This Policy describes how we collect, use, share, and secure the personal information that you provide. It also describes your choices regarding use, access, and correction of your personal information. To ensure you are fully informed of our practices, we recommend that you read the entire Policy. If you have any questions or concerns about our use of your personal information, then please contact us at firstname.lastname@example.org.
A. SCOPE OF THIS POLICY.
When this Policy applies. This Policy applies to our Websites that link to this Policy, the Services, Visitors, and those businesses or individuals who contract with us to use our Services (“Customers”) and, in certain circumstances, their Attendees.
When this Policy does not apply. This Policy does not apply to:
• Third-Party Apps and Services. Our Websites may contain links to other websites, or the Services may integrate or interoperate with third-party online services or applications. The information practices and the content of such other websites or third-party online services or applications are governed by the privacy statements of such other websites of third parties. We encourage you to review the privacy statements of any such other websites or third-party services or applications to understand their information practices.
• Customer Content. Except for information we collect in connection with your registration or authentication into our Services, this Policy does not apply to our security and privacy practices in connection with electronic data, text, messages, communications, or other materials submitted to and stored within the Services by you (“Customer Content”). Customer Content security and privacy practices are detailed in and governed by our Terms of Service and Data Processing Agreement, available here and here, respectively, or such other applicable agreement between you and us relating to your access to and your use of our Services (collectively referred to as the “Agreement”).
Customers to our Services are responsible for establishing policies for, and ensuring compliance with, all applicable laws and regulations, as well as any privacy policies, agreements, or other obligations, relating to the collection of personal data in connection with the use of our Services by individuals (also referred to as “data subjects”) with whom our Customers interact.
We collect information under the direction of our Customers, and we typically have no direct relationship with individuals whose personal data we process in connection with our Customers’ use of our Services. Our use of information collected through our Services will be limited to the purpose of providing the Services to our Customers. If you are an individual who interacts with a Customers using our Services (such as a customer or user of one of our Customers) and require assistance or would either like to amend your contact information or no longer wish to be contacted by one of our Customers that use our Services, please contact the Customers that you interact with directly.
B. INFORMATION THAT YOU PROVIDE TO US
Account and Registration Information. We ask for and may collect personal data about you such as your name, address, phone number, email address, instant messaging ID, and credit card information, as well as certain related information like your company name and website name, when you register for an account to access or utilize one or more of our Services (an “Account”). We also ask for and collect personal data such as an email address and a name or alias from any individual that you authorize to log into and utilize our Services in connection with your Account (a “User” as defined in the Agreement). We base the processing of your personal data on our legitimate interest, to provide you with the necessary functionality during your use of our Services.
If you sign-up for a free trial Account, you are not required to enter your credit card information unless and until you decide to continue with a paid subscription to our Services. A third-party intermediary is used to manage credit card processing. This intermediary is not permitted to store, retain, or use your billing information for any purpose except for credit card processing on our behalf.
We refer to any information described above as “Account Information” for the purposes of this Policy. By voluntarily providing us with Account Information, you represent that you are the owner of such personal data or otherwise have the requisite consent to provide it to us.
Other Submissions. We ask for and may collect personal data from you when you submit web forms on our Websites or as you use interactive features of the Websites, to include participation in webinars, surveys, contests, promotions, sweepstakes, requesting customer support, or otherwise communicating with us. We process your personal data to perform our contract with you for the use of our Websites and the Services and to fulfil our obligations under the Agreement to you; where we have not entered into the Agreement with you, we base the processing of your personal data on our legitimate interest to operate and administer our websites and to provide you with the content you access and request.
Attendee Information. We ask for and may collect personal data such as your name, address, phone number, job title and email address when you register for or attend an event to facilitate your registration or attendance at an event, including sending related communications to you.
C. INFORMATION THAT WE COLLECT FROM YOU ON OUR WEBSITES.
Logs. As is true with most websites and services delivered over the Internet, we gather certain information and store it in log files when you interact with our Websites and Services. This information includes internet protocol (IP) addresses as well as browser type, internet service provider, URLs of referring/exit pages, operating system, date/time stamp, information you search for, locale and language preferences, identification numbers associated with your devices, your mobile carrier, and system configuration information. Occasionally, we connect personal data to information gathered in our log files as necessary to improve our Websites and Services. In such a case, we would treat the combined information in accordance with this Policy.
D. INFORMATION COLLECTED FROM OTHER SOURCES
Information From Services Provided by Third Parties. We may also obtain other information, including personal data, from third parties and combine that with information we collect through our Websites. For example, we may have access to certain information from a third-party social media or authentication service if you log into our Services through such a service or otherwise provide us with access to information from the service. Any access that we may have to such information from a third-party social media or authentication service is in accordance with the authorization procedures determined by that service. If you authorize us to connect with a third-party service, we may access and store your name, email address(es), current city, profile picture URL, and any other personal data that the third party service makes available to us and use and disclose it in accordance with this Policy. You should check your privacy settings on these third-party services to understand and change the information sent to us through these services.
These single sign-on services will authenticate your identity, provide you with the option to share certain personal data (such as your name and email address) with us, and pre-populate our sign-up form. Services like Facebook Connect give you the option to post information about your activities in the Services to your profile page to share with others within your network.
E. HOW WE USE INFORMATION THAT WE COLLECT
General Uses. We may use the information we collect about you (including personal data, to the extent applicable) in order to perform our obligations under our Agreement with you and on the basis of our legitimate interest including to (a) provide, operate, maintain, improve, and promote the Websites and the Services; (b) enable you to access and use the Websites and the Services; (c) process and complete transactions, and send you related information, including purchase confirmations and invoices; (d) send transactional messages, including responses to your comments, questions, and requests; provide customer service and support; and send you technical notices, updates, security alerts, and support and administrative messages; (e) send promotional communications, such as providing you with information about products and services, features, surveys, newsletters, offers, promotions, contests, and events; and provide other news or information about us and our partners (you can opt-out of receiving marketing communications from us by contacting us at and providing the names/email address(es) that you would like removed from our marketing databases and added to our ‘Do Not Contact’ list or following the unsubscribe instructions included in our marketing communications); (f) process and deliver contest or sweepstakes entries and rewards; (g) monitor and analyze trends, usage, and activities in connection with the Websites and Services and for marketing or advertising purposes; (h) investigate and prevent fraudulent transactions, unauthorized access to the Websites and the Services, and other illegal activities; (i) personalize the Websites and Services, including by providing features or advertisements that match your interests and preferences; and (j) for other purposes for which we obtain your consent.
Legal basis for processing (UK/EEA visitors only). If you are a visitor from the United Kingdom (“UK”) / European Economic Area (“EEA”), our legal basis for collecting and using the personal data described above will depend on the personal data concerned and the specific context in which we collect it. However, we will normally collect personal data from you only where we need the personal data to perform a contract with you (e.g., to provide you with our Services), where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms, or where we have your consent. In certain cases, we may also have a legal obligation to collect personal data from you.
If we ask you to provide personal data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal data is mandatory or not (as well as of the possible consequences if you do not provide your personal data).
Similarly, if we collect and use your personal data in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time why we need to use your personal data. If we process personal data in reliance on your consent, you may withdraw your consent at any time.
If you have questions about, or need further information concerning, the legal basis on which we collect and use your personal data, please contact us using the contact details provided under the “Contact Us” section below.
F. SHARING OF INFORMATION COLLECTED
Third-Party Service Providers. We share information, including personal data, with our third-party service providers that we use to provide hosting for and maintenance of our Websites, application development, backup, storage, payment processing, analytics, and other services for us. These third-party service providers may have access to or process your personal data for the purpose of providing these services for us. We do not permit our third-party service providers to use the personal data that we share with them for their marketing purposes or for any other purpose than in connection with the services they provide to us.
We may also share aggregated and/or anonymized information regarding your use of the Services with third parties for marketing purposes based on our legitimate interest to develop and promote Services(s). However, we would never identify you, or your Users or Attendees as the source of the information.
We may collect, and we may engage third-party analytics providers to collect, metrics and information regarding your use of the Services, including evaluating how Users and Attendees use the Services (“Resultant Data”), to develop new features, improve existing features or inform sales and marketing strategies, based on our legitimate interest to improve the Services. When we process Resultant Data, any personal data shall be anonymized. Any such third-party analytics providers will not share or otherwise disclose Resultant Data, although we may make Resultant Data publicly available from time to time.
Compliance with Laws and Law Enforcement Requests; Protection of Our Rights. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may disclose personal data to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. We may also share such information if we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Agreement, or as otherwise required by law.
Testimonials. From time to time, we may post testimonials on the Websites that may contain personal data. We always obtain your consent to post your name along with your testimonial. If you wish to update or delete your testimonial, you can contact us at email@example.com.
Referrals. If you choose to use our referral service to tell a friend about our products and services, we will ask you for your friend’s name and email address. You must only provide your friend’s name and email address if you have a reasonable belief they will not object to us contacting them. If you do, we will send your friend an email inviting them to visit the Websites and will store this information for the purpose of sending this initial email, tracking the success of our referral program and other marketing activities. Your referral may contact us at firstname.lastname@example.org to request that we remove their information from our database.
Community Forums. The Websites may offer publicly accessible blogs, community forums, comments sections, discussion forums, or other interactive features (“Interactive Areas”). You should be aware that any information that you post in an Interactive Area might be read, collected, and used by others who access it. To request removal of your personal data from an Interactive Area, contact us at email@example.com. In some cases, we may not be able to remove your personal data, in which case we will let you know if we are unable to do so and why.
Affiliate Sharing. We may share information, including personal data, with our affiliates, and they will use that information only for the purposes already described in this Policy.
To Market our Services. We may share information, including personal data, with our partners, solely for the purpose of enabling our partners to notify you about our Services. We require our partners to provide an opt-out option within its communications to you. By opting out, you are opting out of receiving future communication from our partner.
With Your Consent. We may also share personal data with third parties when we have your consent to do so.
G. INTERNATIONAL TRANSFER OF PERSONAL DATA
We do not share your personal data with third parties, unless it is necessary to carry out your request, for our professional or legitimate business needs, or as required or permitted by law. Where we do transfer your personal data to third parties or service providers, appropriate arrangements will be made to ensure correct and secure data processing in compliance with applicable data protection law.
We store personal data about Visitors, Customers, and Attendees within the UK and EEA, the United States, and in other countries and territories. To facilitate our global operations, we may transfer and access such personal data from around the world, including from other countries in which our affiliates have operations. Therefore, your personal data may be processed outside of the EEA and in countries which are not subject to an adequacy decision by the UK Government or the European Commission, and which may not provide for the same level of data protection as the UK and EEA.
In this event, we will ensure that the recipient of your personal data offers an adequate level of protection, for instance by entering into standard contractual clauses for the transfer of data as approved by the UK Government or European Commission (Art. 46 GDPR), or we will ask you for your prior consent to such international data transfers.
We have implemented safeguards to ensure an adequate level of data protection where your personal data is transferred to countries outside the UK and EEA, such as:
(a) the recipient country has an adequacy decision from the UK Government or European Commission; or
(b) the UK/European Commission’s Standard Contractual Clauses for the transfer of personal data.
You can obtain more details of the protection given to your personal data when it is transferred outside Europe (including a sample copy of the model contractual clauses) by contacting us using the details set out below.
H. OTHER IMPORTANT PRIVACY INFORMATION
Notice to Users. Our Services are intended for use by enterprises. Where our Services are made available to you through a Customer of ours, that enterprise is the data controller of your personal data. Your data privacy questions and requests should initially be submitted to the Customer in its capacity as your data controller. We are not responsible for our Customers’ privacy or security practices which may be different than this Policy. Our Customers are able to:
• restrict, suspend, or terminate your access to the Services;
• access and describe your personal data that you provided to them;
• access and export your personal data processed by them; and
• amend your personal data, including your end-user profile.
Data retention. Where we are the data controller of personal data (for example, personal data relating to Visitors, Attendees, and individuals who register to use our Services), then we retain the personal data we collect where we have an ongoing legitimate business need to do so (for example, to provide you with our Services, to enable your participation in an event, and to comply with applicable legal, tax or accounting requirements).
When we have no ongoing legitimate business need to process your personal data, we will either delete or aggregate it or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible.
If your personal data is processed within Customer Content, we will process the personal data for as long as we are instructed to do so by the relevant Customer that is the data controller of the Customer Content.
Security. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
The transmission of information via the internet is not completely secure. Although we will take reasonable measures to protect your personal data, Jugo cannot guarantee the security of your information transmitted and any transmission is at your own risk.
H. HOW TO EXERCISE YOUR DATA PROTECTION RIGHTS
You have certain choices available to you when it comes to your personal data. Below is a summary of those choices, how to exercise them and any limitations.
Correcting, updating, and removing your information. An individual who seeks to exercise their data protection rights in respect of personal data stored or processed by us on behalf of a Customer of ours within the Customer Content (including to seek access to, or to correct, amend, delete, port, or restrict processing of such personal data) should direct his/her query to our Customer (the data controller). Upon receipt of a request from one of our Customers for us to remove the personal data, we will respond to their request within thirty (30) days. We will retain personal data that we process and store on behalf of our Customers for as long as needed to provide the Services to our Customers.
Accessing and updating or deleting your information. Our Services give Customers and Users the ability to access, update, and delete certain personal data from within the Services. For example, you can access your Account and make updates to your personal data. In cases where we act as the data controller of your personal data, we will provide you with information about whether we hold any of your personal data upon request. We will respond to such requests within a reasonable timeframe. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations.
Deactivating your user profile. If you no longer wish to use our Services, our Customers may be able to deactivate your Account. First, please contact the applicable Customer with your request. If you are a Customer and are unable to deactivate an Account through your administrator settings, please contact us for support. Please be aware that deactivating your Account does not delete your information; your information may remain visible to other Users based on your past participation within the Services. For more information on how to delete your information, please contact us at firstname.lastname@example.org.
Request that we stop using your information. You may request that your personal data no longer be accessed, stored, used, and otherwise processed where you believe that a Customer or we do not have the appropriate rights to do so. For example, if you believe an Account was created for you without your permission or you are no longer an active User, you can request that we delete your Account as provided in this Policy. Where you gave us consent to use your personal data for a limited purpose, you can contact us to withdraw that consent. You can also opt-out of our use of your personal data for marketing purposes by contacting us, as provided below. When you make such requests, we may need time to investigate and facilitate your request. Please note that a User affiliated with a Customer should first contact that Customer with a request to stop access, storage or use of personal data. If there is delay or dispute as to whether we have the right to continue using your personal data, we will restrict any further use of your personal data until the request is honored or the dispute is resolved, provided our Customer does not object (where applicable).
Opt-out of communications. We offer those who provide personal contact information a means to choose how we use the information provided. You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of our marketing emails or you may send a request to email@example.com. You may opt-out of receiving promotional communications from us by using this unsubscribe link within each email. Even after you opt-out from receiving promotional messages from us, you will continue to receive transactional messages from us regarding our Services.
Other data protection rights. If you wish to exercise any other data protection rights that are available to you under your local data protection laws (such as the right to data portability or to data restriction) then please send your request to firstname.lastname@example.org and we will respond to your request in accordance with applicable data protection laws.
You will not have to pay a fee to access your personal data or to exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information or to exercise any of your other rights. This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
If you wish to exercise any of the rights set out above, please contact us.
You have the right to complain to your local data protection authority if you are unhappy with our data protection practices.
I. CHILDREN’S PERSONAL DATA
We do not knowingly collect any personal data from children under the age of 16. If you are under the age of 16, please do not submit any personal data through our Websites or Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide personal data through the Websites or Services without their permission. If you have reason to believe that a child under the age of 16 has provided personal data to us through the Websites or Services, please contact us at email@example.com, and we will use commercially reasonable efforts to delete that information.
J. BUSINESS TRANSACTIONS
We may assign or transfer this Policy, as well as your account and related information and data, including any personal data, to any person or entity that acquires all or substantially all of our business, stock or assets, or with whom we merge. If we do, we will inform them of the requirement to manage your personal data in accordance with this Policy.
K. SUPPLEMENTAL TERMS AND CONDITIONS FOR CERTAIN REGIONS
Australia. Personal data collected, stored, used and/or processed by us, as described in this Policy, is collected, stored, used and/or processed in accordance with the Australian Privacy Act 1988 (Commonwealth). Specifically, the Privacy Act establishes the Australian Privacy Principles (APPs) (effective from 12 March 2014) that sets out these key obligations, to include:
• APP 5 (notification of collecting personal information) requires entities to ensure that at before, at the time of, or as soon as practicable after, an entity collects personal information from an individual the entity must take such steps as are reasonable in the circumstances to notify the individual of the collection of the personal information.
• APP 7 (direct marketing) restricts the use or disclosure of personal information for direct marketing unless an exception applies; and
• APP 8 (cross-border disclosure of personal information) requires that before an entity discloses personal information about an individual to a person or entity overseas, the entity must take reasonable steps to ensure that the overseas recipient does not breach the Australian Privacy Principles.
Personal Information is defined as any information or an opinion about an identified individual, or an individual who is reasonably identifiable:
• whether the information or opinion is true or not; and
• whether the information or opinion is recorded in a material form or not.
This information can include Customer’s name and contact information including postal address, email address and telephone number, billing information, credit or debit card information, and transaction information for any products that may have been purchased.
We adhere to the Australian Privacy Principles for all personal information that we collect from our Customers (i.e., the companies that utilize and pay for our Services) and from any other individuals that we may receive or collect personal information from. In particular:
• We only collect personal information of the individuals who have registered or signed up for our Services (such as credit card information). Where we collect unsolicited information, we deal with this according to the APPs and this Policy;
• We only use personal information for the purposes set out in this Policy and we only disclose such personal information to third-party vendors to whom Customers link from our Services; and
• Where it is reasonably practicable, we will give our Customers access to their personal information, delete the personal information if requested, and retain it only as necessary to provide our Services to our Customers.
If you are dissatisfied with our handling of a complaint or do not agree with the resolution proposed by us, you may make a complaint to the Office of the Australian Information Commissioner (“OAIC”) by contacting the OAIC using the methods listed on their website at http://www.oaic.gov.au. Alternatively, you may request that we pass on the details of your complaint to the OAIC directly.
Brazil. Personal data collected, stored, used and/or processed by us, as described in this Policy, is collected, stored, used and/or processed in accordance with Brazilian Law No. 13,709/2018, as amended (LGPD). Those individuals who use or access our Website or Services expressly consent to the collection, use, storage, and processing of their personal data by us for the purposes described in this Policy.
Canada. Personal data (as the term is defined in the Personal Data Protection and Electronic Documents Act of Canada (“PIPEDA”) will be collected, stored, used and/or processed by us in accordance with our obligations under PIPEDA.
Japan. Personal data collected, stored, used and/or processed by us, as described in this Policy, is collected, stored, used and/or processed in accordance with Japan’s Act on the Protection of Personal Data.
New Zealand. Personal data collected, stored, used and/or processed by us, as described in this Policy, is collected, stored, used and/or processed in accordance with New Zealand’s Privacy Act 2020 and its 13 Information Privacy Principles (“NZ IPPs”). Specifically, New Zealand law lays out 12 information privacy principles (NZ IPPs) for the proper handling of personal information of Kiwi citizens, and these principles can be found at http://privacy.org.nz/information-privacy-principles. The Act and 12 IPPs presume that trans-border data flows are permissible provided the IPPs are preserved. As is the case with Australian privacy laws, Jugo acts as the processor, not collector of the data, of its New Zealand’s Customers’ customers. In addition, our handling of personal information under this Policy is perfectly aligned with the 12 NZ IPPs, including those directing that personal information be collected for lawful purposes (e.g., for processing customer service issues), that data should be collected directly from individuals (e.g., Users using the Services), that notice of collection of data and purpose of the data collection is provided, that data be collected in a legal manner, or that individuals have right to access and correct their data.
If you wish to make a complaint about the way we have handled your personal information (including if you think we have breached any applicable privacy laws), you may do so to our Privacy Officer in writing, by mail or email to the address or email address set out in the ‘Contact Us’ section of this Policy. Please include your full name, contact details and a detailed description of your complaint. Our Privacy Officer will acknowledge your complaint and respond to you regarding your complaint within a reasonable period. If you consider that we have failed to resolve the complaint satisfactorily, we will provide you with information about the further steps you can take.
United Kingdom. Personal data collected, stored, used and/or processed by Jugo, as described in this Policy, is collected, stored, used and/or processed in accordance with our obligations under the UK Data Protection Act 2018.
Jugo is a “service provider” under the CCPA. When we act as a service provider (for example, by providing our Services to another company that you interact with), we follow the instructions of the business that engaged us with respect to how we process your personal data. If you would like more information about how your personal data is processed by other companies, including companies that engage us as a service provider, please contact those companies directly.
Information We May Collect:
We may collect the following categories of information:
• Demographic Information
• Commercial Information
• Internet or other electronic network activity information
• Geolocation data
• Audio, electronic, visual, or similar information
• Professional or employment-related information
For each category of information, we collect the information from a variety of sources, including directly from you, from your devices, from your social media profiles, and/or from third-party providers. We collect the information to provide you with Services, protect our Customers and ourselves (including the Services), and to improve the Services. We do not share personal data with “third parties” as the term is defined under the CCPA.
We do not sell personal data of any individual, including personal data of minors under 16 years of age. We have not disclosed any personal data for a business purpose in the 12 months prior to this Policy’s last update, nor have we disclosed any personal data for valuable consideration. We may disclose personal data in the following categories for a business purpose going forward:
• Demographic Information
• Commercial Information
• Internet or other electronic network activity information
• Geolocation data
• Audio, electronic, visual, or similar information
• Professional or employment-related information
• Inferences drawn from any of the above information.
You may have certain rights with respect to your personal data, including:
• The right to access, including the right to know the categories and specific pieces of personal data we collect;
• The right to deletion of your personal data, subject to certain limitations under applicable law;
• The right to request disclosure of information collected;
• The right to disclosure of information disclosed for valuable consideration; and
• The right not to be discriminated against for exercising certain rights under California law.
To exercise these rights, please submit a request by emailing firstname.lastname@example.org. Please be as specific as possible in relation to the personal data you wish to access. Once we receive your request, we will review it, determine whether we must forward your request to one of our Customers, or, if applicable, if we can verify your identity, and process the request accordingly. If we need additional information to verify your identity, we will let you know. We will respond to your request within 45 days of receipt or notify you if we require additional time.
If you would prefer, you may designate an authorized agent to make a request on your behalf.
K. CHANGES TO THIS POLICY
This Policy may be updated from time to time to reflect changing legal, regulatory, or operational requirements. We encourage you to periodically review this page for the latest information on our privacy practices.
If there are any material changes to this Policy, you will be notified by our posting of a prominent notice on the Websites prior to the change becoming effective.
If you do not accept any changes made to this Policy, please discontinue use of the Websites and the Services.
This Policy was last updated on 25 Sept 2023.
L. CONTACT US
If you have questions or complaints regarding this Policy or about our privacy practices, please contact us by email at email@example.com or at:
Queen Square House, 18-21 Queen Square, Bristol, England, BS1 4NH
Attn: Data Privacy Officer