GetJenny Privacy Policy

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This document was last updated January 17, 2020.

 

Table of Contents

  1. General
  2. What does this Privacy Policy cover?
  3. Why do we process personal data?
  4. What types of data we gather?
  5. Where do we gather your personal data from?
  6. Is your data shared with others?
  7. Is your data transferred to countries outside the European Union or the European Economic Area?
  8. How do we protect your personal data?
  9. How long do we process your Personal data?
  10. Your rights
  11. Cookies and tracking
    1. What types of cookies do we use?
    2. How can I allow, control and disable cookies?
  1. Choice of law and the right to lodge a complaint
  2. Changes to this Privacy Policy

 

 

1.       General

This Privacy Policy describes how GetJenny Oy (“GetJenny” or “we”) processes personal data; what types of personal data GetJenny gathers, for which purposes the personal data is used and to which parties the personal data can be disclosed.  

Personal data refers to data which allows the identification of an individual person (as defined and in compliance with the European Union’s General Data Protection Regulation 2016/679 “GDPR”). GetJenny complies with the GDPR and other applicable data protection legislation in all processing of all personal data.

By “product” and “service” we mean the Jenny chatbot solution, all of its separate applications and services related to offering the solution.

Contact Information:

Controller:       GetJenny Oy (Business ID 2562711-7)

Address:          Urho Kekkosen katu 4-6, 00100 Helsinki

Email:  privacy@getjenny.com

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2. What does this Privacy Policy cover?

This Privacy Policy covers GetJenny’s practices regarding the information GetJenny collects about its customers and users. Use of GetJenny’s products and services, visits to GetJenny’s website and applications, and communication with our personnel are subject to this Privacy Policy.

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3. Why do we process personal data?

We may process personal data for the following purposes:

  • Managing and analyzing the customer relationship.

GetJenny may use your personal data for managing, pursuing, analyzing and improving the customer relationship with you.

  • Providing products and services.

GetJenny may use your personal data for providing products and services for you, for example when you use our services. Your personal data is processed for carrying out the rights and obligations related to a contract or other commitment between GetJenny and you.

  • Managing and developing services

GetJenny may use your personal data to manage and develop GetJenny’s business operations.

  • Communication with you.

GetJenny may use your personal data to communicate with you, for example, to send you alerts and notifications relating to our products and services, to inform you that our product and services have changed, and to ask for your feedback on our products and services. Our communication with you may contain mandatory customer communication (for example, for security reasons) that you cannot opt-out. We may also use your personal data for registrations for our events and webinars.

  • Marketing to you.

GetJenny may contact you to inform you of new products, services or promotions GetJenny and its cooperation partners may offer. GetJenny may use your personal data to personalize our offering and to provide you with more relevant content. This means, for example, making recommendations and to display customized content and advertising in our services and on third party services and websites.

  • Security and complying with our legal duties.

The processing of your personal data might also be necessary to ensure the security of our services and IT environments and to prevent abuses. In some cases, we may also need to process the personal data to ensure that we are compliant with applicable legal obligations or the personal data may be needed to respond to and defend against legal claims.

 

We process personal data on the following legal basis:

  • The legal basis for the processing of your personal data is, where not stated otherwise or another legal basis is otherwise applicable, the performance of the contract for providing the services to you, as permitted by GDPR article 6(1)(b).
  • GetJenny can also process your personal data where we have a legitimate interest to do so, as permitted by GDPR article 6(1)(f), such as for marketing purposes and to maintain the customer relationship. Where we rely on legitimate interest as a legal basis for processing of personal data, we have considered whether or not those interests are overridden by your rights and freedoms as data subject and we have concluded that they are not.
  • Where the applicable legislation requires your consent for the processing, we will state so and obtain your consent and this will be the legal basis for the processing of personal data, as permitted by GDPR article 6(1)(a). You have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
  • In some cases, we may process personal data to comply with legal obligations applicable to us (such as corporate and accounting).
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4. What types of data we gather?

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:

  • First and last name
  • Contact information (postal address, e-mail address, telephone and fax numbers)
  • Job title and employer (past and current)
  • Language preferences
  • Username and password
  • Starting and ending moment and method of the customer or comparable relationship
  • Information of the use of GetJenny’s digital services as well as digital content created by you
  • Technical data sent to GetJenny by your digital devices (such as computers and mobile devices) as well as information related to cookies and other similar technologies
  • Recordings, transcripts and/or notes of interactions (meetings, phone calls, etc.) with GetJenny personnel as well as e-mail and chat correspondence
  • Direct marketing preferences
  • Campaigns and promotions directed to you, as well as their use
  • Interests and other information provided by you
  • Information received from social media service providers, such as your basic profile data and contact lists within a service.

 

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
  • Purchase history (inc. contracts) billing, delivery, returns and payment collection data (excluding bank account or credit card information unless needed for reimbursement purposes)
  • Content, correspondence and consequences related to feedback and complaints.

 

Information of data subjects participating in GetJenny’s events:

  • Relevant information related to the organization or participation of the event.
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5. Where do we gather your personal data from?

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:

  • Sign up for a newsletter or blog,
  • Request a contact from us,
  • Download a case study,
  • Create a GetJenny account or sign up for a trial,
  • Schedule a demo,
  • Use our website and/or service,
  • Chat with us on our website,
  • Participate in GetJenny’s events

 

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.

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6. Is your data shared with others?

As a general rule GetJenny never sells or leases your personal data to third parties.

GetJenny may share your personal data with authorized third parties that perform services for GetJenny for the purposes described in this Privacy Policy within the limits of the applicable legislation. This may include for example providing services such as customer service, support, software and hosting services, managing and analyzing personal data, conducting research and managing marketing campaigns. GetJenny expects these third parties to abide by all relevant legislation and protect your personal data in a consistent manner with this Privacy Policy. List of the processors and other recipients can be provided upon request.

GetJenny may share your personal data with carefully considered third parties for joint or independent direct marketing purposes. Sharing of your data for such purposes may in principle only happen when the planned purposes of the third party are not incompatible with GetJenny’s purposes described in this Privacy Policy. Only the minimum necessary amount of your personal data is shared with 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.

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7. Is your data transferred to countries outside the European Union or the European Economic Area?

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 European Union (EU). However, GetJenny uses service providers (such as HubSpot) who can transfer data outside the EU/ European Economic Area (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. In case the personal data is transferred outside the EU or the EEA, such transfers are either made to a country that is deemed to provide a sufficient level of privacy protection by the decision of the European Commission or transfers are carried out by using appropriate safeguards such as standard data protection clauses.

More information about the safeguards can be provided upon request.

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8. How do we protect your personal data?

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 the systems 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.

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9. How long do we process your Personal data?

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 retain personal data for a longer or shorter period if required by applicable law (such as customer data for accounting, tax law and product liability related obligations) or if there is some other justified reason for us to retain or delete the personal data. In such a case, once the reason to retain the personal data ceases to exist, personal data shall be erased without delay. 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.

More information about the personal data retention periods can be provided upon request.

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10. Your rights

As a data subject, you have a number of rights under the applicable data protection legislation:

  • You have a right of access to the data concerning you in GetJenny’s personal data files.
  • 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.
  • 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.
  • You have the right to receive personal data provided by you to GetJenny in a structured, commonly used and machine-readable format and, if desired, transmit that data to another controller. The right does not apply for example to data that the controller has created on the basis of the data supplied by you (as a data subject) or that has been compiled through the analysis of data generated by observing the data subject, such as profiling.

You may exercise the aforementioned rights by sending a written request to privacy@getjenny.com. The request must be signed. The request can also be presented at the main office of GetJenny with verification of identity.

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11. Cookies and tracking

GetJenny uses cookies on its website and service to offer a better experience. A cookie is a small piece of data in form of a text file that is placed onto your device (persistent cookie) or stored in memory (session cookie). Information the cookie contains is set by the server and it can be used by that server whenever the user visits the site. Cookies allow websites to store things like remembering you and your user preferences.

Cookies can be stored for varying lengths of time on your browser or devise. Session cookies are deleted from your computer or device when you close your web-browser. Persistent cookies will remain stored on your computer or device until deleted or until they reach their expiry date (which varies typically from a few days up to a couple of years).

Cookies may be set by the site that you are visiting (first party cookies), or by third parties, such as those who serve content or provide advertising or analytics services on our website (third party cookies).

We use cookies to compile data about site and application traffic and interaction to offer a better experience and service in the future. We may contract with third-party service providers to assist us in better understanding our site visitors. Such service providers are not allowed to use the information collected on our behalf except to help us conduct and improve our business. Cookies are also used to store current session and authentication information.

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What types of cookies do we use?

Strictly necessary cookies

These cookies are essential for our site to perform its basic functions. Without these cookies, some parts of our site just won’t work as they should.

 

Functional cookies 

In order to provide you with better experience on this site we provide the functionality to set your preferences for how this site runs when you use it. In order to remember your preferences, we need to set cookies so that this information can be called whenever you interact with a page that is affected by your preferences.

 

Targeting cookies and social media

We may use cookies to deliver advertised content which is relevant to you. In addition, some cookies may be used to track the effectiveness of our ad campaigns on third party websites.

In addition, we use social media buttons and/or plugins on our site that allow you to connect with your social network in various ways. Some of these cookies may be set when a page is loaded, or when you take a particular action like clicking a social media sharing button.

We may also obtain information from our email newsletters or other communications we send to you, including whether you opened or forwarded a newsletter or clicked on any of its content. This information tells us about our newsletters’ effectiveness and helps us ensure that we’re delivering information that you find interesting.

 

Performance and analytics cookies

Performance cookies collect information on how you interact with our websites and how our website performs. These cookies may track things such as how long you spend on the site or pages you visit which helps us to understand how we can improve the site for you.

We use Google Analytics, which is one of the most common analytics tool for helping us to understand how you use our site and ways that we can improve your experience. For more information on Google Analytics cookies, please see the Google Analytics cookie usage documentation.

 

You might encounter the following cookies on our site

Name

Purposes

Google Analytics

Measure Website Usage

Google Ads

Google Advertising and Remarketing. See Google Cookie Policies 

LinkedIn Marketing Solutions

LinkedIn Advertising and Remarketing Analytics

Facebook

Facebook Advertising and Remarketing Analytics. See Facebook's Policies

Matomo Analytics

Measure Website Usage

HubSpot

Measure website usage, personalised experience for recurring visitors, customer relationship management.

 

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How can I allow, control and disable cookies?

You can give a consent to cookies, for example, by using the appropriate settings of a browser or device.

In addition, you can control and disable use of cookies by adjusting the settings on your browser or device. You can, for example, disable use of cookies, allow use of all cookies or only use of first party cookies. You can set the browser to delete cookies after each browser session or delete them manually. Disabling use of cookies may downgrade or break certain elements of our site’s functionally and certain functions may not work in the usual way.

Please check your browser’s help manual for further instructions. Below we have provided instructions for deleting cookies from the most common browsers:

Google Chrome

Mozilla Firefox

Internet Explorer

Safari

 

If you want to prevent Google Analytics gathering data from you, Google Analytics provides an Opt-out browser add-on for that purpose.

More information about the cookies, please see the website of the national supervisory authority Traficom.

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12. Choice of law and the right to lodge a complaint

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.

Contact details of the Finnish data protection authority can be found here.

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13. Changes to this Privacy Policy

GetJenny may from time to time change this Privacy Policy or change or withdraw access to different services at any time with or without notice. However, if this Privacy Policy is changed in a material, adverse way, GetJenny will post a notice advising of such change on GetJenny’s homepage for 30 days. GetJenny recommends you to revisit this Privacy Policy from time to time to notice any such changes.

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