JAKAMO PRIVACY POLICY. PLEASE READ CAREFULLY BEFORE REGISTRATION.
May 25, 2018
1 PURPOSE
Jakamo Limited (“Jakamo” or “we”) respects your privacy and complies with applicable personal data protection regulations. We have published this Privacy Policy to explain how we collect, use or otherwise Process Jakamo Service users’ or other Data Subjects’ (“you”) Personal Data and why we do it.
By using the Service or any part of it you give your full consent to the Processing of your Personal Data and accept this Privacy Policy. If you do not want to give your consent or do not accept this Privacy Policy or any part of it, please, do not register or use the Service, not even on behalf of a Company.
The use of the Service is governed by the service agreement made between the Company and Jakamo. This Privacy Policy forms a part of the service agreement. Jakamo Service Terms are available on the website www.jakamo.net or within the Service.
2 SCOPE OF APPLICATION
In relation to the Service, we may Process your Personal Data as the Controller or as the Processor in terms of the personal data protection regulations. If we determinethe purposes and means of the Processing, we act as the Controller and this Privacy Policy applies. In turn, when we Process your Personal Data on behalf of the Company to, for example, provide and protect the Service, we act as the Processor and the Company acts as the Controller. In the latter case, the Processing of your Personal Data is governed by the privacy policies or similar documentation of the Companies.
This Privacy Policy is also applicable if we Process your Personal Data in other than above mentioned situations in a way that we determine the purposes and means of the Processing.This Privacy Policy covers our Personal Data registers regarding customer relationship management, for example. For more information, please, visit our Trust Center.
3 DEFINITIONS
For the purposes of this Privacy Policy:
Company means a legal or natural person that has a valid company account in the Jakamo Service.
Controller means (i) the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the Processing of Personal Data; (ii) or any other controller referred to in personal data protection regulations.
Cookie means jointly cookies, web beacons, clear gifs and similar technologies.
Jakamo Service or Service means the online platform of Jakamo Limited, including but not limited to the service, sites, user interface, system, servers, hardware, applications, programs, clients, code and software.
Personal Data means information relating to an identified or identifiable natural person (“Data Subject”). Your name and home address are, for example, pieces of Personal Data.
Processing means (i) any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, transfer, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction; or (ii) any other processing of Personal Data referred to in personal data protection regulations.
Processor means a natural or legal person, public authority, agency or other body which Processes Personal Data on behalf of the Controller.
Trust Center means the site of Jakamo that contains information on security, privacy, transparency and compliance relating to the Jakamo Service and to the Processing of Personal Data by Jakamo.
4 COLLECTION OF PERSONAL DATA
We collect your Personal Data mainly from you. The collection of Personal Data in relation to the Service is described below and additional information may be available in the Trust Center. In relation to other Processing, we provide information on the collection of Personal Data in the Trust Center.
You use the Service on behalf of a Company. The user profile is created and you are connected to the Company you are employed in during the registration process. You will be granted company administrator status, if you are a company administrator according to the Jakamo Service Terms, and your status will be stored.
As registering into the Service you have to provide at least the following Information (“Compulsory Information”):
your name,
your email address and phone number,
password and
your department in the Company.
You may also provide the following information:
– your photograph,
your position and job description in the Company,
– language, currency, region and time zone.
You may update the above mentioned information within the Service. It is very important to keep your contact details updated, and not to use disposable, short-term or similar temporary email address or other similar temporary contact details. We may verify all collected information during the registration or from time to time after that. We may, for example, verify your email address during the registration before you can use the Service.
The provision of the Compulsory Information is necessary. Without the Compulsory Information, we cannot provide the Service for you and, in case you are the company administrator, for the Company.
You may also provide and we may collect Personal Data when you use the Service or otherwise interact with us. We automatically collect information from or through the Service and from your device by using Cookies. This kind of automatically collected information may include, for example, internet protocol (IP) address or other device address, devise type, the type of operating system, browser and application used, network identifiers, location, log information, access times, sites visited, features used and the content added or viewed and other information needed for customer service, communication, billing and other customer relationship management, provision and protection of the Service, product and service development, inquiries and research activities or compliance with our legal obligations, dispute resolution and enforcement of our agreements. We also store your consents, preferences, language and other settings, communication, feedback and other interactions with us. We may record your communication with us. We also may collect information regarding your interaction with emails, such as whether you open or forward a message.
In addition, we may collect the Personal Data from other reliable sources. If we have created a link between the Service and the data system of the Company, then we may collect your Personal Data from the Company.In the future, we may integrate the Service with social media services or other services and collect Personal Data from such integrated services. We may provide information on integrated services in the Trust Center.
5 PROCESSING OF PERSONAL DATA
The purposes of the Processing are:
– customer service;
– communication, billing and other customer relationship management;
– direct marketing;
– product and service development;
– inquiries and research activities;
– compliance with our legal obligations, dispute resolution and enforcement of our agreements.
The legal basis for the Processing is your consent. Where your consent is not applicable, we may Process your Personal Data, if the Processing is necessary for compliance with a legal obligation of Jakamo or for the purposes of legitimate interests pursued by Jakamo or by a third party. In general, these legitimate interests include, for example, communication with you, billing, service development, compliance with the service agreement or other activities necessary for to fulfill the purposes of the Processing. We may provide information on the legal basis for the Processing in the Trust Center. If Personal Data is anonymized so it is no longer associated with an identified or identifiable natural person, it is not Personal Data any longer and we may Process it freely.
We do not sell any Personal Data to third parties. We do not even disclose Personal Data to third parties excluding the exceptions mentioned in this Privacy Policy.
We may use subcontractors. In relation to the Service, the servers, backups or other parts of the Service may be operated by our subcontractors. Our subcontractors may, if needed, Process the Personal Data on our behalf acting as the Processors. We require that our subcontractors act in accordance with this Privacy Policy. We are responsible for the performance of our subcontractors as for our own performance in accordance with the Jakamo Service Terms. We will provide up-to-date information on outsourced Processing in the Trust Center, and appropriate measures required by the European Union General Data Protection Regulation (2016/679) are conducted, for example, to ensure the security of the Personal Data.
We may be obliged to disclose Personal Data to authorities subject to the applicable regulations. We may disclose Personal Data to prospective purchaser in a case of reorganization, acquisition, merger or other similar transaction. We may also Process Personal Data to defend our legitimate interests, for example, in legal proceedings.
Jakamo’s servers containing Personal Data are located and database is retained within the European Union at the moment. We may transfer and otherwise Process your Personal Data within the European Union or the European Economic Area. If we transfer your Personal Data outside the European Union or the European Economic Area in the future, we will ensure that there is legal basis for such transfer and, if needed, inform you of the appropriate safeguards.
Up-to-date information on the current location of the Processing and subcontractors is available in the Trust Center.
6 DURATION OF PROCESSING
In relation to the Service, we may retain the Personal Data at least as long as your user profile is valid. You or the company administrator may close your user profile at any time in accordance with the service agreement. Your user profile is also closed, if the Company to which your user profile is connected closes the company account. If your user profile is closed irrespective of the cause, the Personal Data is retained as long as it is connected to an active company account. However, we delete the Personal Data, if the purpose of the Processing of the Personal Data is not valid anymore or otherwise required by law. We may provide information on Personal Data retention in the Trust Center.
In relation to other Processing, we provide information on Personal Data retention in the Trust Center.
Some Personal Data may be retained in backups even after the primary information is deleted. The backup data of Jakamo Service will be stored for 30 days and deleted in accordance with our standard practices. The backups of our subcontractors acting as the Processors are deleted in accordance with subcontractors’ standard practices. We may provide information on backup practices in the Trust Center.
We may retain any information for the period of time needed for us to pursue legitimate business interests, conduct audits, comply with legal obligations, resolve disputes and enforce our agreements, unless regulated otherwise by law.
7 COOKIES
The Service operates online and may use Cookies. Cookies enable the collection of certain information automatically from your computer and system. This automatically collected information is described above in the section 4.
We use Cookies to offer your smoother and better user experience, for example, uninterrupted navigation, and for service development purposes. The use of Cookies targets to your benefit, because we can analyze the use of the Service and develop the Service accordingly. We may also use Cookies for personalization and marketing. The Service may also include elements that set Cookies on behalf of a third party.
We ask your general consent to the use of the Cookies by asking you to accept this Privacy Policy. If your browser settings accept Cookies, we consider also this as your consent to the use of Cookies. You may, at any time, limit or disable the use of Cookies by changing settings of your browser, but this can result malfunction of the Service.
The expiration times of Cookies vary depending on the type of the Cookie. Some Cookies expire when you close the browser and other may expire after couple of months or years. You may delete the Cookies from the settings of your browser.
More information about Cookies is available in the Trust Center.
8 SECURITY OF PROCESSING
The security of all information added to the Service is of utmost importance to Jakamo. Jakamo follows generally accepted industry standards to protect the Personal Data. Appropriate technical and other measures are being utilized in order to guarantee the secure use of the Service and Processing of Personal Data and to minimize possible risks. Jakamo will review the security standards and measures from time to time in order to keep them up to date.
The Jakamo Service is protected with password. The information in transactions is encrypted. Every user must register. The users are being identified by personal passwords which are not to be shared with anyone else. We limit access to our databases to authorized persons having justified need to access the information. The servers and backup files are in premises that are locked and have passage control.
More information about security is available in the Trust Center.
9 YOUR RIGHTS
9.1 Right to object to Processing of Personal Data
Where Personal Data are Processed for direct marketing purposes, you have the right to object at any time to Processing of Personal Data concerning you for such marketing. Where you object to Processing for direct marketing purposes, we shall no longer Process the Personal Data concerning you for such purposes.
Where Personal Data are Processed for the purposes of legitimate interests pursued by Jakamo or by a third party, you have the right to object, on grounds relating to your particular situation, at any time to Processing of Personal Data concerning you for such purpose. Where you object to Processing for such purposes, we shall no longer Process the Personal Data concerning you unless we demonstrate compelling legitimate grounds for the Processing which override the interests, rights and freedoms of you or for the establishment, exercise or defence of legal claims.
9.2 Other rights regarding the Personal Data
You have right to
– obtain from us confirmation as to whether or not Personal Data concerning you are being Processed, and, where that is the case, access to the Personal Data. At your request, we provide you a copy of your Personal Data undergoing Processing. For any further copies requested by you, we may charge a reasonable fee based on administrative costs. Where you make the request by electronic means, and unless otherwise requested by you, the information shall be provided in a commonly used electronic form. However, the right to obtain a copy shall not adversely affect the rights and freedoms of others.
– obtain from us without undue delay the rectification of inaccurate Personal Data concerning you. Taking into account the purposes of the Processing, you have the right to have incomplete Personal Data completed, including by means of providing a supplementary statement.
– obtain from us the erasure of Personal Data concerning you without undue delay where one of the following grounds applies: (a) the Personal Data are no longer necessary in relation to the purposes for which they were collected or otherwise Processed; (b) you withdraw consent on which the Processing is based, and where there is no other legal ground for the Processing; (c) you object to the Processing pursuant to Article 21(1) of the European Union General Data Protection Regulation (2016/679) and there are no overriding legitimate grounds for the Processing, or you object to the Processing for direct marketing purposes; (d) the Personal Data have been unlawfully Processed; (e) the Personal Data have to be erased for compliance with a legal obligation in European Union or European Union Member State law to which we are subject; (f) the Personal Data have been collected in relation to the offer of Service to a child. However, the right to erasure will not apply to the extent stated in the article 17(3) of the European Union General Data Protection Regulation (2016/679).
– obtain from us restriction of Processing where one of the following applies: (a) the accuracy of the Personal Data is contested by you, for a period enabling us to verify the accuracy of the Personal Data; (b) the Processing is unlawful and you oppose the erasure of the Personal Data and request the restriction of their use instead; (c) we no longer need the Personal Data for the purposes of the Processing, but they are required by you for the establishment, exercise or defence of legal claims; (d) you have objected to Processing pursuant to Article 21(1) of the European Union General Data Protection Regulation (2016/679) pending the verification whether the legitimate grounds of the Controller override those of the Data Subject.
– receive the Personal Data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another Controller. However, the right to data portability shall not adversely affect the rights and freedoms of others.
– withdraw your consent to Processing at any time by a written notice or within the Service. If you withdraw your consent, provision of the Service may be restricted or suspended.
– make a complaint with a supervisory authority, in particular in the European Union Member State of your habitual residence, place of work or place of the alleged infringement.
10 MISCELLANEOUS
10.1 Additional privacy information
We may give you descriptions, records or additional privacy notices regarding a specific part of the Service or a specific Personal Data register. If there is a difference between such descriptions, records or notices and this Privacy Policy, the descriptions, records or notices will be considered first.
We may provide information on privacy in the Trust Center. We will not usually send any email or other message regarding the updates of information in the Trust Center. We keep the information in the Trust Center up to date, and you are advised to visit the Trust Center on regular basis.
10.2 Notices
A notice by us to you shall be deemed duly served when the notice is (i) delivered to Service (including the Trust Center) and you have observed it; (ii) sent by email to the email address associated with your user profile or to other the email address you have given to us; or (iii) delivered otherwise in writing to you.
10.3 Age limitations
Jakamo Service is an advanced information sharing platform for businesses. We do not allow use of the Service by minors. If you learn that a minor has provided us with Personal Data, please inform us. We will take steps to delete such Personal Data.
10.4 Amendments and assignment
We reserve right to amend this Privacy Policy and assign our rights in accordance with the Jakamo Service Terms. If we intend to further Process the Personal Data for a purpose other than that for which the Personal Data were collected according to this Privacy Policy, we provide you prior to that further Processing with information on that other purpose and with any information required by law.
In case of reorganization, acquisition, merger or other similar transaction, we reserve right to assign control to the Personal Data to our subsidiaries, affiliates or to a third party. We conduct all measures related to the Personal Data in compliance with the European Union General Data Protection Regulation (2016/679).
You will be informed of amendments or assignments in accordance with the Jakamo Service Terms.
10.5 Governing laws
The governing laws and dispute resolution are determined by the Jakamo Service Terms.
Your Personal Data shall be Processed in accordance with the European Union General Data Protection Regulation (2016/679) as well as other applicable and mandatory personal data protection laws.
10.6 Contact information
We have tried to give you all relevant information in a way that the amount is sufficient and the wording is easy to understand. However, if you have any question regarding privacy, please contact us.
Our contact information valid on the date of this Privacy Policy:
Jakamo Limited
Business ID: 2475188-8
Address: Keskuskatu 10 C 18, 60100 Seinäjoki, FINLAND
Email: legal@thejakamo.com
Website: www.jakamo.net
You can find our valid contact information on the website www.jakamo.net.