Todai Inc. (“Todai,” “we,” “our,” and/or “us”) values the privacy of individuals who use our websites and related services (collectively, our “Services”). This privacy policy (the “Privacy Policy”) explains how we collect, use, and disclose information about users of our Services.
This Privacy Policy applies to Personal Information that Todai processes as a controller, such as website, marketing, sales, recruiting, support, account administration, and business-contact information. It does not apply to Customer Data that Todai processes on behalf of a business customer as a processor or service provider under a customer agreement.
“Personal Information” means any information relating to an identified or identifiable individual.
“Customer Data” means personal information, content, records, communications, or other data submitted to or processed by Todai on behalf of a business customer under that customer’s agreement with Todai.
If you have questions about personal information processed by Todai on behalf of one of our business customers, please contact that customer directly. We may assist the customer in responding to privacy requests where required by our agreement with them.
Organizational Users and Customer Data
If you use Todai through an account provided by your employer or another organization, that organization may control or administer your use of the Services. This Privacy Policy does not apply to Customer Data that Todai processes on behalf of that organization under a customer agreement.
Customer Data may include business communications, records, content, and related information that the organization chooses to make available to Todai. In those cases, Todai processes Customer Data as a processor or service provider on behalf of the organization and in accordance with its instructions.
Your organization may be able to access, manage, export, restrict, or delete information associated with your use of the Services, depending on its agreement with Todai and the settings it controls. If you have questions or requests about Customer Data processed through your organization’s use of Todai, please contact that organization directly. If you contact Todai about Customer Data, we may refer your request to the relevant organization or assist that organization in responding to your request.
Personal Information We Collect
We may collect Personal Information from or about you or your devices from various sources, as described below. Where applicable, we indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so. If you do not provide Personal Information when requested, you may not be able to benefit from our Services if that information is necessary to provide you with them or if we are legally required to collect it.
A. Personal Information You Provide to Us Directly
Contact Information such as your name, email address, address, and phone number.
Professional information such as your employer, business contact details, job title, department, industry, sector, and LinkedIn profile.
Payment Information. If you make a payment on our Services, your payment-related information, such as credit card or other financial information, is collected by our third-party payment processor on our behalf.
Registration and Account Information. When you create an account or use the Services on behalf of an organization, we may collect information needed to set up, administer, secure, and support the account. This may include your name, work email address, company name, role or title, billing or administrative contact information, and information about authorized users, account administrators, or other personnel involved in managing the account.
Communications. If you contact us directly, we may receive additional information about you, such as your name, email address, phone number, the contents of a message or attachments that you may send to us, and other information you choose to provide. When you communicate with us online, third party vendors may receive and store these communications on our behalf.
Job applicant information. As we may post job openings and opportunities, if you reply to one of these postings by submitting your application, we will collect your full name, email address, phone number, resume, and cover letter. We use this information to assess your qualifications and suitability for the job. We may also collect other information such as your social media links, immigration status, and demographic information if you choose to provide this information to us.
B. Personal Information We Collect When You Use Our Services
Analytics and Usage Information such as your public IP address for incoming HTTPS requests and information about your activities on our 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).
Location Information. When you use our Services, we receive your non-precise location information by using your IP address.
Online Device Information. We receive information about the device and software you use to access our Services. This may include IP address, device type, browser type and version, operating system, referring URLs, pages viewed, timestamps, and similar diagnostic or usage information.
C. Information We Collect From Other Sources
Vendors and Service Providers. We may receive information about you from service providers that support our Services, such as analytics, security, customer support, recruiting, payment, hosting, and business operations providers. These service providers may collect or process information on our behalf, including through cookies and similar technologies used on our Services.
Personal Information from Different Sources. We and/or our third-party vendors and service providers may collect information about you from other sources, such as publicly available sources (including social media platforms like LinkedIn) and/or commercially available lists.
How We Use the Personal Information We Collect
Todai may use your personal information to do the following:
Provide the Services: We use Personal Information to operate, maintain, administer, secure, and provide the Services, including to create and manage accounts, authenticate users, provide requested features, communicate service-related information, and perform our agreements with customers or users.
Secure the Services: We process data by tracking use of our websites and services for the purposes of maintaining the safety and security of our Services, including verifying accounts and activity, investigating suspicious activity, and enforcing our terms and policies, in reliance on our legitimate interest in promoting the safety and security of our Services, systems and applications and in protecting our rights and the rights of others.
Provide customer support: To communicate with you, provide you with updates and other information relating to our Services, provide information that you request, respond to comments and questions, and otherwise provide support.
Send Marketing Communications: For marketing and advertising purposes, such as developing and providing promotional and advertising materials that may be relevant, valuable or otherwise of interest to you.
Comply with legal obligations: We process your personal information when cooperating with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws, for compliance purposes, including enforcing our terms of service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.
For our business or commercial purposes: We may use Personal Information for legitimate business purposes, such as maintaining and analyzing our records, identifying and communicating with potential customers, protecting against fraudulent, unauthorized, or illegal activity, improving the safety, security, performance, and reliability of our Services, understanding usage trends, measuring the effectiveness of our communications and campaigns, and operating and expanding our business activities.
We may use automated tools, including artificial intelligence and machine learning technologies, to help provide, secure, support, analyze, and improve the Services. We do not use Personal Information covered by this Privacy Policy or Customer Data to train or fine-tune generalized artificial intelligence or machine learning models, unless expressly permitted by agreement. We do not use Personal Information covered by this Privacy Policy to make solely automated decisions that have legal or similarly significant effects on individuals.
Processing job applications: We process your personal information if you apply for a job with Todai, to evaluate your application and make hiring decisions, communicate with you and inform you of current and future career opportunities (unless you tell us that you do not want us to keep your details for such purposes), manage and improve our recruiting and hiring processes, or to conduct reference and background checks where required or permitted by applicable local law. We perform this processing to the extent that it is necessary to comply with our legal obligations, for our legitimate interest in assessing the suitability of our candidates and managing our recruiting process, or, where required by applicable law, with your consent.
How We Disclose the Personal Information We Collect
We may need to share your personal information with third parties for the purposes of operating our business and maintaining and improving our Services.
We may share your Personal Information with the following categories of recipients:
Business Customers and Account Administrators. If you use the Services on behalf of an organization, we may disclose account, user, usage, support, security, and administrative information to that organization and its authorized representatives, such as account owners, administrators, billing contacts, security contacts, or other personnel responsible for managing the organization’s use of the Services.
Affiliates. We may disclose any Personal Information we receive to our current or future affiliates for any of the purposes described in this Privacy Policy.
Vendors and Service Providers. We work with third-party service providers to operate our Services, including for billing, payment processing, invoicing, analyzing data, providing IT-hosting and maintenance, and other services. These third parties may have access to or process your Personal Information as part of providing those services to us.
As Required By Law and Similar Disclosures. We may access, preserve, and disclose your Personal Information if we believe doing so is required or appropriate to comply with law enforcement requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; or respond to legally valid requests.
Merger, Sale, or Other Asset Transfers. We may transfer your Personal Information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets. The use of your Personal Information following any of these events will be governed by the provisions of this Privacy Policy in effect at the time the applicable Personal Information was collected.
Consent. We may also disclose your Personal Information with your permission.
We may share aggregated or deidentified usage data with third parties in the normal course of operating our business and to help us perform analysis and make improvements. For example, we may share information publicly to show trends in the use of our Services.
Your Rights and Choices
Device and Browser Controls. You may be able to control certain information collected through your browser or device settings, including cookie settings and, where applicable, location-sharing settings.
Marketing Communications. You can unsubscribe from our promotional emails via the mechanisms provided in the emails. Even if you opt out of receiving promotional email messages from us, you will continue to receive administrative messages from us.
Your European Privacy Rights. To the extent applicable, if you are located in Europe, you have the additional rights described below:
- Access and Portability. You may ask us to provide you with a copy of the Personal Information we maintain about you, including a machine-readable copy of the Personal Information that you have provided to us, and request information about its processing.
- Rectification and Deletion. You may ask us to update and correct inaccuracies in your Personal Information, or to have the information anonymized or deleted, as appropriate.
- Restriction and Objection. You may ask us to restrict the processing of your Personal Information, or object to such processing.
- Consent Withdrawal. You may withdraw any consent you previously provided to us regarding the processing of your Personal Information, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdrew your consent.
- Complaint. You may lodge a complaint with a supervisory authority, including in your country of residence, place of work, or where an incident took place. We would, however, appreciate the chance to deal with your concerns before you approach a supervisory authority, so please contact us in the first instance.
You may exercise your rights by contacting us using the details in the “Contact Information” section below. Before responding to a request, we may ask you to provide information reasonably necessary to verify your identity and authority to make the request. These rights may be subject to exceptions or limitations under applicable law. If we update, delete, or restrict Personal Information in response to your request, we will take reasonable steps to reflect that change in our active systems within a reasonable period of time. We may retain certain Personal Information where permitted or required by law, including for backup and archival purposes, security and fraud prevention, legal compliance, dispute resolution, enforcement of our agreements, or other legitimate purposes permitted by applicable law.
Third Parties
Our Services may contain links to other websites, products, or services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that this Privacy Policy does not apply to your activities on these third-party services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any Personal Information to them.
Retention
To the extent required by applicable law, we take measures to delete your Personal Information or keep it in a form that does not permit identifying you when your Personal Information is no longer necessary for the purposes for which we process it unless we are required by law to keep your Personal Information for a longer period. When determining the specific retention period, we consider various factors, such as the type of service provided to you, the nature and length of our relationship with you, and mandatory retention periods provided by law and the statute of limitations.
Security
We make reasonable efforts to protect your Personal Information by using physical and electronic safeguards designed to improve the security of the Personal Information we maintain. However, because no electronic transmission or storage of Personal Information can be entirely secure, we can make no guarantees as to the security or privacy of your Personal Information.
Children’s Privacy
We do not knowingly collect, maintain, or use Personal Information from children under 18 years of age, and no part of our Services is directed to children. If you learn that a child has provided us with Personal Information in violation of this Privacy Policy, then you may alert us using the contact details as indicated in the “Contact Information” section below.
International Transfers
We operate our business and provide our Services from multiple locations, including the United States, the European Union, and the United Kingdom. Depending on how you interact with us, your Personal Information may be processed in a country other than the one where you are located.
Our public website and certain business operations may be hosted or supported from the United States. For our customer offering, the location where Customer Data is hosted may depend on the region or hosting option selected by our customer and described in our agreement with that customer. In those cases, we process Customer Data as a service provider or processor on behalf of our customer and in accordance with their instructions.
Where required, we rely on appropriate safeguards such as the European Commission’s Standard Contractual Clauses, the UK International Data Transfer Addendum, or other lawful transfer mechanisms. You may contact us using the details below for more information about the safeguards we use for international transfers.
Additional Information For Individuals Located In Europe
To the extent required by applicable law, if you are located in the European Economic Area (“EEA”), Switzerland or the United Kingdom (“UK”) (together “Europe”), we only process your Personal Information as a controller when we have a valid “legal basis,” including as set forth below.
- Consent. You have consented to the use of your Personal Information. For example, we may process your Personal Information to send you marketing communications where you have consented to such use.
- Contractual Necessity. We need your Personal Information to provide you with our Services. For example, we may need to process your Personal Information to respond to your inquiries or requests.
- Compliance with a Legal Obligation. We have a legal obligation to use your Personal Information. For example, we may process your Personal Information to comply with tax, labor and accounting obligations.
- Legitimate Interests. We or a third party may have a legitimate interest in using your Personal Information for purposes such as securing, operating, analyzing, and improving our Services; detecting, preventing, and investigating misuse or security incidents; understanding how our Services are used; and supporting our business operations. We may also create and use aggregated or anonymized information that does not identify you for analytics, service improvement, quality measurement, and the development or improvement of statistical models. We do not use Personal Information covered by this Privacy Policy or Customer Data to train or fine-tune generalized artificial intelligence or machine learning models, unless expressly permitted by agreement.
Changes to this Privacy Policy
We will post any adjustments to the Privacy Policy on this page, and the revised version will be effective when it is posted. If we materially change the ways in which we use or disclose Personal Information previously collected from you through the Services, we will notify you through the Services, by email, or other communication.
Contact Information
For individuals located in the European Economic Area, Todai has appointed Adam Brogden as its EU representative. You may contact our EU representative at:
Adam Brogden
contact@gdprlocal.com
Tel: +353 1 554 9700
INSTANT EU GDPR REPRESENTATIVE LTD
Office 2,
12A Lower Main Street, Lucan, Co. Dublin
K78 X5P8
Ireland
For individuals located in the United Kingdom, Todai has appointed Adam Brogden as its UK representative. You may contact our UK representative at:
Adam Brogden
contact@gdprlocal.com
Tel: +44 1772 217800
1st Floor Front Suite
27–29 North Street
Brighton
England
You may also contact Todai directly at privacy-contact@todai.io.