Personal Information. Please remember that you control what Private Personal Information you provide while using the Service. Ultimately, you are responsible for maintaining the secrecy of your Private Personal Information in your possession. Always be careful and responsible regarding your Private Personal Information. We are not responsible for, and cannot control, the use by others of any information which you provide to them and you should use caution in selecting the Private Personal Information you provide to others through Just10. Similarly, we cannot assume any responsibility for the content of any Private Personal Information or other information which you receive from other users through Just10, and you release us from any and all liability in connection with the contents of any Private Personal Information or other information which you may receive from other users. We cannot guarantee, or assume any responsibility for verifying, the accuracy of the private Personal Information or other information provided by other users of Just10. You release us from any and all liability in connection with the use of such Private Personal Information or other information of others.
Traffic and Usage
We may monitor traffic patterns, usage and related information. We use this information in order to optimize and assess usage of Just10. We reserve the right to disclose information about your usage of Just10 in aggregate forms that do not reveal your personal identity.
Personal Information of Individuals Under 14 Years Old
We do not knowingly provide Just10 to, and will not knowingly collect Private Personal Information from:
- anyone under the age of 14 who uses Just10.
Note that we depend on the information provided to us by users to determine that a user is of the appropriate age to use Just10. We cannot be held responsible if any user is untruthful when answering questions to determine a user's age are posed by us.
Change of Control or Sale
In the event that the company Just10 Inc. undergoes a change of control (for example a merger, sale, or restructuring due to financing, bankruptcy, or inversion), or in the event that the Just10 app or website are acquired by a third party through an asset sale, we will only be authorized to transfer or assign your Private Personal Information (and any other information we have collected from you) if and only if:
a) all such transfers or assignments are strictly for the purposes of effecting such sale or change of control; and
b) you are notified via email or within Just10 within thirty (30) days of such a transfer or assignment having occurred; and
c) at all times, before, during, or after such a transfer, you will retain the right to permanently delete all of your information from Just10; and
d) Your information is only transferred and/or assigned along with Just10, and never on its own;
For the avoidance of doubt, nothing in the preceding shall ever authorize us to directly or indirectly sell, rent, exploit, lease, or barter your Private Personal Information for any reason.
Should you have any further questions or concerns about this Policy and the privacy of information you provide to us, please feel free to contact our Privacy Officer at:
June 1, 2016
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