Last Updated: July 25th, 2018
Thank you for using Jogg! Your privacy matters to Jogg, Inc. (the "Company", "we", or "us").
We hope this helps you to understand our privacy commitments to you. For information on how to contact us if you ever have any questions or concerns, please see the ‘How to Contact Us’ section at the end of this Policy. Or, if you do not agree with the content of this Policy, then please remember it is your choice whether you want to use our Service.
1. YOUR RIGHTS AND YOUR PREFERENCES
You may be aware that a new European Union law, called the General Data Protection Regulation or "GDPR" gives certain rights to individuals in relation to their personal data. Accordingly, we have implemented additional transparency and access controls to help you take advantage of those rights. As available and except as limited under applicable law, the rights afforded to individuals are:
- Right of Access: the right to be informed of and request access to the personal data we process about you;
- Right to Rectification: the right to request that we amend or update your personal data where it is inaccurate or incomplete;
- Right to Erasure: the right to request that we delete your personal data;
- Right to Restrict: the right to request that we temporarily or permanently stop processing all or some of your personal data;
- Right to Object: the right, at any time, to object to us processing your personal data on grounds relating to your particular situation, and the right to object to your personal data being processed for direct marketing purposes;
- Right to Data Portability: the right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service; and
- Right Not to be Subject to Automated Decision-Making: the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.
In order to enable you to exercise these rights with ease and to record your preferences in relation to how JOGG uses your personal data, we will enable you to control some of the categories of personal data we process about you, and will enable you to access your personal data. Also, JOGG will enable you to choose which communications you receive from JOGG, manage your publicly available personal data, and set your sharing preferences.
If we send you electronic marketing messages based on your consent or as otherwise permitted by applicable law, you may, at any time, respectively withdraw such consent or declare your objection (“opt-out”) at no cost. The electronic marketing messages you receive from JOGG (e.g. those sent via email) also will include an opt-out mechanism within the message itself (e.g. an unsubscribe link in the emails we send to you).
2. WHAT PERSONAL DATA DO WE COLLECT?
(a) Personal Data You Provide To Us
Personal Information: For you to create a basic Jogg account, we need to collect a few important details about you that could reasonably be used to identify you personally. We may collect or require e-mail address, age, profile photo and mobile number ("Personal Information"). We may also retain a record of any email interactions you have with JOGG.
You also may give us permission to access your information in other services. For example, you may link your Facebook or Twitter account to Jogg. The information we get from those services often depends on your settings or their privacy policies, so be sure to check what those are.
User Content: Video, text and other materials that you upload or post to the Service. When you send video Replies or create Joggs, we also collect, process and store the contents of those videos on our servers, as well as the date and time that those videos were created. The contents of those messages are also temporarily stored on the devices of recipients.
Contests, Surveys and Sweepstakes Data: This personal data is used to allow you to sign up and participate in these types of promotions. The exact personal data collected will vary depending on the promotion.
Marketing Data: This personal data is used to enable JOGG and our partners / service providers to send you marketing communications either: via email, whilst using the JOGG Service and/or direct from the applicable third party.
(b) Information We Collect As You Access And Use Our Services
Usage Information: We and our third-party service providers may use a variety of technologies that automatically (or passively) collect certain information whenever you visit or interact with the Services ("Usage Information"). We collect information about your activity on our Service and the video content you send and receive through our Service. For example, we collect information such as the time, date, sender, recipient of a response, the number of responses and to who, which users you interact with the most, and your interactions with messages and how it is formatted.
Log Information: We log information about your use of our websites and app, including your browser type and language, access times, pages viewed, your IP address, the website you visited before navigating to our websites and the URL that referred you to our Services.
Device Information: We collect other unique identifiers ("Device Identifier") for your computer, mobile or other device used to access the Service (any, a "Device"). A Device Identifier is a number that is automatically assigned to your Device used to access the Service, and our computers identify your Device by its Device Identifier. In addition, the Service may access your video storage applications, with your consent, to facilitate your use of certain features of the Service. You will always have the option to change your mind and withdraw your consent at any time. We may also collect information regarding the type of device you are using to access or connect to the Service, your device attributes, network connection type (e.g. WiFi, 3G, LTE, Bluetooth), provider, network and device performance, browser type, language, information enabling digital rights management, operating system and the version of the JOGG application.
Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect information, and this may include sending cookies to you. Cookies are small data files stored on your hard drive or in device memory that help us to improve our Service and your experience, see which areas and features of our Service are popular and count visits. We may also collect information using web beacons (also known as "tracking pixels").
We also use anonymised and aggregated information for purposes that include testing our IT systems, research, data analysis, creating marketing and promotion models, improving the Service, and developing new features and functionality within the Service.
(c) Information Third Parties Provide About You
3. HOW DO WE USE THE INFORMATION COLLECTED?
When you use or interact with the Service, we use a variety of technologies to process the personal data we collect about you for various reasons. We have set out in the table below the reasons why we process your personal data, the associated legal bases we rely upon to legally permit us to process your personal data, and the categories of personal data used for these purposes:
Description of why JOGG processes your personal data (‘processing purpose’)
Legal Basis for the processing purpose
Categories of personal data used by JOGG for the processing purpose
To provide, personalize, and improve your experience with our Service
To understand how you access and use our Service to ensure technical functionality of the Service, develop new products and services, and analyze your use of the Service including any JOGGs or Replies.
To communicate with you for Service-related purposes.
To prevent or detect misuse or fraud including fraudulent use of the Service.
To communicate with you, either directly or through one of our partners, for:
4. HOW DO WE SHARE INFORMATION?
We will not share, rent or sell your information to third parties outside Jogg, unless one of the following circumstances applies:
(a) To Third Parties Providing Services on Our Behalf.
We use third party companies and individuals to facilitate our Service, provide or perform certain aspects of the Services on our behalf - track the Services' analytics, engage in anti-fraud and security measures, provide support, provide geo-location information, perform technical services, or perform other administrative services. Our service providers will be given access to your information as is reasonably necessary to provide the Service under reasonable confidentiality terms.
(b) Legal Requests and Preventing Harm
We may share information about you in response to any legal process or enforceable governmental request for information if we believe disclosure is consistent with, or required by, any applicable law, rule, or regulation; to investigate or remedy potential violations of our user agreements or policies, or to protect the rights, property, security and safety of us, our users, our Services or others. Additionally, to protect the safety of the public for any reason and to detect, prevent or otherwise address fraud, security or technical issues. Moreover, we may do this to prevent or stop activity we may consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity. Such disclosures may be carried out without notice to you at our discretion, provided that we deem that such interest is not overridden by your interests or fundamental rights and freedoms requiring the protection of your personal data.
(c) Change of Control
We may share aggregated, non-personally identifiable information publicly with our partners – like publishers, advertisers or connected sites. For example, we may share information publicly to show trends about the general use of our Service. We may use sponsorship, marketing and advertising partners to show you more tailored content, or to help us understand your use of our Service, to provide you with a better service. We also may share personal data with certain marketing and advertising partners to send you promotional communications about JOGG. Depending on how you sign up for the Service (e.g. through a third party service or a mobile provider), we share your JOGG username or other registration information as necessary to enable your account.
(e) Film and Television Studios, Production Companies and Producers
You can ask us to share personal data (like your email address) with film or television studios we may be working with, or other partners who may want to directly send you news or promotional offers, but you can also revoke that consent at any time.
5. WHAT ABOUT INFORMATION I DISCLOSE PUBLICLY?
(a) User Generated Content and Public Information.
Any information or content that you voluntarily disclose or submit for posting to the Service, such as User Content, may become available to the public. Your User Content will be submitted immediately to the Jogg creator, but only made public on Jogg if your video response is “Bullseyed” (A creator deems your video response as worth publishing).
We or others may reproduce, publish, distribute or otherwise use User Content online or offline in any media or format (currently existing or hereafter developed). Others may have access to this User Content and may have the ability to share it with third parties across the Internet. You should be aware that any User Content you provide in these areas may be read, collected, and use by others who access them. Thus, please think carefully before deciding what information you share, including Personal Information, in connection with your User Content.
(b) Name and Likeness.
We may also publish your name, voice, likeness and other Personal Information that is part of your User Content, and we may use the content, or any portion of the content, for advertising, marketing, publicity and promotional activities.
If you remove information that you posted to the Service, it may remain viewable in cached and archived pages of the Service or on our servers as described above, or if other Users or third parties using Jogg have copied or saved that information.
6. HOW DO I CHANGE MY INFORMATION AND WHAT IF I CANCEL MY ACCOUNT?
If you are a registered user of our Service, we provide you with tools and account settings to access or modify the profile information you provided to us and associated with your account. You can also permanently delete your Jogg account if you choose to do so.
7. HOW IS MY PERSONAL DATA RETAINED AND HOW CAN I INSTRUCT YOU TO ANONYMISE MY PERSONAL DATA OR DELETE MY PERSONAL DATA?
We keep your personal data only as necessary to provide you with the JOGG Service and for legitimate and essential business purposes, such as maintaining the performance of the JOGG Service, making data-driven business decisions about new features and offerings, complying with our legal obligations, and resolving disputes. We keep some of your personal data for as long as you are a user of the JOGG Service. For example, we keep your uploaded video content and account information.
If you request, we will delete or anonymise your personal data so that it no longer identifies you, unless, we are legally allowed or required to maintain certain personal data, including situations such as the following:
- If there is an unresolved issue relating to your account, such an unresolved claim or dispute we will retain the necessary personal data until the issue is resolved;
- Where we are required to retain the personal data for our legal, tax, audit, and accounting obligations, we will retain the necessary personal data for the period required by applicable law; and/or,
- Where necessary for our legitimate business interests such as misuse of the Service, fraud prevention or to maintain the security of our users.
We cannot guarantee that deletion of any content always occurs within a particular timeframe. In addition, as for any other digital information, there may be ways to access messages while still in temporary storage on recipients’ devices or, forensically, even after they are deleted.
8. WHAT SHOULD PARENTS KNOW ABOUT CHILDREN?
We do not knowingly collect personal data from children under 13 years or under the applicable Age Limit. If you are under the Age Limit, please do not use the JOGG Service, and do not provide any personal data to us.
If we learn that we have collected the personal data of a child under the age of 13 years or the applicable Age Limit, we will take reasonable steps to delete the personal data. This may require us to delete the JOGG account for that child.
9. WHAT ABOUT SECURITY?
The Personal Information and Usage Information we collect is securely stored within our databases, and we use standard, industry-wide, commercially reasonable security practices such as encryption, firewalls, SSL (Secure Socket Layers) and security updates for protecting your information. However, as effective as encryption technology is, no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that information you supply won't be intercepted while being transmitted to us over the Internet or wireless communication, and any information you transmit to the Company you do at your own risk. Your password protects your user account, so we encourage you to use a unique and strong password, limit access to your computer and browser, and log out after having used the JOGG Service.
10. WHAT ABOUT CONSENT TO TRANSFER INFORMATION TO OTHER COUNTRIES?
JOGG may subcontract processing to, or share your personal data with, third parties located in countries other than your home country. Your personal data, therefore, may be subject to privacy laws that are different from those in your country of residence.
Personal data collected within the European Union and Switzerland may, for example, be transferred to and processed by third parties located in a country outside of the European Union and Switzerland. In such instances JOGG shall ensure that the transfer of your personal data is carried out in accordance with applicable privacy laws and, in particular, that appropriate contractual, technical, and organisational measures are in place such as the Standard Contractual Clauses approved by the EU Commission.
In Addition, your Personal Information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By using the Services or providing us with any information, you consent to the transfers described in this section, including the processing and storage of your information in countries other than your home country.
12. HOW DO I KNOW ABOUT POLICY CHANGES?
13. HOW TO CONTACT US
Attn: Data Protection Officer
1800 S Brand Boulevard
Glendale, CA 91204