This document was last updated May 23, 2018.
In this document “GetJenny” refers to Sosho Oy which is a Finnish limited company (company ID 2562711-7).
By “Product” and “Service” we mean the Jenny chatbot solution, all of its separate applications and services related to offering the solution.
The purposes of processing your personal data are the following (one or more purposes may apply simultaneously):
The content of GetJenny’s personal data file may include the following types of data and changes made to these data types:
Basic information of all data subjects:
In addition to the above specified basic information, GetJenny may process the following subcategories of personal data of you.
Information of data subjects who have made purchases, given feedback and/or made complaints related to GetJenny’s products or services
Information of data subjects participating in GetJenny’s events
We collect personal data about you before, during, and after our customer relationship (or other comparable relationship) with you. For example, but not limited to, we collect data when you:
Your personal data and its updates are also obtained from authorities and companies offering personal data updating services, public directories and other public sources of information (such as but not limited to, news, company websites, and social media services). In addition, we may receive your personal data from our selected partner in case of a promotional campaign or commercial collaboration.
Cookies and tracking
As a general rule GetJenny never sells or leases your personal data to third parties.
GetJenny may share your personal data based on a valid order from a court or other official body with sufficient legal authority, or based on your personal request (after confirming identity)
GetJenny may share your personal data as part of any merger, acquisition, a sale of company assets or transition of service to another provider. This also applies in the unlikely event of an insolvency, bankruptcy or receivership in which your personal data would be transferred to another entity as a result of such a proceeding.
GetJenny’s services are provided using resources and servers located in various countries around the world. Our Service and related servers and data are hosted on Amazon Web Services and Microsoft Azure within the EU. Additionally, GetJenny uses services which can transfer data outside the EU/EEA.
Therefore, GetJenny may transfer your personal data outside the country where you use our services, including to countries outside the EU and EEA such as the United States. GetJenny requires all third parties to comply with the GDPR or to have executed Standard Contractual Clauses (as approved by the European Commission) that provide legal grounds for assuring that, when processed in the United States, the personal data of EU citizens that are processed by such a third party Service will receive from the Supplier and its service providers located outside the EU an adequate level of protection within the meaning of Article 46 of Regulation (EU) 2016/679 (General Data Protection Regulation).
GetJenny has established electronic and administrative safeguards designed to make the information collected securely. Manually processed documents containing your personal data are protected against unauthorized access.
Only appointed personnel of GetJenny and of approved organizations operating by GetJenny’s assignment or on behalf of GetJenny are entitled to use the personal data file application. All persons processing the application have a personal right of use based on the data a person needs according to his/her job description. All systems are protected with a firewall which protects it from contacts outside of GetJenny and data is encrypted.
All personnel of GetJenny and its subcontractors are obliged to keep the information of the personal data which they obtain in their work confidential.
GetJenny may process your personal data for as long as the customer relationship or other comparable relationship between you and GetJenny exists, as well as for a reasonable time thereafter. GetJenny may store and process your personal data for tax and/or other legal purposes as long as necessary.
In case you have opted-in to our marketing content (such as our newsletter), we will store and process your information as long as you remain as a subscriber and as well as for a reasonable time thereafter.
You have a right of access to the data concerning you in GetJenny’s personal data files. The request for right of access shall be made in writing to email@example.com. The request for the right of access must be signed. The request for right of access can also be presented at the main office of GetJenny with verification of identity.
You have the right to prohibit GetJenny from processing your personal data for purposes of direct advertising, distance selling, other direct marketing and market research and opinion polls and the right to demand correction or removal of an erroneous data by contacting the controller’s contact person.
You have the right to request, GetJenny to restrict processing of certain personal data and to object to the processing of certain data if such data are processed for other purposes than purposes necessary for the performance of our services or for compliance with a legal obligation. You may also object any further processing of personal data after prior given consent. These requests may, however, lead to fewer possibilities to use our products and services.
In addition, you have the right to receive personal data provided by you to GetJenny in a structured, commonly used format.
The processing of this personal data file is governed by the laws of Finland.
In case you suspect a breach of data protection legislation and the matter is not solved amicably between you and GetJenny in negotiations, you may lodge a complaint with the local supervisory authority for data protection.