Privacy Statement

Abukai, Inc. (“Abukai” or the “Company”) is committed to protecting the privacy of your information. This Privacy Statement describes Abukai’s information practices.

By clicking “OK”, “ACCEPT”, “AGREE”, “ACCEPT AND PROCEED”, “I ACCEPT” or similar button, or continuing to browse on our site or signing up for our Services, you are indicating your acceptance and consent to be bound by the terms and conditions of this Statement. This Privacy Statement describes how Abukai collects, uses, shares or otherwise processes personally identifiable information relating to individuals (“Personal Data”) and the rights associated with that processing. If you do not assent to this Statement, you must discontinue browsing our site and not use our Services. Abukai offers a variety of services that are collectively referred to as the “Service” or “Services.” Abukai’s Websites and Service are targeted at businesses and not individuals. Abukai may collect information from individuals who visit the Company’s Websites (“Visitors”) and individuals who register to use the Service (“End Users”) as part of their company’s Abukai account (“Corporate Account”) via the Websites or Mobile Applications. A company purchasing Services from Abukai that signed a “Services Agreement” with Abukai is our “Customer.”

Your acceptance of this Statement or use of the Abukai Services shall be deemed acceptance of the terms and conditions of this Statement. If you do not agree to all the terms and conditions of this Statement, you may not use Abukai Services.

1. Applicability of This Privacy Statement

This Privacy Statement applies to the processing of Personal Data collected by us when you

• visit Abukai’s Websites (http://abukai.com, https://abukai.com, and other Abukai web properties) (“Websites”),
• use Abukai’s Mobile Applications (“Mobile Applications”), which may be downloaded from our Websites, Apple’s App Store, Google Play, or possibly other app stores (if authorized by Abukai),
• receive communications from us or otherwise communicate with us, including but not limited to emails, phone calls, voicemails, or text messages,
• register for, attend or take part in conference calls, certifications, contests, events, meetings, programs, webinars or similar activities,
• are employed by a Customer of ours where your information has been shared with us in our capacity as a controller (for example, during the contracting process),
• use our Services where we act as a controller of your Personal Data,
• participate in surveys, research, or other similar data collection facilitated by us.

Please note that this Privacy Statement only applies to the use of your Personal Data by us or on our behalf. It does not apply to:

• Certain Personal Data collected by third parties during your communications or interactions with those third parties or your use of their products or services. For example, Abukai’s Websites and Mobile Applications may contain links to other websites. Abukai is not responsible for the information practices or the content of such other websites. The Company encourages you to review the privacy statements of such third parties to understand their information practices.
• Certain Personal Data processed, stored or hosted by us when we act as a Processor on behalf of our Customers in the course of providing our Service, in which case the privacy statement, policies, arrangement, or other agreements of the relevant Customer will apply, and our agreements with said Customer apply. Once a business (“Customer”) has signed a Services Agreement with Abukai, the Customer may provide us with certain Personal Data.

2. What Data We Collect

• Contact and Billing Information
  When purchasing or renewing Services, including additional Seats or Customizations, Abukai requires a Customer to sign a Services Agreement, Addendums or Change Requests, and to provide Abukai with billing information, such as billing name and address (“Billing Information”). Abukai may also collect other related information, such as which Services were purchased and when, and when which Services were used. Abukai, our banks and payment providers may also keep records of payments. When registering to use a Service, you may also have provided your email address, name, company information and other contact details to Abukai. In registering to use the Service, you will be creating an account with the Company (“User Account”), which may contain certain required contact information, billing information or other information you choose to provide.


• Company Employee Information
  Please contact your corporate account administrator to understand what data they share with Abukai. For example, Customers or End Users may have provided name, email address, job title, employee ID, unit, or other such information to facilitate the account setup and provisioning. When setting up End Users in Abukai, the Customer or End Users may enter their own personal information or personal information of other End Users.


• Customer Data Entered or Uploaded to Abukai Services
  End Users may enter or upload data such as notes, labels or email addresses or other information. Such information may be typed into the Mobile Application, or uploaded to Abukai Websites or Portals.
  
  End Users may also choose to use the Forward Reports or Delegate function in our Mobile Application or ABUKAI User Portal, entering information about another person. You must seek that person’s consent to our use of their name and email address. By providing us with their name and email address, you warrant that your designated email forward recipient or delegate consents to the use of their personal information in this manner. By providing us with an email address to forward your reports or setting up a person as your delegate, you agree that we may share your personal information with that person and instruct us to do so.


• Application Notifications Data
  Once you activate Abukai’s Mobile Application and if you gave Abukai the according permission prior, Abukai may utilize device user tokens (such as push notification identifiers or similar identifiers). Abukai may also use web-based notification identifiers.


• Region/Location Data
  When you visit Abukai’s Websites, browser, and other settings or information may be used to determine your region. Abukai may process location data from your Mobile Application if you give the Mobile Application permission to do so. A Customer representative may also have entered certain location, region-related or unit information when setting up End Users. End Users or Visitors may also have submitted location information through web forms, email, or other means. Some of this information may also be derived from your device's Internet Protocol (“IP”) address.


• Data relating to Third Party Services Authorized by Customers
  Customers or End Users may have authorized third parties to send certain information to Abukai, or to receive information from Abukai such as accounting details, organizational information, project codes or other information. Some of these connections are automated, such as in the case of an integration with an accounting or ERP software. These third parties may also place Cookies when you authorize their services or software.


• Direct Communication Information
  You may submit information to Abukai and its agents, affiliates, contractors, employees, staff, partners, consultants or other representatives via methods including, but not limited to, email, web form input, support inquiries, participating in phone calls/online meetings/training sessions (which may be recorded), attending in-person meetings, visiting our offices, registering for/attending an event, interacting with our Websites or emails, interacting with our social media pages, filling out surveys, responding to questionnaires, or participating in other forms of research. Such communications may also contain files, screenshots, documents, contact information, emails, or other content. These communications may also contain feedback or other information relevant to improving Abukai Services, including, but not limited to ideas, concepts, enhancement, or other information you may have provided to Abukai or its affiliates.


• Data to Improve Services and Data Generated by ABUKAI
  Once you activate Abukai’s Mobile Application, we may collect information about the type of device and operating system version used.
  
  We may also use mobile, web analytics software, or tools provided by application stores or other parties to allow us to better understand our Customers. Such tools enable us to operate and provide our Services to our Customers. These tools may aggregate information such as how often you use our Mobile Applications, Services, or Portals, possible key events that occur within the Mobile Application, Websites or Portals, performance data, crashes, logs, reports, and possibly information about the region or location of where an End User downloaded or activated the Services. These tools often are integral parts of the app store platforms available to us.
  
  You may also choose to submit images including metadata, to Abukai, for example as part of an expense report or by emailing or uploading them to Abukai, or provide other data, formats, or specifications to Abukai, which may result in Abukai-generated data or may otherwise help Abukai improve its Services.


• Data to Protect You, Customers, the Public and Abukai When you visit Abukai’s Websites, use Abukai Services or utilize Abukai's Mobile Applications, the Company may collect your Internet Protocol (“IP”) addresses, MAC addresses, or similar identifiers. Abukai may also utilize location information, usage, device model, device operating system, and other account information.


• Job Application Information You may submit or provide your contact information, resume, CV, or other job application information to Abukai, via email, our Website, a third-party website, or other means.


• Customer Testimonials
  Abukai posts a list of Customers, case studies, and testimonials on the Company’s Websites that contain information such as Customer names, End User names, pictures, or job titles. By providing a testimonial, you grant Abukai a worldwide, perpetual, royalty-free, irrevocable (subject to mandatory data protection requirements), nonexclusive, fully sublicensable license to use, reproduce, modify, adapt, translate, publish, publicly perform, publicly display, broadcast, transmit and distribute the testimonial for any purpose, including marketing, and in any form. You agree that any rights, licenses, or obligations hereunder may be assigned by Abukai. This information will only be posted if Customer or End User grants that right in a Services Agreement or grants that right via written permission.


• Referral Information
  You may also choose to refer Abukai to a colleague or other person that might be interested in Abukai or Services. You must seek that person’s consent to use their name and email address so that we may contact them about the Abukai Service. By providing us with the name and email address of a referral, you warrant that your referral consents to such contact.


• Personal Information We Collect from Other Sources
  We also collect information about you or your company from other sources including partners where you may have filled out an interest request to learn more about Abukai.


• Cookies
  When you visit our Websites, or an authorized third party, a cookie may be placed on your device that collections information, including Personal Data, about your online activities over time and across different sites.
  
  We use both session-based and persistent cookies on our Websites. Session-based cookies exist only during a single session and disappear from your device when you close your browser or turn off your device. Persistent cookies remain on your device after you close your browser or turn your device off.
  
  If you have chosen to identify yourself to Abukai, the Company uses session cookies containing information to allow the Company to uniquely identify you. Each time you log into the Service, a session cookie containing a unique identifier that is tied to your account is placed in your browser. A session cookie may also contain your preference to stay logged in to Abukai Websites.
  
  Abukai may also engage third parties to operate portions of the Website and Service. Abukai does not control what information these Third-party Cookies contain. Please refer to the privacy statements of each third party, and see Section 3 “Cookies” and Section 6 in this document for additional details. For example, we engage a third party to process payments on our Website. That third party may use cookies to process your purchase of Abukai Services.
  
  We categorize our own Cookies and Third-Party Cookies into Required and Functional Cookies. You may not opt out of Required Cookies as without them our Websites and Services do not function.
  
  List of Required Cookies, including which information is collected and how long the information is stored:

  Cookie name	Information Collected	Duration of information stored
  CONSENT	Required to store consent granted, level and date and operate website	24 months
  PHPSESSID	Required to operate website - stores ID of current browser session	Browser Session
  login_username	Required for operating User Portal.	Browser Session
  Idle_counter	Required for operating User Portal.	Browser Session
  presentationid	Required to host a presentation in ABUKAI Presentations.	Browser Session
  presentation_fileid	Required to host a presentation in in ABUKAI Presentations.	Browser Session
  Paypal cookies: ts_c x-csrf-jwt ts ui_experience cookie_check rmuc tsrce d_id LANG cookie_prefs TfXMWj95u2_Zf1Kmv_GCUOjlGG8 KHcl0EuY7AKSMgfvHl7J5E7hPtK login_email x-pp-s paypal-offers–cust nsid	Required to purchase an account on the Abukai Website.	Browser Session

   

  List of Functional Navigational Cookies, including which information is collected and how long the information is stored:

  Cookie name	Information Collected	Duration of information stored
  _ga	Required to improve Website and obtain general information about how users are using the Website to inform company, marketing, product, strategy and other departments – Google Analytics traffic information.	24 months
  _ga_ZXZVW1CQTV		24 months
  _gac_gb_UA_18414788_1		90 days
  _gid		24 hours
  _gat_gtag_UA_18414788_1		1 minute
  ABUKAI	Stores username and password only when the user checks ‘stay signed in’ to keep the user logged in when the browser session expired.	1 month
  ABUKAI2	Stores whether stay signed in was checked.	1 month



• Marketing Promotions Information
  From time to time, we may engage in marketing communications and may have collected your email address, name or other information for such purposes.
  
  

  We may also use web beacons, pixels or other tracking technologies on our Websites and in emails. For example, we may place a pixel in a marketing email that notifies us when you click on a link in the email. Abukai may use web beacons alone or in conjunction with cookies to compile information regarding Visitors’ usage of the Company’s Websites and interaction with emails from the Company. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular website tied to the web beacon, or a description of a website tied to the web beacon.

California law requires us to let you know how we respond to web browser Do Not Track (DNT) signals. Abukai does not respond to DNT signals. However, some third-party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. When you use such sites, you can change your web browser’s settings to reflect your cookie preferences. Each browser is a little different, but usually these settings are under the "options" or "preferences" menu.

3. Why We Process Data

Abukai will use information to effectively answer your requests, deliver and improve our Services, foster our business, and fulfill our obligations.

• Contact and Billing Information is needed to set up the Customer account per Customer's requirements, provision the account, additional configuration changes, and seats, manage account access and account maintenance, but also to send invoices, and other follow-up. Abukai also has obligations to keep records of this information for reporting purposes and may need this information for dispute resolution. Abukai may also pass payment information to a third-party payment processor to check the financial qualifications of prospective Customers and to collect payment for a Service.

• Company Employee Information is used to allow End Users to connect to Customer's account. The information is needed to ensure that the right configuration is activated for certain End Users. In some cases, this information also gets used to appropriately route information to approvers or other End Users, or to enable the Company to follow-up with you. Utilizing your name in Abukai may also make it easier for other End Users to understand whose reports or other information they are reviewing.

• Customer Data Entered or Uploaded to Abukai Services will be used to render your Services. For example, a forward email address will be used to forward your reports to that person. For example, your information might be shared with an approver, or other person at your company per a Customer’s instructions.

• Application Notifications Data may be used to provide you with notifications about our Services in the Mobile Application or Websites (such as push or web notifications). These notifications can be useful, for example, to remind you to file your expense report, or to notify you that an expense report was approved or has finished processing. Abukai may also notify you of certain features or capabilities to help assist or train End Users.

• Region/Location Data may be used to localize content, customize settings, formats, default currencies, or other information, account, or subaccount provisioning, as well as to recognize receipts or identify currencies. Your location information may also be used to create data more accurately for you, for example to better recognize receipts, invoices, currencies, locations, or vendors, and improve the results.
  
  This type of information may also be used to route inquiries or get you in touch with a person that may speak your language or is familiar with your area or type of business if available. The information may also be used for load balancing, to manage content distribution networks, and to improve service performance. Abukai may be required to retain certain location information such as billing location, place of purchase or use, due to Abukai’ s legal, accounting, reporting, and other obligations.

• Data relating to Third Party Services Authorized by Customers will only be sent to third parties with the authorization of the customer and for the purposes requested by the Customer or to fulfill any other contracts in place such as Abukai Services Agreements. Please refer to the privacy resources of the relevant third parties. Section 6 in this document may also provide additional details.

• Direct Communication Information may be used to provide support, conduct trainings, receive or facilitate feedback, help Customers, Visitors and/or End Users or otherwise provide Services. We may use the information to identify or investigate potential issues or errors, to inform future trainings or plans, to develop training materials, generate ideas, product development purposes, to review information with stakeholders for input, to enhance or improve the Services, and other activities of legitimate interest to us. Such information may also contain feedback, ideas, concepts, enhancements, or other information you have provided to Abukai, Abukai employees, contractors, consultant, partners, or other affiliates that Abukai may then use.
  
  Direct Communication information will be used to respond to a possible inquiry or request, and to follow up with you. We may also use the information for on-going quality assurance, training and administration purposes.
  
  Additionally, Abukai retains such information per its policies and to protect its business. Abukai may also be legally required to retain certain information.

• Data to Improve Services and Data Generated by Abukai may be used to better understand our Customers as well as operate and provide our Services to our Customers. You agree that Abukai has a legitimate interest to better understand Customers and to further develop its products and improve its Services as well as a legitimate interest to fulfil its contractual obligations and deliver a great service experience.
  
  Abukai may generate or derive data, or data files based on the data submitted such as learning databases, machine learning models, logic, expense data, lists of vendors or locations, training datasets, develop review processes, or develop new products or services. For example, Abukai may derive this data by processing images and other transaction data to render your Services per our terms or agreements. You agree that Abukai has a legitimate interest in learning from the data received to further improve Services, for example to improve the recognition quality of receipts, invoices, or other documents, develop better algorithms, improve the Services for you and other customers, and advance its R&D. Please note that data and files generated by Abukai for its purposes are owned by Abukai and represent Abukai data. Such learning is an integral part of Services required for our Services to function.

• Data to Protect You, Customers, the Public and Abukai
  We may use information to detect, prevent, investigate and respond to fraud, abuse, security risks, intellectual property violations, service term violations, service outages, attacks, or other technical issues that could harm you, other users, our Customers, the public, or Abukai. Abukai may also use this information to identify or investigate possible issues, outages, bugs, or errors.
  
  We are legally required to maintain appropriate technical and organizational measures for security purposes and processing such information is a critical corner stone to keeping up appropriate security.

• Job Application Information
  This information may be kept on file to consider your application at a later date. Abukai may also choose to invite you to an interview or request additional information to evaluate you as an applicant. If you do not want Abukai to follow-up with you, do not provide the information you do not wish to share. This information may be used to assess an applicant’s qualifications and your fit for a role at Abukai.

• Customer Testimonials are essential for Abukai to successfully compete in the marketplace, and so we can continue to offer great Services. Case studies, testimonials, and reviews help us better market, differentiate and explain our Services to prospective Customers and how Abukai can be used. We appreciate supporting us in this manner and you licensing us your information for this purpose.

• Referral information may be used to process your request to refer our service to someone else, contact that person, and follow-up with that person to discuss their business, possible requirements, solutions, proposals, and Services. Referrals are the lifeblood of a business like Abukai and we appreciate your support and thinking of us when you know of others that could benefit from Abukai’s Services.

• Personal Information We Collect from Other Sources may be used to follow up with you or, for example, for us to do better research into how we could help you as a prospective customer, or possibly what challenges other stakeholders at your company may face that Abukai could help with. This type of information may help us prepare for important presentations or discussions about your business needs, and also may help us evaluate how much effort we should invest as a company in a certain business opportunity. We may also use such information to better network with prospective customers. Please refer to the privacy policies of other providers where you may enter your personal information to see how those companies may share your data.

• Cookies
  Cookies allow us to deliver key functionality, track use, infer browsing preferences, and improve and customize your browsing experience. We categorize our cookies into Required Cookies and Functional Cookies:

  • Required Cookies are essential to make our Websites work. For example, we may need to remember your consent preferences where applicable. Abukai also requires certain session cookies to work. For example, our Services need to uniquely identify you and serve the correct information to you after you log in, while protecting your information from unauthorized access. These session cookies allow the Company to uniquely identify you when you are logged into the Service and to process your online transactions and requests. For example, if you log in and approve an expense report, Abukai needs to store that information under your User Account and to render the Service. Session cookies are required to use the Service. We also require a session cookie to automatically log you out after a certain time period for security purposes.
    
    When placing a purchase through our Website, certain Third-party Cookies are required so the third party can process the payment to complete a purchase on the Abukai websites. Session cookies may also be required for ABUKAI Presentations so that the software knows which presentation you are actually hosting or participating in.

  • Functional Cookies are not 100% required to make our Website work, but may improve your experience and also help us in improving our Services. For example, when you select the option to "stay signed in" when logging in, a persistent cookie is required to let you stay logged in even if your browser session expired. Abukai uses persistent cookies that only the Company can read and use to identify browsers that have previously visited the Company’s Websites.
    
    Third-party Cookies may be used to track and analyze non-personally identifiable usage and volume statistical information from Visitors and End Users. Such information can be extremely helpful to improve our Websites, Services and content, and is essential for our business to effectively compete in a competitive marketplace. Such information can also help us make interactions with the Company and our Websites easier and more meaningful to you and others. For example, we may also use information to provide more personalized information about the Company or Services.

  Abukai may use information from session and persistent cookies in combination with other data to provide you with information about the Company and Services. The Company is especially careful about the security and confidentiality of the information stored in persistent cookies.
  
  Other Third-party Cookies may also be used to track the performance of advertisements we may place, for example with other websites. Such information may be re-associated with personal information after the Company receives it. There may also be other Third-party Cookies when browsing to third-party websites for example to authorize a certain web integration. These websites are not covered by this Privacy Statement. This Privacy Statement does not cover the use of Third-party Cookies on third-party websites, and you may want to review the privacy statements or policies of such other websites.

• Marketing Promotions Information
  

  Marketing Promotions Information may be used by the Company for sales and marketing purposes. For example, the Company may use information you provided to send you marketing emails. Or you may have subscribed to a newsletter. We may send you information regarding our Services, our Company or its partners. We may also send you information about promotions or events.
  
  We may use web beacons, pixels, and other tracking technologies to operate and improve our Websites and marketing emails. Web beacons may be used in marketing emails that notify the Company when you click on a link in the email that directs you to one of the Company’s Websites. Web beacons may be used to operate and improve the Company’s Websites and email communications. Information from web beacons may be used in combination with other data to provide you with information about the Company and the Service.

From time to time, we may also use your Personal Data to send important notices to you, such as communications about purchases you have made, or changes to our terms and conditions or other policies. This information is important to your interactions with us, and you acknowledge that you may not opt out of receiving these communications.

4. How You Can Control or Edit Data

• Contact and Billing Information

  During the duration of the contract, the Customer can edit Contact and Billing information through the Abukai Portal. Please contact your account administrator for details. We retain Contact and Billing information beyond the Service term, typically for a minimum of seven years, as required for tax and accounting purposes.

• Company Employee Information

  Please contact your corporate account administrator to understand what data they share with Abukai. The Customer's privacy statements, policy or agreements between you and your company may apply as they are the Data Controller, and have the rights to edit, delete or correct such information.
  
  In many cases, we collect information provided by our corporate customers, and in such cases, we may only have a limited relationship with the individuals whose information we process. If you believe your Personal Data has been collected by us in such circumstances and would no longer like to be contacted as an employee or customer of one of our corporate customers, please contact that corporate customer directly to request your removal. You or your Company are the sole custodian of your User Account, and you are responsible for the accuracy of all information contained in your User Account or otherwise provided to Abukai as personally identifiable information. You agree that Abukai is only a facilitator of the Service and has no responsibility for the accuracy of any such information.
  
  Usually, we recommend utilizing corporate email addresses with Abukai so that your account functions properly as the account may be tied to a corporate email domain. If there is high sensitivity, the Customer also has the option to utilize pseudo-anonymized email addresses as an additional security measure. Customers may choose to not include End User names in the employee information, however then approvers or other staff may have a harder time reviewing data and using the data for their accounting and analysis purposes.

• Customer Data Entered or Uploaded to Abukai Services

  Please contact your corporate account administrator to understand what data they share with Abukai. The Customer's privacy statements, policy or agreements between you and your company may apply as they are the Data Controller, and have the rights to edit, delete or correct such information.
  
  Please note that you also choose which information to send to Abukai for this purpose and hence have control over what information gets processed. This information can generally be further edited or corrected within Abukai or changed by you.
  
  For Forward Report or the Delegate function, you may choose who you designate to forward reports to or as delegate. You have the option to disable the report forwarding or delegation at any time, unless the Customer provided different instructions.

• Application Notifications Data

  You have full choice over whether to enable notifications via your mobile device or web browser and may disable the notifications at any time through your device, operating system or browser settings. When an account administrator removes an End User, this Application Notifications Data gets deleted. To update Application Notification Data in this case, End Users can simply authenticate or authorize a new device.

• Region/Location Data

  You have full choice over whether to share location information with Abukai and can turn on or off location services in the settings found on your device for Abukai. By default, location services are turned off on your mobile device unless explicitly turned on for Abukai by you. Please note that Abukai may recognize documents less well if location services are turned off for Abukai.
  
  You may also change your region settings on your device or in your browser. For information provided by a Customer representative, the Customer can also edit this information through the Abukai Portal. Please contact your account administrator for details or review the sections of the Abukai Portal that may be accessible to you. Your Customer may be under a legal obligation to retain certain information, for example for accounting and reporting purposes. Please check with your company contact.
  
  As for web forms, emails, or other means of communication, you can choose which location information you share, and can decide which information to make available for processing to us. Please note that Abukai may retain this information for its business purposes and may have a legal obligation to retain records per Abukai’s policies.

• Data relating to Third-Party Services Authorized by Customers

  Please contact your corporate account administrator to understand what data they share with third parties and with which third parties. The Customer's privacy statements, policy or agreements between you and your company may apply as they are the Data Controller, and have the right to edit, delete or correct such information. The Customer chooses which third-party services to connect to. The customer may instruct Abukai to disconnect those services at any time. Third parties privacy statements or policies may apply.

• Direct Communication Information

  You choose which information to send to Abukai for this purpose and hence have control over what information gets processed. Abukai may retain this information or may choose to delete such information per Abukai’s policies. Abukai may also be required to retain certain information for legal reasons for extended periods.
  
  Customers may opt out of communications not required for the fulfillment of any Services Agreement or the fulfillment of inquiries initiated by you or the Customer, or for the use of Abukai Services. Customers wishing to opt out of these communications should contact Abukai at https://secure.abukai.com/secure/?id=contact.

• Data to Improve Services and Data Generated by ABUKAI

  Mobile or web analytics software or tools provided by application stores or other parties may be provided or employed by other companies under their own privacy statement and/or legal agreements with you, for example by operating system vendors or application store operators. These companies may collect information about you when and how you interact with their devices, content, or services. In such cases, we are not responsible for the practices of these companies. Please consult their privacy policies to learn about their data practices.
  
  Please note that submitting images (of receipts, invoices, etc.) to Abukai is fully optional and decided by you. If you do not want certain information to be contained in the images, you do not have to submit that information or for example have the option to black out or strike out information that you do not want Abukai to process. Abukai only processes such images, if you submit those images, for example by clicking “Process Expense Report” in the Mobile Application or by otherwise agreeing to have them processed. Before any picture can be taken with the Abukai Mobile Application, you must grant Abukai the permission to take a picture or import an image from your photo gallery. You can remove that permission at any time through the settings on your mobile device for Abukai.
  
  Abukai-generated data, data files, learning databases, and other assets are Abukai Data, and retained by Abukai to ensure Abukai can offer best-in-class services and further its R&D. Abukai has the right to collect and use data generated by and through Customer’s and its End Users’ access to and use of Abukai Services and Software and residing on Abukai servers in aggregate, non-personally identifiable form for any purpose.

• Data to Protect You, Customers, the Public and Abukai

  Similar data gets commonly logged or collected through third-party routers, switches, access points, servers, or other devices that Abukai does not control, and provides the basis of how the Internet functions.
  
  As for data that Abukai collects, you may choose to not visit Abukai Websites or not use Abukai Services. You may also use a VPN to access Abukai that may utilize a different IP address than your original IP address for the access. Collecting such data is necessary to protect you, Customers, the public, and our Company. We need to maintain appropriate technical and organizational measures for security purposes as legally required, and this data allows us to fend off or investigate potential attacks on us, or misappropriations of our Services and intellectual property.

• Job Application Information

  You may choose not to send information to Abukai or apply to Abukai jobs via third-party websites. Abukai may keep your information on file to consider an applicant at a later date. Abukai may also retain certain information to protect its business.

• Customer Testimonials

  You may choose not to send information to Abukai for Customer Testimonials. Given the license granted, Abukai has no responsibility to update or correct testimonials and related materials. Abukai may, at its sole discretion, remove, replace, edit, or otherwise modify customer testimonials or related materials.

• Referral Information

  You may choose not to refer people to Abukai. If someone has referred you without your permission, you may request that Abukai delete your information.

• Personal Information We Collect from Other Sources

  Please review the privacy statements or policies of other sources where you may have published or shared information that may be available to us or may have been otherwise shared with us.

• Cookies

  Standing alone, cookies do not personally identify you. They merely recognize your web browser. Unless you choose to identify yourself to Abukai, either by responding to a promotional offer, opening an account, signing in to Abukai Services, or filling out a Web form (such as a “Contact Us” or a “Custom Account Request” Web form), you remain anonymous to the Company.
  
  If you do not want cookies tracked at all, you can also disable cookies through your browser. Additional cookies may reside on other portions of the Website in order to provide the Abukai Service. EEA Visitors, and those in select other jurisdictions, must provide consent for the collection of anything besides Required Cookies. If you reside in the EEA, United Kingdom, or Switzerland you can find how to adjust your consent at any time in section 9 of this Statement.
  
  While you can opt out of Functional Cookies, you may not opt out of Required Cookies as we must use them to deliver the Website and key portions of our Websites will not function without them.
  
  You can also control the use of cookies on your device, but choosing to disable cookies on your device may limit your ability to use some features on our Websites or Services. If you disable your Web browser’s ability to accept cookies, you will be able to navigate the Company’s Websites, but you will neither be able to successfully purchase nor use our Services. Most browsers allow you to manage how cookies are set and used as you’re browsing, and to clear cookies and browsing data. Also, your browser may have settings letting you manage cookies on a site-by-site basis. Here is a link to information from some of the larger browsers about how you can control your browser cookies: https://allaboutcookies.org/how-to-manage-cookies. You may visit allaboutcookies.org to learn more cookies and how to block cookies using different types of browsers or mobile device. Please note, however, that by blocking or deleting cookies used on the Website or Mobile Application, you may not be able to take full advantage of Abukai Services.
  
  For Third-party Cookies, we advise reviewing the privacy statements or policies of those third parties as we do not control those third-party websites.

• Marketing Promotions Information

  Customers may opt out of communications not required for the fulfillment of any Services Agreement or the fulfillment of inquiries initiated by you or the Customer, or for the use of Abukai Services. Customers wishing to opt out of these communications or unsubscribe from our marketing emails should contact Abukai at https://secure.abukai.com/secure/?id=contact.
  
  

After the end of the applicable retention period, we follow protocols to make sure data is deleted or retained in anonymized form where applicable. After completing these steps, copies of data may remain for a period in our encrypted backup systems. These backup systems are used to protect you against accidental or malicious deletion, for outage or disaster recovery, and to fulfill our legitimate interest as well as legal obligation to provide sufficient security standards.

If you are based within the EEA, United Kingdom, Switzerland, or within another jurisdiction having similar data protection laws, in certain circumstances you may have additional rights to control or edit your data. Please refer to Section 10, and Section 9 for adjusting privacy preferences.

5. How We Secure Data

Abukai uses robust security measures to protect Personal Data from unauthorized access, maintain data accuracy, and help ensure the appropriate use of Personal Data. When the Service is accessed using current version of Google Chrome, Internet Explorer version 6.0 or later, Firefox version 2.0 or later, or Safari version 3.0 or later, Secure Socket Layer (“SSL”) technology protects Personal Data using both server authentication and data encryption. These technologies help ensure that Personal Data is safe, secure, and only available to Customer, and those to whom the Customer has granted access. Abukai also hosts its Websites in a secure server environment that uses firewalls and other advanced technology to prevent interference or access from outside intruders. Abukai also offers enhanced security features within some of its Services that protect Customers from non-employees linking to a corporate account. Customers can select to deploy additional Security measures.

Your User Account is also protected with certain user credentials, such as a valid username and password. You are responsible for taking all reasonable steps to ensure that no unauthorized person shall have access to your User Account, username, or password. It is your sole responsibility to authorize, monitor, and control access to and use of your username, password, and User Account by third parties. Customers are responsible for any Personal Data of users that they provide to Abukai, and are responsible for maintaining the security and confidentiality of their Abukai usernames and passwords. Despite our efforts to use these security measures to protect Customer’s data, we do not warrant or represent that your User Account will be protected against loss, misuse, or alteration by third parties.

Further you acknowledge that you herewith agree that Abukai, taking into account the nature of the processing, has in place the appropriate technical and organizational measures in place to process such data. You also acknowledge herewith that we have provided sufficient notices to you of potential future processors and that you had sufficient opportunity to object prior to entering any Services Agreement or this Agreement with Abukai.

6. Who We Share Data With

Abukai may share information with employees, staff, contractors, consultants, agents, affiliates, business partners, and representatives only in order to deliver the Abukai Services and to process information according to Section 2 and 3, our Services Agreements and other applicable terms, to provide support, engage in sales inquiries, and to fulfill any other contracts in place. Abukai may share Personal Data with the Company’s employees, staff, contractors, consultants, agents, affiliates, business partners, and representatives so that these parties can contact Customers, End Users and/or Visitors who have provided contact information on our behalf. Abukai may also share Personal Data with the Company’s employees, staff, contractors, consultants, agents, affiliates, business partners, and representatives to ensure the quality of information provided.

Abukai may utilize third-party payment processors and your information may be shared with the payment processor when purchasing or renewing Abukai Services to complete a transaction. Abukai may share your information with other End Users at your company, for example to facilitate an approval flow or reporting, as required to fulfill our Services Agreements and as instructed by the Customer.

Abukai does not share, sell, rent, or trade personally identifiable information with third parties for their own promotional purposes.

When we share information as described herein, we only share information with parties as described in this Privacy Statement and with Abukai, Inc. and the affiliates that Abukai controls that are either subject to this Privacy Statement or follow practices at least as protective as those described in this Privacy Statement.

Abukai reserves the right to disclose personally identifiable information of the Company’s Customers, End Users or Visitors if required by law or if the Company reasonably believes that disclosure is necessary to protect the Company’s rights and/or to comply with a judicial proceeding, court order, or legal process.

Third Party Services Authorized by Customers

Services may embed content provided by others or include links to other websites and applications. For example, customers may authorize Abukai to send information, such as accounting details, expense data, organizational information, project codes, or other information, to third party services, servers, or other software. Some of these connections, links, upload, or integrations are automated, such as in the case of accounting or ERP software integrations once established per the Customer’s request. The companies involved may collect information about you, such as when and how you interact with their content or services. We are not responsible for the practices of these companies. Please consult their privacy policies to learn about their data practices.

7. Legal Grounds for Processing

Once a business (“Customer) has signed a Services Agreement with Abukai, Abukai may process certain Personal Data on a contractual basis. Abukai also has a legitimate interest to process certain information. Abukai may also be under certain legal obligations to process information, and in some cases relies on your consent.

Contact and Billing Information – Legitimate Interest, Legal Obligation

Company Employee Information – Contractual

Customer Data Entered or Uploaded to Abukai Services – Contractual

Application Notifications Data – Contractual

Third Party Services Authorized by Customers – Contractual

Direct Communication Information - Legitimate Interest, Legal Obligation

Job Application Information – Legitimate Interest, Legal Obligation

Region/Location Data – Legitimate Interest, Legal Obligation

Data to Improve Services and Data Generated by ABUKAI – Legitimate Interest

Data to Protect You, Customers, the Public and Abukai - Legitimate interest, Legal Obligation

Customer Testimonials – Legitimate Interest, Contractual

Referral Information – Legitimate Interest

Personal Information We Collect from Other Sources – Legitimate Interest

Marketing Promotions Information – Consent, Legitimate Interest

Cookies – Consent, Contractual

In many cases, we collect information provided by our corporate customers, and in such cases, we may have only a limited relationship with the individuals whose Personal Data we process. If you believe your Personal Data has been collected by us in such circumstances and would no longer like to be contacted as an employee or customer of one of our corporate customers, please contact that corporate customer directly in order to request your removal or correction of your Personal Data.

In certain instances, when you consent to our processing your Personal Data for a specified purpose, you may withdraw your consent at any time, and we will stop any further processing of your data for that purpose.

8. International Transfers

Your Personal Data may be collected, transferred to, and stored by us or our affiliates in the United States. Your Personal Data may also be processed in other countries or jurisdictions, for example for review by other End Users such as approvers, or through our infrastructure, for example, our global content delivery networks we may utilize. Some of these countries or jurisdictions may not be subject to an adequacy decision by the European Commission or your local legislature or regulator and may not provide for the same level of data protection.

When we act as Data Processor for our Customers, we ensure that the recipient of your Personal Data offers an adequate level of protection and security, for instance by entering into the appropriate back-to-back agreements and, if required, standard contractual clauses or an alternative mechanism for the transfer of data as approved by the European Commission (Art. 46 GDPR) or other applicable regulators or legislators. Please refer to the privacy statements or other arrangements you may have in place with the Customer and how they may share, transfer or store your Personal Data.

9. Adjusting Privacy Preferences for Website and Mobile Data Collection of Persons Residing in the European Economic Area (EEA), United Kingdom, Switzerland and other jurisdictions

Adjusting Consent for the Abukai Websites
Persons residing in the EEA, United Kingdom, Switzerland and certain other jurisdictions have additional rights to withdraw consent at any time. You may at any time withdraw or adjust Website Functional Cookie consent granted hereunder. You may view and adjust your selection here. Your current selection is check marked.

(NOT AVAILABLE IN YOUR COUNTRY)

When you consent to our processing your Personal Data for a specified purpose, you may withdraw your consent at any time, and we will stop any further processing of your data for that purpose. In case Abukai is required to retain your Personal Data for legal reasons your Personal Data will be restricted from further processing and only retained for the term required by law. However, any withdrawal has no effect on past processing of personal data by Abukai up to the point in time of your withdrawal. Furthermore, if your use of an Abukai offering requires your prior consent, Abukai may not be (any longer) able to provide the relevant Service, content, offer or event to you after your revocation.

Adjusting Preferences for the Abukai Mobile Applications
For Abukai Mobile Applications, you can adjust location, notifications, camera, and/or other permissions. You can adjust these permissions for the Abukai Mobile Application through the operating system permissions selector or other settings on your device at any time. The Mobile Application can only access the information if you granted the relevant permission. Other information may only get processed if you entered it or otherwise agreed to processing it. Certain Mobile Applications may also provide you with an option to choose between Required Shared Preferences and Additional Shared Preferences, if applicable. Required Shared Preferences enable the Service, and its core features. While Additional Shared Preferences enable Abukai to obtain additional general information about how users are using the application and Service to improve the application. To adjust between Required and Additional Shared Preferences, please delete the Mobile Application and associated data from your device and reinstall the application from the mobile application store.

10. Requesting, Correcting, Updating, and Deleting Your Information (only available for Certain Visitors and Customers)

If you are based within the EEA, United Kingdom, Switzerland, or within another jurisdiction having similar data protection laws, in certain circumstances you have the following rights:

• the right to be told how we use your information and obtain access to your information;
• the right to have your information rectified or erased or place restrictions on processing your information;
• the right to object to the processing of your information e.g. for direct marketing purposes;
• the right to have any information you provided to us on an automated basis returned to you in a structured, commonly used and machine-readable format, or sent directly to another company, where technically feasible (“data portability”);
• where the processing of your information is based on your consent, the right to withdraw that consent subject to legal or contractual restrictions;
• the right to object to any decisions based on the automated processing of your personal data, including profiling; and
• the right to lodge a complaint with the supervisory authority responsible for data protection matters. To locate your area Data Protection Authority go to http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

Please note that only customers with these rights will have access to these procedures. If we hold any information about you, which is incorrect or if there are any changes to your details, you may see the information stored and rectify such information, at your discretion here. You are responsible for any incorrect information that you provide Abukai. You are personally responsible to rectify such information with the provided tool in the ABUKAI User Portal or through your ABUKAI Corporate Account. You acknowledge that your right to view, rectify and port your data record is satisfied by this tool. If you need to rectify any data that is not editable in the ABUKAI User Portal, please click here.

If you withdraw your consent to the use of your personal information for purposes set out in this Privacy Statement, we may not be able to provide you with access to all or parts of our Website, applications, and Services.

We will retain your personal information for the duration of our business relationship and afterwards for as long as is necessary and relevant for our legitimate business purposes, in accordance with the Abukai Data Retention, Marking and Destruction Policy or as otherwise permitted applicable laws and regulation. Where we no longer need your personal information, we will dispose of it in a secure manner (without further notice to you).

You can request from Abukai at any time information about which Personal Data Abukai processes about you and the correction or erasure of such Personal Data. Please note, however, that Abukai can delete your Personal Data only if there is no statutory obligation or prevailing right of Abukai to retain it. Kindly note that if you request that Abukai erase your Personal Data, you will not be able to continue to use any Abukai Service that requires Abukai’s use of your Personal Data. To request erasure of your personal data, please fill out this form.

If Abukai uses your Personal Data based on your consent or to perform a contract with you, you may further request from Abukai access to a copy of the Personal Data or a transfer of that data that you have provided to Abukai by filling out this form. Abukai will carefully consider your request and discuss with you how it can best fulfill it. For ABUKAI Expenses, you may obtain a copy of your Personal Data by logging on to the ABUKAI User Portal at abukai.com/user. You may also rectify any incorrect Personal Data there.

Furthermore, you can request from Abukai that Abukai restricts your Personal Data from any further processing in where the processing is inappropriate.

11. Abukai’s Notice of Certification Under the EU-U.S. Data Privacy Framework program (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework program (Swiss-U.S. DPF)

Effective as of September 5, 2023, Abukai, Inc. complies with the EU-U.S. Data Privacy Framework program (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework program (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Abukai, Inc. has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Abukai, Inc. has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework program Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov.

Scope
Abukai adheres to the principles of the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF with respect to personal data submitted by Abukai’s Customers in reliance on the Data Privacy Framework to the following online Services: ABUKAI Expenses, ABUKAI Invoices, ABUKAI Presentations, ABUKAI ToDo, and other Services that may be made available.

Data Processed
Abukai provides online services that our customers use to operate aspects of their businesses. These include services for processing expense reports and invoices, project management and sales. In providing these tools, Abukai processes data our customers submit to our services or instruct us to process on their behalves. While Abukai’s customers decide what data to submit, it typically includes information about their expenditures, accounting systems, customers, employees, and more.

Purposes of Data Processing
Abukai processes data submitted by customers for the purpose of providing Abukai’s online services to our customers. To fulfill these purposes, Abukai may access the data to provide the services, to correct and address technical or service problems, or to follow instructions of the Abukai customer who submitted the data, or in response to contractual requirements.

Third Parties who May Receive Personal Data
Abukai uses a limited number of third-party service providers to assist us in providing our services to customers. These third-party providers offer customer support to our customers, perform database monitoring and other technical operations, assist with the transmission of data, and provide data storage services. These third parties may access, process, or store personal data in the course of providing their services. Abukai maintains contracts with these third parties restricting their access, use and disclosure of personal data in compliance with our DPF obligations, and Abukai may be liable if they fail to meet those obligations and we are responsible for the event giving rise to damage. Note that Abukai does not share data with DPF non-agent third parties (as defined by the DPF principles) except for those expressly authorized by Customers. If that practice should change in the future we will update this policy and provide individuals with opt-out or opt-in choice as required.

U.S. Federal Trade Commission Enforcement
Abukai’s commitments under the DPF are subject to the investigatory and enforcement powers of the United States Federal Trade Commission.

Abukai acknowledges the right of EEA United Kingdom, and Swiss individuals to access their personal data pursuant to the DPF. Individuals wishing to exercise this right may do so by filling out this form.

Compelled Disclosure
Abukai may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. In compliance with the Data Privacy Framework Principles, Abukai, Inc. commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the DPF Principles. European Union, Swiss and United Kingdom individuals with DPF inquiries or complaints should first contact Abukai, Inc. here.

Abukai, Inc. has further committed to refer unresolved privacy complaints under the DPF Principles to an independent dispute resolution mechanism, Data Privacy Framework Services, operated by BBB National Programs. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/programs/all-programs/dpf-consumers/ProcessForConsumers for more information and to file a complaint. This service is provided free of charge to you.

If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/s/article/G-Arbitration-Procedures-dpf?tabset-35584=2.

We will not rely on the Swiss-US Data Privacy Framework or the UK Extension to the EU-US Data Privacy Framework until they enter into force, but we adhere to their required commitments in anticipation of their doing so.

12. Restrictions

Use of this Website by Children
This Website is not intended for anyone under the age of 18 years. If you are younger than 18, you may not register with or use this Website. If you are a parent or guardian and believe we may have collected information about a child, please contact us here.

Russia-Specific Provisions
The following applies to users who are resident in the Russian Federation: The services hereunder are not intended for use by citizens of the Russian Federation who are resident in Russia. If you are a Russian citizen residing in Russia, you are hereby notified that any Personal Data that you input into the services will be solely at your own risk and responsibility, that you expressly agree that Abukai may gather your Personal Data and will process this data in the United States and in other countries, and that you will not hold Abukai accountable for any potential non-observance of legislation of the Russian Federation.

13. Additional State Specific Disclosures

Abukai may be subject to the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), granting California residents extra rights. Abukai may be subject to the Colorado Privacy Act, Connecticut Data Privacy Act, Utah Consumer Privacy Act, and Virginia Consumer Data Protection Act and if Abukai is subject to the acts listed here, then the following disclosures are effective as of June 20, 2023.

Please note that if your company has signed a Services Agreement with Abukai, your company is considered the “business” per CCPA/CPRA and Abukai is the “service provider” per CCPA/CPRA.

California consumers have the right to receive notice of certain information about our data collection, use, and disclosure. The following list summarizes the categories of personal information we may collect that may be disclosed to service providers. We may collect personal information (described in section 2 in this statement) for the purposes (described in sections 3 of this statement):

• Identifiers
• Commercial information
• Internet activity information
• Financial information
• Professional and employment-related information
• Geolocation data
• Audio and visual data
• Inferences drawn from any of the above information categories.

Your Data Rights
You may have certain data rights under your state’s privacy laws including to request information about the collection of your personal information by us, to access your personal information or to correct or delete your personal information. If you wish to do any of these things, please contact us here. Additionally, you may have the right to appeal the denial of any of these rights by submitting a form that will be provided to you if we deny a data request. Depending on your data choices, certain services may be limited or unavailable.

To ensure the security of your Abukai account, we will generally ask you to verify your request using the contact information you have already provided. If you are an authorized agent making a request on behalf of a consumer pursuant to the California Privacy Rights Act, we may ask you to provide information verifying you have proper authority to make the request on behalf of the consumer or we may ask the consumer to verify their identity with us directly.

No Sale of Personal Information Including Sensitive Personal Information and California Privacy Rights Act Sensitive Personal Information Disclosure We do not sell any personal information of consumers, as the term is defined under the California Privacy Rights Act. Your personal information processed by Abukai is only shared with Abukai’s third party service providers in accordance with this Privacy Statement and any Services Agreement. Abukai may transfer your Personal Information to our service providers as part of providing our Services, but these transfers are conducted under contracts that protect your data from additional uses and are not considered a sale pursuant to California law.

California Privacy Rights Act Retention Disclosure
We keep your personal information to enable your continued use of Abukai Services, for as long as it is required in order to fulfill the relevant purposes described in either this Privacy Statement, as allowed by any Services Agreement, as permitted, as may be required by law, or as otherwise communicated to you.

California Privacy Rights Act Non-Discrimination Statement
We will not discriminate against any consumer for exercising their rights under the California Privacy Rights Act.

Colorado Privacy Act Profiling Disclosure. We do not engage in profiling of consumers in furtherance of automated decisions that produce legal or similarly significant effects, as those terms are defined under the Colorado Privacy Act.

California Privacy Rights Act, Colorado Privacy Act, Connecticut Data Privacy Act, Virginia Consumer Data Protection Act, and Utah Consumer Privacy Act De-identified Data Disclosure. Abukai may use de-identified data in some instances. We either maintain such data without attempting to re-identify it or treat such data as personal data subject to applicable law.

14. Changes to this Privacy Statement

Abukai reserves the right to change this Privacy Statement. Abukai will provide notification of the material changes to this Privacy Statement through the Company’s Websites. Your continued use of the Abukai’s Websites and/or Services following the posting of changes to the Privacy Statements means that you accept the changes and agree with the terms contained therein. We encourage you to regularly review this Privacy Statement, and we will indicate the date the last changes were published.

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy.

15. Contacting Us

Questions regarding this Privacy Statement or the information practices of the Company’s Websites should be directed to Abukai Privacy by contacting us here or emailing us at support@abukai.com.

This Privacy Statement is effective as of September 3, 2023.