Data Privacy Policy

This data privacy policy describes how Abjayon Inc. (“Abjayon”, “we”, “us”, and “our”) collect, use and disclose the personal information (as defined below) of you (“consumer” or “you”) when acting as a business. This policy applies to personal information collected by our websites, applications, services, and products (collectively “services”), and during routine offline business contact with you.

In the context of this policy, personal information means information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information does not include publicly available information, deidentified or aggregated consumer information.


  1. Personal information we collect

The table below indicates the categories of personal information about consumers that we collect. Note that the examples given below do not represent a comprehensive list and that not all categories and examples shown below may apply to every consumer.

 Category Examples
Identifiers A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, or other similar identifiers.
Personal information categories A name, signature, address, telephone number, education, employment. Some personal information included in this category may overlap with other categories.
Protected classification characteristics Race, gender, ethnicity (optional)
Commercial information Records of services purchased or obtained from us, or considered, or other purchasing or consuming histories or tendencies relating to our services.
Internet or other similar network activity Browsing history, search history, information on a consumer’s interaction with our services and advertisements.
Geolocation data A device’s physical location – to the extent that an IP address may provide information regarding the location of a device you use to access our services.
Inferences drawn from personal information The creation of a profile or summary about, for example, an individual’s preferences, behaviour or characteristics.

Your personal information is required to enable us to provide our service to you. If you do not provide the necessary personal information, it may delay or prevent us from providing services to you. You confirm that you are authorized to provide to us the personal information which we shall collect on your behalf.


  1. Where we collect information from
  • Directly from you when you use our services or interact with us. We may also collect your personal data through the use of cookies and similar tracking technologies when you opt-in.
  • From the organization(s) to which you belong or person(s) who have arranged your access to our services, e.g., your employer or the institution you are affiliated with may provide us with contact information so that we can set up your login.
  • Our partners and service providers, e.g., technology providers in connection with your use of our services.
  • Public or paid-for sources, e.g., we may acquire information from data re-sellers or marketing lists from third parties.


  1. Purposes

Abjayon is permitted to process your personal data under the following legal grounds:

  • consent;
  • when processing is necessary for a business purpose stated in this policy or a following notice of collection;
  • compliance with legal obligations that Abjayon is subject to;
  • engaging in public or peer reviewed scientific, historical, or statistical interest; and
  • exercise or defence of legal claim.

We may use or disclose your personal information for one or more of the business purposes listed below or to carry out other reasonable business purposes consistent with this list:

  • Customer and product administration: to provide you with our services and information that you or the sponsoring organization requested or for which you have expressed an interest, or that you access through our services. Also, to create product accounts, provide user and technical support, enforce our terms of business, report product usage information to our customers and business partners, content and technology providers, manage customer information across our websites and services, contact you about renewal of your services, and to perform other related administrative tasks.
  • Product development and personalization: to deliver personalized functionality and content in our services, for instance we may retain your browsing and usage information to make your searches within our services more relevant. We also analyse product usage information to understand which content and tools are most useful for you and to allow us to deliver and suggest tailored content, features and other Abjayon services that we believe may interest you. We may also use information collected on our services, usually in aggregated form, to analyse the functionalities we offer and to improve the design and content of our services.
  • Product content: to organize and include information in our services and to include personal information which you choose to make available in our services (for instance, you may wish to provide information to enable peer connection and related collaboration).
  • Research activities: to maintain and support our research activities, which includes the identification and recruitment of research participants, related fieldwork, developing and providing research services and payment of incentives to a research participant or to contact you to participate in future research activities.
  • Marketing and events: to administer events we host or attend (e.g., conferences, webinars, etc.), to send you marketing messages for Abjayon services that may interest you and to provide you with advertising based on your activity. You can opt out from marketing messages at any time by clicking the unsubscribe link on the message. We do not disclose your contact information to third parties for their own marketing purposes unless we have obtained your consent to do so in accordance with applicable laws.
  • Security: to protect the security of our IT systems, architecture and networks as well as to prevent misuses of our services.
  • Legal rights: to exercise our rights and to the extent reasonably required, to assist third parties (such as your employee or our business partners) in exercising their rights, to carry out our contractual obligations, to defend ourselves from claims and to comply with laws and regulations that apply to our group or third parties with whom we work and for the purposes of fraud screening and prevention.
  • Business operations & restructuring: to operate our business which includes activities such as recordkeeping, accounting, training and quality management and improvement purposes. We may also use personal information to participate in, or be the subject of, any sale, merger, acquisition, restructure, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock.

We may also use your personal information as described to you in a supplemental or separate notice when collecting your information.


  1. Sharing your personal information

Abjayon shall adopt a reasonable standard of care to store and protect from disclosure of any personal information collected by limiting access to personal information and sensitive personal information to individuals on a ‘need to know’ basis.

We do not sell, rent, share, distribute, lease or otherwise provide your personal information to third parties, without your prior consent. Keeping this in mind, we may disclose Personal Information in the following cases:

Affiliates: We may provide your personal information to our affiliates and all business entities under Abjayon; to enable them to improve the Offerings and provide offerings related to the Offerings.

Service Providers: We may share your personal information with the service providers who work with us in connection with operating the Website and/ or providing the Offerings. All such service providers are subject to stringent confidentiality restrictions consistent with this policy.

Merger or Acquisition: We may transfer your personal information if we are acquired by another entity, or if we merge with another company or transfer a part of our business, including the Website, to a third party. Any such third party or resultant entity that receives your personal information shall have the right to continue to use your personal information in line with the purposes set out herein. In the event of such a sale or transfer, we may notify you.

Legal and Regulatory Authorities: We may disclose your personal information in order to comply with our legal obligations/ court orders/ requests by Govt. authorities.


  1. Sharing your sensitive personal information

Sensitive personal information is a subset of personally identifiable information that requires greater security protections and standards of care in handling. Sensitive personal information, also known as “special categories of information”, is defined as information that if lost, compromised, or disclosed could result in substantial harm, embarrassment, inconvenience, or unfairness to an individual.

We do not use or disclose sensitive personal information other than to provide you our services as permitted by law. Abjayon does not sell or share sensitive personal information for the purpose of cross-context behavioural advertising.

We collect sensitive personal information based on one or more of the following legal grounds:

  • You have given explicit consent to the collection for one or more specified purposes;
  • Where the collection of sensitive personal information is manifestly made public by you; and/or
  • Where the collection is necessary for exercise or defence of legal claims.


  1. Retention
  2. We retain your personal information for only as long as necessary to provide you, our services. We retain your personal information in accordance with our Records Retention Policy.


    1. Children

    We do not knowingly collect or sell personal information from anyone under the age of 16. If you are under 16, please do not provide any personal information about yourself to us. If you believe that a child under 16 may have provided us personal information, please contact us at


    1. Your rights
    2. This section describes your rights and explains how to exercise them, subject to certain exceptions.

      Right to know

      You have the right to request that we disclose certain information to you about our collection, use and disclosure of your personal and sensitive information. This information includes:

      • Categories of personal information we have collected about you
      • Specific personal information we have collected about you
      • Where we received your personal information from
      • The business purpose for collecting or sharing your personal information

      Right to deletion

      You have the right to request that we delete personal information we collected about you, subject to any exceptions permitted by applicable law.

      Right to correction

      You have the right to request that we correct your inaccurate personal information.

      Right to opt out of sharing

      Abjayon does not share your personal information with third parties for cross-context behavioural advertising.

      Do not sell my personal information

      Abjayon does not sell personal information.

      Do not share or disclose my sensitive personal information

      You have the right to limit how your sensitive personal information is disclosed or shared with third parties, as per the law.

      Exercising your rights

      To exercise your rights as described above, please submit a request by sending an email to

      Upon receiving a request from you, we will first verify your identity by matching the information you provide (including your name, email address, and phone number) with what we have on file for you. We may ask you for additional information to verify your identity or to comply with your request.

      You may use an authorized agent to make a request on your behalf. To designate an agent, you will need to provide a written and signed document by both you and the agent that authorizes the agent to act on your behalf or demonstrate power of attorney. You may also use a power of attorney. We will still require you to provide sufficient information to allow us to reasonably verify your identity and we may deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf.

      Response timing and format

      We will respond to your request within 10 days of receipt and endeavour to respond to a verifiable consumer request within 45 days of receipt.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

      We will typically communicate with you in the same manner in which the request was received. Or, if you have an account with us, we may deliver our written response to that account.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.

      We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded and only as permitted by applicable law.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.


      1. Changes to our privacy policy
      2. We reserve the right to amend this policy at our discretion and at any time. Any changes will be effective when we post the revised policy. We encourage you to periodically review this page for the latest information on our privacy practices.


        1. How to contact us
        2. If you have any questions or comments about this policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights, please do not hesitate to contact us by e-mailing us at