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Privacy Policy

 

This document was last updated May 23, 2018.

Table of Contents

  • General
  • What does this Privacy Policy cover?
  • To what purposes we may process your data?
  • What information we may collect about you
    • Basic information of all data subjects
    • 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
  • Where do we gather your personal data from?
    • Cookies and tracking
  • Is your data regularly shared with others?
  • Is your data transferred to countries outside the European Union or the European Economic Area?
  • Principles of securing the data
  • How long do we process your Personal data?
  • Your right of access, correction and prohibition
  • Choice of law and the right to lodge a complaint to the supervisory authority and the contact details of the supervisory authority
  • Changes to this Privacy Policy


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General

This Privacy Policy explains what information we collect, how we use that information and what are your rights and choices.

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.

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.

To what purposes we may process your data?

The purposes of processing your personal data are the following (one or more purposes may apply simultaneously):

  • 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.
  • 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.

What information we may collect about you?

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 data (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

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.

Cookies and tracking

GetJenny uses cookies on its website and Service to offer a better experience. A cookie is a small piece of data sent from a website and stored on your computer by your web browser.

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.

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, 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.

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.

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 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).

Principles of securing the 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 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.

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 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.

Your right of access, correction and prohibition

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 privacy@getjenny.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.

Choice of law and the right to lodge a complaint to the supervisory authority and the contact details of the supervisory authority.

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.

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.