Privacy Policy

Last Updated: October 2021

This Privacy Policy (“Policy”) describes the manner in which Naya Studio, Inc. (“Naya”, “we”, or “us”) and our website at www.Naya.Studio (the “Site”), as well as all related websites, networks, applications, and other services provided by us and on which a link to this Policy is displayed (collectively, together with the Site, our “Service”) collects and uses data from individuals. This Policy, which is incorporated into and is subject to the Naya Terms of Use, describes the information that we gather from you on the Service, how we use and disclose such information, and the steps we take to protect such information.

Information We Collect on the Service

• User-provided Information. When you use the Service, we may collect information about you, including but not limited to your name, company name, certain employee names, payment information, email addresses, physical addresses, geographic area, or geographic area preferences, and we may link this information with other information about you. You may provide us with information in various ways on the Service. For example, you provide us with information when you register for an account, log-in via various other services and websites such as Facebook, Google, or otherwise use the Service. If you integrate our account with a social service, such as Facebook, Google, or Apple, we may collect your user name and email address.

• Cookies and Automatically Collected Information. When you use the Service, we may send one or more cookies – small text files containing a string of alphanumeric characters – to your device. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Service. Please review your web browser “Help" file to learn the proper way to modify your cookie settings. Please note that if you delete, or choose not to accept cookies from the Service, you may not be able to utilize the features of the Service to their fullest potential. We may use third party cookies on our Service as well. For instance, we may use Google Analytics to collect and process certain analytics data. Google provides some additional privacy options described at www.google.com/policies/privacy/partners/ regarding Google Analytics cookies. Naya does not process or respond to web browsers’ “do not track” signals or other similar transmissions that indicate a request to disable online tracking of users who visit our Site or who use our Service. However, we will not attempt to track your activity on third party sites. Further, Naya shall use commercially reasonable efforts to prohibit you from receiving spam in connection with our Services.

• Third Party Web Beacons and Third Party Buttons. We may implement third party buttons (such as Facebook “like” or “share” buttons) that may function as web beacons even when you do not interact with the button. Information collected through third-party web beacons and buttons is collected directly by these third parties, not by Naya. Information collected by a third party in this manner is subject to that third party’s own data collection, use, and disclosure policies.

How We Use the Information We Collect.

We use information we collect on the Service in a variety of ways in providing the Service and operating our business, including the following:

• We use the information that we collect to provide you with the Service.

• We use the information that we collect on the Service to operate, maintain, enhance and provide features of the Service, and to respond to comments and questions and otherwise to provide support to users.

• We use the information that we collect on the Service to understand and analyze the usage trends and preferences of our users, to improve the Service, and to develop new products, services, features, and functionality.

• We may use your email address or other information we collect to contact you for administrative purposes and for other purposes such as customer service reasons or to send communications, including Service-related updates relating to the Service offered by us.

• We may use cookies and automatically collected information to: (i) personalize our Service, such as remembering information about you so that you will not have to re-enter it during your visit or the next time you visit the Service; (ii) provide customized content, and information; (iii) monitor and analyze the effectiveness of the Service; (iv) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (v) which Services you have participated in.

• We may use the information we collect to send you marketing emails, including emails about upcoming promotions, and other news, including information about products and services offered by us and our affiliates.  You may opt-out of receiving such information at any time: such marketing emails tell you how to “opt-out.” Please note, even if you opt out of receiving marketing emails, we may still send you non-marketing emails. Non-marketing emails include emails about your account with us (if you have one) and our business dealings with you.

• We may create anonymous, aggregated, or de-identified data.

• In some cases we may specifically ask for your consent to collect, use or share your personal information, such as when required by law. 

• We may use the information as we believe necessary or appropriate (a) to enforce the terms and conditions that govern our Services; (b) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity; and (c) to protect our rights, privacy, safety or property, and/or that of you or others.

When We Disclose Information.

Except as described in this Privacy Policy, we will not disclose information about you that we collect on the Service to third parties without your consent. When you provide information to us, you are giving us your consent to share information with the individual and entities with whom we work to provide the Services. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:

• We will disclose your information in connection with providing the Service. For example, we work with third party service providers to provide website, application development, hosting, maintenance, and other services for us. These third parties may have access to or process information about you as part of providing those services for us. Generally, we limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and we require them to agree to maintain the confidentiality of such information.

• We may disclose information about you if required to do so by law or in the good-faith belief that such action is necessary to comply with state and federal laws, in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.

• We also reserve the right to disclose information about you that we believe, in good faith, is appropriate or necessary to: (i) take precautions against liability; (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity; (iii) investigate and defend ourselves against any third-party claims or allegations; (iv) protect the security or integrity of the Service and any facilities or equipment used to make the Service available; or (v) protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights, property, or safety of others.

• Information about our users may be disclosed and otherwise transferred to an acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.

• We may make certain aggregated, automatically-collected, or otherwise non-Personal Data available to third parties for various purposes, including: (i) compliance with various reporting obligations; (ii) for business purposes; or (iii) to assist such parties in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through the Service.

Your Choices

You may, of course, decline to share certain information with us, in which case we may not be able to provide to you some of the features and functionality of the Service. You may update, or correct your account information and preferences at any time by accessing your account preferences page on the Service. Please note that while any changes you make will be reflected in active user databases within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

You may at any time delete your account. After you request deletion of your account, we will delete your Personal Data, if any, after a reasonable amount of time, not to exceed 90 days.

If you receive commercial email from us, you may unsubscribe at any time by following the instructions contained within the email. You may also opt out from receiving commercial email from us by sending your request to us by email at service@naya.studio or by writing to us at the address given at the end of this policy. We may allow you to view and modify settings relating to the nature and frequency of promotional communications that you receive from us in user account functionality on the Service. If you connect your Naya account to your Gmail account, you can modify your preferences for the Google services by visiting https://myaccount.google.com/security. If you connect your Naya account to your Apple account, you can modify your preferences for the Apple services by visiting https://www.apple.com/legal/privacy/. If you connect your Naya account to your Facebook account, you can modify your preferences for the Facebook services by visiting  https://www.facebook.com/policy.php.

Please be aware that if you opt out of receiving certain information from us or otherwise modify the nature or frequency of communications you receive from us, it may take up to ten business days for us to process your request, and you will continue to receive administrative messages from us regarding the Service.

Third-Party Services

The Service may contain features or links to websites and services provided by third parties. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the Service. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the Service. We encourage you to learn about third parties’ privacy and security policies before providing them with information.

Children’s Privacy

Protecting the privacy of young children is especially important. Our Site is a general audience site not directed to children, and we do not knowingly collect Personal Data from children under the age of 13 without obtaining parental consent.

Data Security

We use certain physical, managerial, and technical safeguards that are designed to improve the integrity and security of information that we collect and maintain. Please be aware that no security measures are perfect or impenetrable. We cannot and do not guarantee that information about you will not be accessed, viewed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

International Visitors

The Service is hosted in the United States. If you choose to use the Service from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your Personal Data outside of those regions to the United States for storage and processing. In addition, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Service. By providing any information, including Personal Data, on or to the Service, you consent to such transfer, storage, and processing.

We will comply, and will require that our personnel and subcontractors comply, with all applicable requirements of the GDPR, including, without limitation, ensuring that transfers of Personal Data to third countries are made only in accordance with the following: (a) the transfer is to a jurisdiction deemed by the European Commission to have an adequate level of protection; (b) the transfer is subject to contractual provisions approved by the European Commission; or (c) pursuant to a framework deemed adequate and approved by the European Commission. For purposes of this Agreement, “GDPR” means the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).  

Naya Studio complies with the EU-U.S. and the Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States.  Naya Studio (as Naya Studio Company) has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

Naya Studio may transfer your personal information to third parties as described in this Privacy Policy.  Naya Studio maintains contracts with its third-party service providers restricting their access, use and disclosure of personal information in compliance with our Privacy Shield obligations.  Naya Studio may be liable if these third parties fail to meet those obligations and we are responsible for the event giving rise to the damage. 

In compliance with the Privacy Shield Principles, Naya Studio commits to resolve complaints about our collection or use of your personal information.  European individuals with inquiries or complaints regarding our Policy should first contact Naya Studio at service@Naya.Studio.  Naya Studio has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States.  If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint.  The services of JAMS are provided at no cost to you.  If neither Naya Studio nor JAMS resolves your complaint, you may have the ability to engage in binding arbitration through the Privacy Shield Panel.  Additional information on the arbitration process is available on the Privacy Shield website at www.privacyshield.gov. 

Naya Studio may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.  The Federal Trade Commission has jurisdiction over Naya Studio’s compliance with the Privacy Shield. Naya Studio’s commitments under the Privacy Shield Principles are subject to the investigatory and enforcement powers of the Federal Trade Commission.

Changes and Updates to this Policy

Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time. If we modify this Policy, we will make it available through the Service, and indicate the date of the latest revision. In the event that the modifications materially alter your rights or obligations hereunder, we will make reasonable efforts to notify you of the change. For example, we may send a message to your email address, if we have one on file, or generate a pop-up or similar notification when you access the Service for the first time after such material changes are made. Your continued use of the Service after the revised Policy has become effective indicates that you have read, understood and agreed to the current version of this Policy.

Your California Privacy Rights

If you are a California consumer, for more information about your privacy rights, please see our California Consumer Privacy Statement.

How to Contact Us

Please contact us with any questions or comments about this Policy, information we have collected or otherwise obtained about you, our use and disclosure practices, or your consent choices by email at service@Naya.Studio.