This policy was last updated December 26, 2018.
1. Personal data collection and use by Jama
1.2 This policy applies to the following groups of individuals:
- business contacts;
- individuals who have signed up for a free trial;
- on premise customers;
- online customers; and
- website users.
2. The detail – the key information you should be aware of is set out below
2.1 How we obtain your personal data
You may provide us with your personal data as a result of entering into a subscription for one of our services or signing up to receive information on our website. We also obtain personal data from third parties such as sellers of marketing lists or our suppliers, which we refer to as “third party sources” or “suppliers” throughout this policy. Jama also has a referral scheme whereby another individual may give us your personal data because they believe you would be interested in our services.
2.2 What personal data we collect about you
We collect and use the following personal data:
- job title;
- business email address;
- telephone number;
- company name;
- IP address;
- cookie IDs; and
- profile picture.
If you are an online customer or website user, we will also collect the following about you:
- username; and
2.3 How we use your personal data
- We will collect, use and store the personal data to carry out our obligations arising from any contract that exists between us, for example to correspond with you in relation to your or your company’s subscription or trial of our services.
- Where we do not have a contract with you or your company, we will collect, use and store the personal data listed to contact you about our services. Your personal information is processed in accordance with our legitimate interest to run, grow and develop our business. We have undertaken a balancing test to ensure that our legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information. You can ask us for information on this balancing test by using the contact details listed above.
- Whatever our relationship with you is, we may also collect, use and store your personal data for the following additional reasons:
- to deal with any enquiries or issues you have about how we collect, store and use your personal data, or any requests made by you for a copy of the information we hold about you. Even if we do not have a contract with you, we may process your personal data for these purposes where it is in our legitimate interests for customer services purposes;
- for internal corporate reporting, business administration, ensuring adequate insurance coverage for our business, ensuring the security of company facilities, research and development, and to identify and implement business efficiencies. We may process your personal data for these purposes where it is in our legitimate interests to do so;
- to comply with any procedures, laws and regulations which apply to us – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others to comply, as well as where we are legally required to do so;
- to establish, exercise or defend our legal rights – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others, as well as where we are legally required to do so;
2.4 How and why we share your personal data with others
- If you are not a customer of Jama, then we will share your personal data with suppliers of customer relationship management tools and marketing agencies for the purpose of pursuing our legitimate interest of growing our business.
- We will also disclose your personal data to third parties in the following circumstances:
- where it is in our legitimate interests to do so to run, grow and develop our business:
- we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets and/or to their professional advisers; or
- all or a substantial part of Jama’s or any of its affiliates’ assets are acquired by a third party, in which case personal data held by Jama will be one of the transferred assets;
- if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, any lawful request from government or law enforcement officials and as may be required to meet national security or law enforcement requirements or prevent illegal activity;
- in order to enforce or apply our terms and conditions or any other agreement or to respond to any claims, to protect our rights or the rights of a third party, or to prevent any illegal activity;
- to protect the rights, property, or safety of Jama, our staff, our customers (including residents) or other persons. This may include exchanging personal data with other organisations for the purposes of fraud protection and credit risk reduction; or
- when we believe in good faith that disclosure is necessary to protect your safety or the safety of others.
- All personal data is stored and processed in the US. This transfer is governed by the principles Privacy Shield. Details of which can be found below.
3. EU-U.S. Privacy Shield and SWISS-U.S. Privacy Shield
3.1 Jama participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework. Jama is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Frameworks, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List. https://www.privacyshield.gov/list
3.2 Jama is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Jama complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
3.3 With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Jama is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Jama may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
3.4 If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
3.5 Jama has further committed to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU and Switzerland in the context of the employment relationship.
3.6 Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
4. User Access and Choice
4.1 Upon request Jama will provide you with information about whether we hold any of your personal data. If your personal data changes, or if you no longer desire our service, you may correct, update, amend, delete/remove, ask to have it removed from a public forum, directory or testimonial on our site or deactivate it by making the change on our member information page or by emailing our Customer Care at firstname.lastname@example.org or by contacting us by telephone or postal mail at the contact information listed below. We will respond to your request within 30 days.
4.2 Jama sends out various marketing material including announcements about product updates, services or the company newsletter. You may opt-out at any time and choose to stop receiving periodic email by following the unsubscribe instructions included in these emails, accessing the email preferences in your account setting page or you can contact us at email@example.com.
5. EU citizens’ rights
5.1 If you are an EU citizen, you have certain additional rights to object to our use of your personal data. In this context personal data means any data that we hold about you which identifies you as an individual, for example your name or email address, and information connected to this would be personal data.
5.2 Information on the rights of EU citizens is set out below. If you would like further information in relation to these or would like to exercise any of them, please contact us via email at firstname.lastname@example.org at any time.
5.3 We will consider all such requests to exercise the rights listed below and provide our response within a reasonable period (and in any event within one month of your request unless we tell you we are entitled to a longer period allowed by applicable law). Please note, however, that certain personal data may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims.
5.4 If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make.
5.5 Right of access
You have a right to access to any personal data we hold about you. You can ask us for any of the following:
- a copy of your personal data;
- confirmation whether your personal data is being used by us;
- details about how and why it is being used; and
- details of what safeguards are in place if we transfer your personal data outside of the European Economic Area (“EEA”).
5.6 Right to update your personal data
You have a right to request an update to any of your personal data which is out of date or incorrect.
5.7 Right to ask us to delete your personal data
You have a right to ask us to delete any personal data which we are holding about you in certain specific circumstances. If you would like further information on these specific circumstances, please contact us.
If we receive a request from you we will also pass your request onto other recipients of your personal data unless that is impossible or involves disproportionate effort. We will also tell you who the recipients of your personal data are if you would like us to.
5.8 Right to restrict use of your information
You have a right to ask us to restrict the way that we process your personal data in certain specific circumstances. If you would like further information on these specific circumstances, please contact us.
If we receive a request from you, we will also pass your request onto other recipients of your personal data unless that is impossible or involves disproportionate effort. We will also tell you who the recipients of your personal data are if you would like us to.
5.9 Right to stop receiving marketing materials
You have the right to ask us to stop using your personal data for direct-marketing purposes. If you exercise this right, we will stop using your personal data for this purpose.
5.10 Right to data portability
You have the right to ask us to provide your personal data to a third-party provider of services.
This right only applies where we use your personal data on the basis of your consent or performance of a contract; and where our use of your information is carried out by automated means.
5.11 Right to object.
You have the right to ask us to consider any valid objections which you have to our use of your personal data where we process your personal data on the basis of our or another person’s legitimate interest.
6. Information Related to Data Collected for our Clients
6.1 Jama collects information under the direction of its clients, and in these instances, Jama has no direct relationship with the individuals whose personal data it processes. If you are a customer of one of our clients and would no longer like to be contacted by one of our clients that use our service, please contact the client that you interact with directly.
6.2 If you wish to access, correct, amend, or delete personal data which we hold on the direction of a client you should contact that client (the data controller) directly. If the client requests Jama to remove, amend or correct your personal data, we will respond to their request within 30 days of receiving it from the client.
6.3 We will retain personal data we process on behalf of our clients for as long as we are instructed to by the relevant client.
7. Tracking Technologies / Cookies
8. Log Files
8.1 As is true of most web sites, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.
8.2 We may combine this automatically collected log information with other information we collect about you. We do this to provide support for the services we offer.
We partner with a third party to either display advertising on our website or to manage our advertising on other sites. Our third-party partner may use technologies such as cookies to gather information about your activities on this website and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union click here). Please note this does not opt you out of being served ads. You will continue to receive generic ads.
10.1 The security of your personal data is important to us. When you enter your login information to our platform, we encrypt the transmission of that information using transport layer security (TLS).
10.2 We follow generally accepted standards to protect the personal data submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Web site, you can contact us at email@example.com.
11. Links to 3rd Party Sites
Our Web site offers publicly accessible blogs. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal data from our blog, contact us at firstname.lastname@example.org. 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.
13. Community Forum
We display personal testimonials of satisfied customers on our site in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at email@example.com.
15. Social Media Widgets
16. Changes To This Policy
17. Product Usage Data
Our product team is committed and dedicated to providing the absolute best Jama experience. To support this initiative, we might access your anonymized usage data. Analysis of this data will inform our data-driven product development. Please see the Usage Data FAQ for more information.
135 SW Taylor Suite 200
Portland, OR 97204
Phone Number: (971) 930-1500
Email us: firstname.lastname@example.org