Privacy Policy
PRIVACY NOTICE
Effective: April 15, 2024
Introduction Dejavoo Systems, LLC (collectively “Dejavoo”, “we”, “us” or “our”), is committed to safeguarding the privacy and security of your personal data. The Dejavoo website provides information about our products and news. When you visit our website, we may obtain data from and about you and your devices. Please note, we may provide separate privacy notices that apply to specific to the products or services (“Products”) we offer. We have crafted our Privacy Notice (“Notice”) to provide you with a transparent view of our privacy practices and principles, presented in a user-friendly format for easy navigation, reading, and understanding. This Notice includes:- Who this Privacy Notice Applies To
- Personal Data We Collect, and How We Collect It, and How We Use It
- How We Share Your Personal Data
- Cookies And Other Tracking Technologies
- Retention and Disposal of Personal Data
- How We Keep Your Personal Data Safe
- Children’s Privacy
- Your Rights and Choices
- Exercising Your Rights
- Additional Information for Individuals in the European Union (“EU”) and United Kingdom (“UK”)
- Additional Information for Consumers in the United States
- California Residents
- How to exercise your rights (California)
- Colorado, Connecticut, and Virginia Residents
- How to exercise your rights (Colorado, Connecticut, Virginia)
- Utah Residents
- How to exercise your rights (Utah)
- Additional Information for Canadian Residents
- How to exercise your rights (Canada)
- Nexus Portal Policy
- Changes to this Privacy Notice
- Contact Us
Who this Privacy Notice Applies To
- Dejavoo website visitors
- Event attendees
- General
- Interact or use our Website (www.dejavoo.io), including when you download materials from our resources page, request a demo or ask us to contact you.
- Register and/or attend our events or conferences (“Event” or collectively “Events”).
- Our Products (software and hardware), where a separate privacy notice governs.
- Employees or contractors; current employees and contractors may refer to the internal employee privacy notice for more information about our employee personal data collection and handling practices.
Personal Data We Collect, and How We Collect It, and How We Use It
The personal data we collect from you depends on how you interact with us and the choices you make. We use your personal data for our legitimate interests, which are ways that you would reasonably expect us to use your data for our business purposes. We limit our use of your personal data to the purposes described in this Notice. We may collect information from or about you in a variety of ways including:- Directly from you, when you provide information to us or interact with our website; and
- Automatically from you when you use or interact with our website.
| Type of Interaction | Categories of data we collect | How we use your data |
| Dejavoo website visitors |
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| Event attendees |
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| General | We collect different personal data from you depending on how you interact with us, as listed out in the categories above. |
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- Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our website and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the website (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings).
- Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the website. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, internet service provider and/or mobile carrier, operating system, and system configuration information.
- Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the website. For example, technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to certain functionalities.
How We Share Your Personal Data
We may share your personal data in the following situations:- Affiliates. We may share your information with companies that we own or control, or that are under common ownership or control.
- When we use Google Analytics. We may share your information with Google Analytics to track and analyze the use of the Services. The Google Analytics Advertising Features that we may use include Google Display Network Impressions Reporting and Google Analytics Demographics and Interests Reporting. To opt out of being tracked by Google Analytics across the Services, visit: https://tools.google.com/dlpage/gaoptout. You can opt out of Google Analytics Advertising Features through Ads Settings and Ad Settings for mobile apps. Other opt out means include http://optout.networkadvertising.org/ and http://www.networkadvertising.org/mobile-choice. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.
- Social Media and Public Forums. In certain circumstances, you may have the ability to share comments, testimonials, and other postings in public forums. If you choose to participate in these public forums, your personal information may be available to the general public. If you interact with us on social media platforms, the platform may be able to collect information about you and your interaction with us. If you interact with social media objects on our website (for example, by clicking on a Facebook “like” button), both the platform and your connections on the platform may be able to view that activity. To control this sharing of information, please review the privacy policy of the relevant social media platform.
- Business Transition. If Dejavoo, or any portion of our assets, are acquired by, merged with, transferred to, or invested in by another company, we may share your personal data with that company or other third parties involved in the business transition. We cannot promise that an acquiring party or the merged entity will have the same privacy practices or treat your information the same as described in this Policy.
- Legal. We may share information where necessary to comply with applicable law, to respond to requests from law enforcement agencies or other government authorities or third parties, as permitted by law, and without your consent when it is necessary to protect our customers, employees, or property, in emergency situations, or to enforce our rights.
Cookies And Other Tracking Technologies
We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Information about how we use such technologies and how you may refuse certain cookies is available in our Cookie Notice.Retention and Disposal of Personal Data
We retain information as long as necessary to fulfill the purposes for which we collected it, for legitimate business reasons, or as required by law. However, we may need to keep your data for longer than our specified retention periods to comply with legal or other obligations (e.g., such as tax, accounting, or other legal requirements). Personal data is disposed of by using secure means, such as electronic deletion or making it data anonymization.How We Keep Your Personal Data Safe
We have implemented appropriate and reasonable technical and organizational security measures, including encryption protocols, access controls, and regular security audits, designed to safeguard the security of any personal data we process. The objective of measures is to prevent accidental loss, unauthorized access, alteration, or disclosure of personal data. Access to your personal data is limited to authorized personnel, agents, and contractors who have a business need to know, who are governed by confidentiality agreements and will only process your personal data according to our instructions. Furthermore, we have created an incident response plan to rapidly address any data breaches or security incidents. Our commitment to data security and compliance with industry standards ensures that your personal data is handled with the highest level of care and protection.Children’s Privacy
Our website is not directed to individuals under 13 and we do not knowingly solicit or collect personal information from children. If we are notified or discover that a child under the age of 13 has submitted personal information to us, we will take reasonable steps to delete the information.Your Rights and Choices
In this section, we describe the rights and choices available to all users. You may have certain rights relating to your Personal data, depending on our reason for processing your personal data and the requirements applicable by law (e.g., your location such as EU, UK, California, Colorado), which may include:- The right to access your personal data.
- The right to have your personal data rectified, corrected, or updated.
- The right to know what personal data is being collected and for what purpose.
- The right to have your personal data deleted, including from any third parties where your personal data has been sold, shared, or disclosed.
- The right to know what personal data is being “sold” or “shared”, for what purpose and the categories of recipients of your personal data.
- The right not to be subject to any automated decision making and profiling.
- The right to object to the processing of your personal data.
- The right to opt out of the “sale” or “sharing” of your personal data.
- The right to non-discrimination for exercising a privacy right: We will not discriminate against you for exercising any rights.
- Additional Information for Individuals in the European Union and United Kingdom
- Additional information for
consumers in the United States
- California Residents
- Colorado, Connecticut, and Virginia Residents
- Utah Residents
- Additional Information for Canadian Residents
Exercising Your Rights
To exercise these rights, you may contact us by email at [email protected] or by calling the toll-free at 877-358-6797 Ext.194 If you have a complaint about how we handle your data, we would like to hear from you. For jurisdiction-specific information see:- Additional Information for Individuals in the European Union and United Kingdom
- Additional information for
consumers in the United States
- California Residents
- Colorado, Connecticut, and Virginia Residents
- Utah Residents
- Additional Information for Canadian Residents
Additional Information for Individuals in the European Union (“EU”) and United Kingdom (“UK”)
Legal basis for processing (EU and UK) The General Data Protection Regulation (GDPR) and United Kingdom (“UK”) GDPR require us to explain the valid legal bases (i.e., valid legal reason) we employ to process your personal data, which are outlined below. If you have questions about the legal basis of how we process your personal data Contact Us.- Consent. We may process your information if you have given us permission (i.e., consent) to use your personal data for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent in the Your Rights and Choices section.
- Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
Additional Information for Consumers in the United States
The table below summarizes categories of personal Information collected used and disclosed in the past twelve (12) months. We describe the sources through which we collect your personal data in the Information We Collect section, and describe the purposes for which we collect, use, and disclose this information in the How We Use Your Information.| Category of Personal Data | Collection | Disclosure | |||
| Collected | In past 12 months | For business purpose | For business purpose in the past 12 months | ||
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Identifiers | YES | NO | YES | NO |
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Professional related information | YES | NO | YES | NO |
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Internet or network data | YES | NO | YES | NO |
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Geolocation data | YES | NO | YES | NO |
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Inferences drawn from collected personal information. | YES | NO | YES | NO |
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User Content | YES | NO | YES | NO |
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Profiles and inferences | ||||
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Visual | YES | NO | YES | NO |
California Residents
Under the California Consumer Privacy Act (“CCPA”) and other California laws, California residents may have the following rights in addition to those set forth in the Your Rights & Choices section, subject to your submission of an appropriately verified request. To learn about how to submit a see Exercising Your Rights. Your rights with respect to your personal data include: Request to know – You may request any of the following, for the 12 month period preceding your request: (1) the categories of Personal data we have collected about you, or that we have sold, or disclosed for a commercial purpose; (2) the categories of sources from which your Personal data was collected; (3) the business or commercial purpose for which we collected or sold your Personal data; (4) the categories of third parties to whom we have sold your Personal data, or disclosed it for a business purpose; and (5) the specific pieces of Personal data we have collected about you. Right to request deletion of the data – You have the right to delete certain Personal data that we hold about you, subject to exceptions under applicable law. Right to Correct – You have the right to correct certain Personal data that we hold about you, subject to exceptions under applicable law. Right to Non-Discrimination – You have the right to not receive discriminatory treatment as a result of your exercise of rights conferred by the CCPA. Opt-Out of Sale or Share – If we engage in sales or sharing of data as defined by applicable law, you may direct us to stop selling, sharing or disclosing Personal data to third parties for commercial purposes. Direct Marketing – You may request a list of Personal data we have disclosed about you to third parties for direct marketing purposes during the preceding calendar year. Other privacy rights- You may object to the processing of your personal data.
- You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
- We will honor your opt-out preferences if you enact the Global Privacy Control (GPC) opt-out signal on your browser.
How to exercise your rights
To submit a request to exercise these rights described above, refer to Exercising Your Rights. Verification process Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for verification purposes. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and or security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.Colorado, Connecticut, and Virginia Residents
This section applies only to Colorado, Connecticut and Virginia residents. Under the Colorado Privacy Act (“CPA”), Connecticut’s Data Privacy Act (“CTDPA”), Virginia’s Consumer Data Protection (“CDPA”) Act, residents of Colorado, Connecticut, and Virginia have the listed below. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.- Right to be informed whether we are processing your personal data Right to access your personal data.
- Right to correct inaccuracies in your personal data.
- Right to request deletion of your personal data.
- Right to obtain a copy of the personal data you previously shared with us.
- Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”).
How to exercise your rights
To submit a request to exercise these rights described above, refer to Exercising Your Rights. If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf. If we decline to act regarding your request and you wish to appeal against our decision, please email us at [email protected]. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. Verification process Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. We will only use personal data provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for verification purposes. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and or security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.Utah Residents
Under the Utah Consumer Privacy Act (UCPA), you have the rights listed below. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.- Right to be informed whether we are processing your personal data Right to access your personal data.
- Right to request deletion of your personal data.
- Right to obtain a copy of the personal data you previously shared with us.
- Right to opt out of the processing of your personal data if it is used for targeted advertising or the sale of personal data.
How to exercise your rights
To submit a request to exercise these rights described above, refer to Exercising Your Rights.Additional Information for Canadian Residents
As a resident of Canada, you have certain rights regarding your personal information, including the right to access, correct, and request deletion of your personal information.How to exercise your rights
To submit a request to exercise these rights described above, refer to Exercising Your Rights.Nexus Portal Policy
The following policies apply to the Nexus Portal and govern portal access, acceptable use, brand usage, and data handling obligations for authorized users.1. Portal Usage Policy
The Nexus Portal is a proprietary environment designed to streamline operations for Dejavoo and its ecosystem. Access is a privilege granted to authorized users to facilitate business efficiency and data transparency.1.1 Access Eligibility & Authorization
- Authorized Users: Access is strictly limited to active partners, registered resellers, and internal Dejavoo staff.
- Request Process: Access must be requested through an official manager or account administrator. All users must undergo a verification process before credentials are issued.
- Role-Based Access: Users are granted access based on the “Principle of Least Privilege.” You will only see the data and tools necessary for your specific business function.
1.2 Standards of Appropriate Use
Users are expected to maintain professional conduct while using the portal. This includes:- Data Stewardship: Treating all customer and transaction data as highly confidential.
- Accuracy: Ensuring all information entered into the portal (orders, merchant info, support tickets) is accurate and up to date.
- Accountability: The account holder is legally and operationally responsible for every action taken under their login credentials.
1.3 Prohibited Activities
To maintain the integrity and security of the Nexus Portal, the following actions are strictly prohibited:- Credential Sharing: Sharing usernames or passwords with colleagues or third parties. Each individual must have their own unique login.
- Automated Extraction: Use of bots, scrapers, or scripts to harvest data without explicit written consent from Dejavoo.
- Security Circumvention: Attempting to bypass MFA (Multi-Factor Authentication) or testing the portal for vulnerabilities.
- Misuse of Assets: Using portal data for any purpose outside of authorized Dejavoo business.
1.4 Monitoring & Enforcement
Dejavoo reserves the right to monitor portal activity to ensure compliance with security protocols.- Suspension: Any suspicious activity or breach of these terms may result in the immediate suspension of access.
- Termination: Repeated or severe violations (such as data theft or credential sharing) will lead to permanent revocation of portal access and potential legal action.
2. Marketing & Brand Usage Policy
Dejavoo is committed to providing high-quality marketing resources that empower our partners to succeed. To maintain a premium and consistent global brand image, all partners must adhere to the following standards when utilizing Dejavoo intellectual property.2.1 Authorized Use of Brand Assets
- Logo Integrity: Partners may use official Dejavoo logos, product photography, and marketing templates exclusively for the promotion of Dejavoo products and services.
- Asset Sourcing: Only assets downloaded directly from the Nexus Portal Marketing Hub or provided by an official Dejavoo representative are authorized for use.
- Modification Prohibitions: Assets may not be altered, stretched, recolored, or combined with other graphics in a way that obscures the original brand identity.
2.2 Claims, Pricing, and Disclaimers
- Technical Accuracy: All product claims (e.g., processing speeds, hardware specs) must reflect current Dejavoo documentation.
- Pricing Transparency: When displaying pricing, partners must include all necessary legal disclaimers regarding processing fees, contract terms, or hardware lease requirements.
- Non-Endorsement: Marketing materials must not imply that Dejavoo is a partner in a joint venture or that Dejavoo endorses a partner’s third-party products unless explicitly stated in writing.
2.3 Review & Pre-Approval Requirements
To ensure compliance and brand alignment, certain materials require a mandatory review by the Dejavoo Marketing Team:- Co-Branded Campaigns: Any advertisement where the Dejavoo logo appears alongside a partner or third-party logo.
- Custom Creative: Any asset created from scratch that mentions Dejavoo hardware or proprietary software features.
- Mass Media: Any use of the brand in press releases, television, radio, or high-traffic digital billboards.
2.4 Restrictions & Misuse
- Keyword Bidding: Partners are prohibited from bidding on “Dejavoo” branded keywords in SEM (Search Engine Marketing) without prior written authorization.
- Domain Names: Partners may not register domain names containing the word “Dejavoo” or any confusingly similar variations.
- Unauthorized Messaging: Messaging that guarantees specific financial outcomes or uses “bait-and-switch” pricing tactics is strictly prohibited and may result in the termination of the partnership.
2.5 Requesting Support
For custom collateral requests, brand guideline PDF downloads, or to submit a campaign for review, please contact your Relationship Manager.3. Privacy & Data Handling Policy
The Nexus Portal displays information related to partners, merchants, orders, and transactions. All users must handle this data in accordance with applicable privacy laws and Dejavoo’s data protection policies.3.1 Data Sources and Scope
All data displayed in the Nexus Portal is sourced from Dejavoo’s Priority ERP and CRM systems in accordance with your existing contractual agreements with Dejavoo. The portal serves as a front-end interface to view and manage this information but does not independently store or process the underlying data. Information displayed may include:- Business and merchant account details
- Order history and transaction amounts
- Pricing and contract terms as agreed upon in your contract
- Other business-related information necessary for account management
3.2 Permitted Use of Data
Portal access is granted solely for legitimate business purposes related to managing your account, reviewing orders, and conducting business with Dejavoo. Users may only access data pertaining to their own organization’s account. Prohibited activities include:- Sharing portal data with third parties outside your contracted organization
- Using data for purposes unrelated to your business relationship with Dejavoo
- Attempting to access, modify, or view data belonging to other merchants or accounts
- Scraping, automated extraction, or bulk downloading of portal data
3.3 Account Security and Access Control
Credential Protection- Portal login credentials are unique to each authorized user and must not be shared with anyone outside your organization
- Sharing credentials with unauthorized individuals outside your company may result in immediate account suspension or termination
- Users are responsible for maintaining the confidentiality of their passwords and account access
- Users must log out of the portal when stepping away from their workstation or completing their session
- The portal may implement automatic session timeouts for security purposes
- Do not access the portal from public or shared computers where session data may be compromised
3.4 Data Export and Documentation
Users are not permitted to independently export data from the Nexus Portal. If you require data exports, reports, or documentation for your records:- Contact your designated Dejavoo Sales Representative
- Submit a formal request to [email protected]
- Exports will be provided in accordance with your contractual terms and Dejavoo’s data security protocols
- Do not print sensitive portal information and leave it unsecured
- Do not take screenshots containing sensitive merchant or transaction data and store them in insecure locations (personal devices, unencrypted cloud storage, etc.)
- Do not download or copy portal data to personal devices or unauthorized storage
3.5 Data Retention and Deletion
The Nexus Portal displays current and historical order information as maintained in Dejavoo’s Priority ERP system. Data retention periods are governed by:- Your contractual agreement with Dejavoo
- Applicable legal and regulatory requirements
- Dejavoo’s enterprise data retention policies
3.6 Merchant Data Corrections and Updates
If you need to update business information, correct account details, or have questions about the data displayed in your portal:- Contact your designated Dejavoo Sales Representative directly
- For urgent issues, email [email protected]
- Users cannot directly modify core business data through the portal interface
3.7 Security Incident Reporting
If you suspect any of the following, you must report it immediately:- Unauthorized access to your portal account
- Suspicious activity or login attempts
- Data discrepancies or potential data breaches
- Loss or theft of devices with portal access credentials
- Email: [email protected]
- Phone: Contact your assigned Sales Representative directly
3.8 Privacy Compliance and Legal Framework
Dejavoo is committed to compliance with applicable privacy laws and regulations, including but not limited to:- General Data Protection Regulation (GDPR) where applicable
- California Consumer Privacy Act (CCPA) and similar state privacy laws
- Payment Card Industry Data Security Standard (PCI-DSS) for payment data handled by our CRM
- Other applicable data protection and privacy regulations
3.9 User Responsibilities Summary
As a Nexus Portal user, you are responsible for:- Keeping your login credentials secure and confidential
- Using portal data only for authorized business purposes
- Logging out when not actively using the portal
- Reporting security incidents immediately
- Complying with all data handling restrictions outlined in this policy
- Not sharing access with unauthorized individuals outside your organization
- Requesting formal approval for any data exports or documentation needs
3.10 Policy Updates
Dejavoo reserves the right to update this Privacy & Data Handling Policy as needed to reflect changes in:- Legal or regulatory requirements
- Portal features and functionality
- Security best practices
- Business operations
