Sakon’s Data Privacy Notice for Residents of California
Sakon’s Data Privacy Notice for Residents of the EU, UK and Switzerland – DPA for Customers
Sakon offers a suite of integrated applications that is used by our customers to seamlessly manage their IT Infrastructure and make better business decisions. This Privacy Policy applies to all of our customers as well as visitors.
This Privacy Policy describes how Sakon collects, uses and discloses information, and what choices you have with respect to the information.
Sakon complies with the EU-U.S. DPF, Swiss-U.S. DPF and UK Extension to the EU-U.S. DPF as set forth by the U.S. Department of Commerce, the European Commission, the UK Government, and the Swiss Federal Administration regarding the collection, use, and retention of personal information transferred from the European Union, Switzerland, and UK to the United States. Sakon has certified to the Department of Commerce that it adheres to the Data Privacy Framework principles. If there is any conflict between the terms in this privacy policy and the DPF Principles, the Data Privacy Framework Principles shall govern.
To learn more about the Data Privacy Framework, and to view our certification, please visit https://www.dataprivacyframework.gov/
The Federal Trade Commission has jurisdiction over Sakon’s compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF).
It is Sakon's policy to respect your privacy regarding any information we may collect while you are using our software applications and websites, collectively called the Services.
This Privacy Policy applies when you use our Services. For our customers and their employees, a link to this Privacy Policy is also available in the “My Profile” section of the application.
Sakon operates a web-based application named Sakon that is part of the services that we offer. The application consists of various modules and all such products, applications, websites are collectively called “Services”.
We process two main types of personal data.
1) Customer Data - Personal data that forms part of the data provided by our customers and their end-users for processing.
2) Other Data - Personal data about our customers, visitors and other individuals that is collected and processed directly by us.
Our Customers are the controller of their Customer Data. Sakon is the processor of Customer Data and the controller of Other Data.
As customers, you provide data to us for processing as part of usage of our Sakon applications.
Customer Data may be processed by us as a result of a customer’s use of the Services when our customers, or their end-users, input or upload information into the Service. For example, customers who use our Sakon application may upload Customer Data about themselves or their employees.
This data includes name, email address, phone number, landline number, job title for employees. We collect billing details for invoice purposes. Sakon also collects customer data, on our customer’s instruction, from third parties on their behalf.
Customers provide data that is necessary to create user accounts.
For creation of user accounts, you provide your name, email address, password, telephone number and correspondence address.
We also collect data when you use our applications and websites.
Sakon may receive your data from sources other than from you, such as Telecom Providers.
Data Provided by Telecom vendors
As part of customer data processing, we collect or receive, on your behalf, contact details within Telecom Invoices and portal login credential from Telecom Vendors.
We collect data through cookies.
Sakon uses cookies to help Sakon identify and track visitors, their usage of Sakon website, and their website access preferences. Sakon visitors can control cookies through your browser settings.
The information we collect from cookies may include your IP address, browser and device characteristics, referring URLs, and a record of your interactions with our Service. We will respect your choices relating to on-line tracking, whether you choose to reject individual cookies or set your web browser to reject cookies and other tracking technology. However, refusing a cookie may, in some cases, preclude you from using, or negatively impact the display or function of, the Service or certain areas or features of the Service.
How we use your personal data will depend on which Services you use and how you use those Services.
Customer Data will be used by Sakon in accordance with Customer’s instructions, including any applicable terms in the Customer Agreement and as required by applicable law. Sakon is a processor of Customer Data and Customer is the controller.
Other Data is used by us to provide our services, send our newsletters and to communicate with you by responding to your requests, comments and questions.
We have lawful bases to process your personal data. We have a legitimate interest in processing, also may in some cases use your consent as basis for lawfully processing your personal data.
We process your personal data only when we have a lawful basis. Presently, we have a legitimate interest and, in some cases, your consent as the lawful basis for processing. Our legitimate interest is to deliver the services to our customers. We have determined that our processing of your personal data is necessary to deliver the services to our customers, and that our processing of such data is no more intrusive than other ways of delivering the services to our customers. Finally, we believe that our processing of personal data will not cause unjustified harm in a way that would override our legitimate interest basis as provided under the Data Protection Regulations.
In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.
Where you have consented to a particular processing, you have a right to withdraw the consent at any time.
We use your data to authenticate you and authorize access to our services.
We only process Customer Data on behalf of our customers and in accordance with their instructions provided in the applicable Services agreement with us. We use the data that we have about you to provide our services and provide support to you. In each case, Sakon collects such information only in so far as is necessary or appropriate to fulfil the purpose of the interaction with our services.
We may send you service related messages or marketing / promotional materials. You may choose to restrict the collection or use of your personal information
We will update you with improvements in our services, new features and from time to time also carry out direct marketing of our products and services. Direct marketing is carried out only if you consent to receiving such communications from us.
The Sites and Services do not knowingly collect personal information from users under the age of 16
If you are under the age of 16, you are not permitted to use the Sites and Services or to disclose Personal Information. If we learn we have collected or received Personal Information from a child under 16, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us.
We will retain your personal information for as long as is needed to fulfil the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).
Customer Data - We retain your information for as long as you have an active Services account. We may also retain your personal information for extended period under applicable statutory laws.
Sakon will retain Customer Data in accordance with a Customer’s instructions, including any applicable terms in the Customer Agreement and as required by applicable law. When you decide to close your account, we delete all personal information about you.
Other Data - We retain your information for as long as necessary for the purposes that we have described in this Privacy Policy
Sakon may retain Other Information pertaining to you for as long as necessary for the purposes described in this Privacy Policy.
You can request to access, update or correct your personal information. You also have the right to object to direct marketing.
You may have additional rights pursuant to your local law applicable to the processing. For example, if the processing of your personal information is subject to the EU General Data Protection Regulation ("GDPR"), and your personal information is processed based on legitimate interests, you have the right to object to the processing on grounds relating to your specific situation. Under GDPR you may also have the right to request to have your personal information deleted or restricted and ask for portability of your personal information.
Whenever you use our services, we aim to provide you easy means to access, modify, delete, object to or restrict use of your personal information
We strive to give you ways to access, update/modify your data quickly or to delete it unless we must keep that information for legal purposes. Some rights can be access from within the Sakon application. For visitors, these rights can be exercised by contacting us with your specific request.
We keep some personal data even after account closure
Once you choose to close your account, we generally delete your personal information within 30 days of closure of your account. Some information that is necessary for statutory obligations such as records of payment processing, invoicing data will be retained as necessary.
Your data will be shared with other recipients in order to provide you with services.
While we aim to limit the sharing of your data, at times, it is necessary to share your data with certain service providers. Examples of when and for what purpose your data is shared include data center / hosting services, email marketing services, etc.
The following categories of recipient will most likely receive your data in order for us to provide services to you
To Comply with Laws. If we receive a request for information, we may disclose if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation or legal process. We may also share your data to an acquirer in the event of a sale of substantially all of our assets or other change of control transaction.
Please be aware that Sakon may be required to disclose an individual's personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
Sakon will be liable in cases of onward transfers to third parties
Your data will be stored and processed in multiple countries including outside of the European Union (EU) Region
Since we are an international company, your data will be processed outside of the EU region. Your data will be processed within Third Party Data Centers in USA and in Germany. Some countries where we process data may not have as protective laws as your own country and there are risks associated with such transfer.
Sakon offers European Union Model Clauses, also known as Standard Contractual Clauses, to meet the adequacy and security requirements for our Customers that operate in the European Union, and other international transfers of Customer Data. These clauses are contractual commitments between parties transferring personal data (for example, between Sakon and its Clients, suppliers or data processors outside the EU), binding them to protect the privacy and security of the data.
We implement security controls to prevent breaches and unauthorised access to your data.
We maintain reasonable and appropriate security measures to protect Customer Data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction.
Examples of security measures include physical access controls, encryption, HTTPS, restricted access to data, monitoring for threats and vulnerabilities etc.
We also subject our services to internationally recognised certification and attestation standards. Details about our security measures are available at www.sakon.com/security-measures.
Protection of personal information
Sakon takes all measures reasonably necessary to protect against the unauthorized access, use, alteration or destruction of potentially personally-identifying and personally-identifying information.
THIS NOTICE DESCRIBES HOW YOUR MEDICAL INFORMATION MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.
Effective date: August 11, 2020
This is a summary of how we may use and disclose your protected health information and your rights and choices when it comes to your information. We will explain these in more detail on the following pages.
We may use and disclose your information as we:
You have some choices about how we use and share information as we:
You have the right to:
At Sakon, we respect your privacy. We are also legally required to maintain the privacy of your protected health information (PHI) under the Health Insurance Portability and Accountability Act (HIPAA) and other federal and state laws. We follow state privacy laws when they are stricter or more protective of your PHI than federal law.
As part of our commitment and legal compliance, we are providing you with this Notice of Privacy Practices (Notice). This Notice describes:
If you have any questions about this Notice, please contact [INSERT CONTACT INFORMATION].
Your PHI:
Is health information about you:
Includes information such as your:
If we receive a record of the care and health services, you receive this Notice applies to all the PHI that we receive or generate.
If we receive a record of the care and health services, you receive this Notice applies to all the PHI that we receive or generate.
We can change the terms of this Notice, and the changes will apply to all information we have about you. The new notice will be available on request, in our office, and on our website.
The law permits or requires us to use or disclose your PHI for various reasons, which we explain in this Notice. We have included some examples, but we have not listed every permissible use or disclosure. When using or disclosing PHI or requesting your PHI from another source, we will make reasonable efforts to limit our use, disclosure, or request about your PHI to the minimum we need to accomplish our intended purpose.
We may share your information in other ways, usually for public health or research purposes or to contribute to the public good. For more information on permitted uses and disclosures, see www.hhs.gov/ocr/privacy/hipaa/understanding/consumers/index.html. For example, these other uses and disclosures may involve:
For certain health information, you can tell us your choices about what we share. If you have a clear preference for how we share your information in the situations described below, please contact us and we will make reasonable efforts to follow your instructions.
You have both the right and choice to tell us whether to:
We may share your information if we believe it is in your best interest, according to our best judgment, and:
In these cases, we will only share your information if you give us written permission:
You may revoke your authorization at any time, but it will not affect information that we already used and disclosed.
When it comes to your health information, you have certain rights. This section explains your rights and some of our responsibilities to help you.
You have the right to:
You can contact us about this Privacy Policy or use of our services.
If you have questions or complaints regarding this Policy, you may contact us through email at privacy@sakon.com or through phone at 1- 800-601-1641. You may contact us at our mailing address below:
Sakon Inc,
44 Lake St, Suite 210
Burlington, VT 05401
If you are a resident of the European Economic Area and we maintain your Personal Data within the scope of the General Data Protection Regulation (GDPR), you have additional rights. If you are not satisfied with the resolution, you can also lodge a complaint with the Supervisory Authority in the country of your residence.
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Sakon commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU and UK and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF should first contact Sakon at privacy@sakon.com and at address
Sakon Inc,
44 Lakeside Avenue, Suite 111,
Burlington, VT 05401
Sakon has further committed to cooperate with the panel established by the EU data protection authorities (DPAs),the Swiss Federal Data Protection and Information Commissioner (FDPIC), the UK Information Commissioner’s Office (ICO) and the Gibraltar Regulatory Authority (GRA) with regard to unresolved DPF complaints concerning data transferred from the EU, Switzerland and the UK.
Finally, as a last resort and in limited situations, EU individuals may seek redress from the DPF Panel, a binding arbitration mechanism.
Sakon may change this Privacy Policy from time to time, at our sole discretion.
Sakon encourages visitors and customers to frequently check this page for any changes to its Privacy Policy. We will notify you of material changes in advance by email or by notice when you log in to the Sites and Services or both. You confirm that your continued use of our services after any change in this Privacy Policy will constitute your acceptance of such changes and agree to be subject to the revised privacy policy.