“Personal Data” (or personal information) means any information about an individual from which that person can be identified. For instance, it may include your name, telephone number, email address, or payment information, and in some places like the European Economic Area (“EEA”) even your IP address. However, it does not include anonymous data — where any identifiers connected to an individual have been permanently removed. We collect a variety of Personal Data about our customers and visitors to the Platform in different ways.
The Personal Data that we collect falls into these general categories (with some overlap in some instances):
We do not — and do not wish to — collect any special categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data), nor do we collect any information about criminal convictions and offenses.
We also collect, as a processor, any Personal Data of a third-party that you include in any data you provide through the Platform and you act as the controller of such Personal Data.
Know that if you choose not to share certain Personal Data with us, or refuse certain contact permissions, we might not be able to provide the services you need. This is especially true of Identity Data, which is necessary for us to enable your use of the Platform, or of Financial Data, which we need to collect and retain in order to validate and record any financial transactions on the Platform.
We use different methods to collect Personal Data from and about you:
Direct interaction with the Platform. You may provide us your Identity, Contact and Financial Data by registering on the Platform or by corresponding with us, mostly by email or through social media. This includes Personal Data you provide when you:
Automated technologies or interactions. As you interact with us, such as browsing our Site, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may also collect Tracking Data when you use our Platform.
Third parties or publicly available sources. We may receive Personal Data about you from various types of third parties, including:
Jepto recognizes the privacy interests of children, and we encourage parents and guardians to take an active role in their children's online activities and interests.
Our Platform and services are not intended for minors and Jepto does not target the Platform or any of its services to minors. Jepto does not knowingly collect Personal Data from minors. If you are under the age of 18, please do not register and do not provide us with any Personal Data.
We will only use your Personal Data as allowed by law. In general, we will use your Personal Data in the following circumstances:
Generally, we do not rely on consent as a legal basis for processing your Personal Data other than where the law requires it, for example in relation to sending certain direct marketing communications. Where our legal basis is consent, you have the right to withdraw consent any time.
For our EEA users and visitors, see Legal Bases for Processing Personal Data to find out more about the lawful bases that we will rely on to process your Personal Data.
Jepto may share Personal Data with our third-party agents, contractors, or service providers who are hired to perform services on Jepto’s behalf. These providers may operate or support certain functions of the Platform, or process Personal Data on our behalf in order to assist us with certain functions. Below is an illustrative list of functions for which we may use third-party service providers and the names of the providers we may use to perform these functions:
We may disclose Personal Data about you as required or permitted by law and/or to comply with a judicial proceeding, court order, or legal process. To the extent permitted by applicable law, we also may disclose Personal Data about you in response to a request from law enforcement agencies, regulators or other public agencies (including schools or children services) or if we believe such disclosure may prevent a crime, facilitate an investigation related to public safety or protect the safety of individuals, protect the security or integrity of our Platform, or enable us to take precautions against liability or to protect our rights.
We may disclose or otherwise transfer information about our users, including Personal Data, to an acquirer, successor, or assignee as part of any merger, acquisition, sale of assets, or similar transaction, or in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.
We also share data with third parties connected to advertising, retargeting and analytics. Please see Cookies below, including the cookie list, for more information about who those third parties are.
We share aggregated, automatically-collected or otherwise non-personal information with third parties for various purposes, including (i) compliance with reporting obligations; (ii) for business or marketing purposes; (iii) to assist us and other parties in understanding our users' interests, habits and usage patterns for certain programs, content, services, advertisements, promotions and/or functionality available through the Platform. We do not share personal information about you in this case.
We reserve the right to change the Agreement at any time for any reason. Any changes we may make to the Agreement in the future will be notified to you by posting an updated version of the Agreement on this page with an updated revA cookie is a small text file that is stored on a user's computer for record-keeping purposes. When you visit or access the Platform, we may by means of cookies, beacons, tags, scripts, and/or similar technologies automatically collect technical information about the devices and software you used to access the Platform, such as the type of Internet browser or mobile device you use, the website or source that linked or referred you to the Platform, your IP address or device ID (or other persistent identifier that uniquely identifies your computer or mobile device on the Internet), the operating system of your computer or mobile device, and other similar technical information.
You can see more information about the cookies we use including who they belong to, their ID and why they are used. We’ve also included links to the third-party websites where you can go to find out more.
We use both session ID cookies and persistent cookies. Jepto tracks users use of the Platform, but does not track users across third-party websites.
These same technologies (or a combination of them) may also be used to help us:
We may use third-party tools and technologies to help us gather this information discussed above. For instance, we use Google Analytics to collect and process certain analytics data with technologies such as tracking pixels. Typically, all technical, analytics, and usage information is gathered by Jepto in anonymous form and does not identify you personally.
What does this mean? When you click on a link to an External Partners on our Site, that External Partner will drop a cookie (or similar tracking technologies) and likely capture and collect your device ID or IP address, as well as information about your device, operating system, the wireless carrier providing service to such device, and the geographical location of the device (i.e. Usage, Technical and/or Tracking Data primarily) so that it can track your activity on the Site and when you visit other sites, unless you blocked cookies as described below.
These External Partners may also download non-personally identifiable cookies to your computer, or use other technologies such as “web beacons” to measure the effectiveness of their ads and to personalize advertising content. Their use of your Personal Data will be governed by the terms of their privacy policies and their privacy policies may explain the way in which you can “opt-out” of certain tracking by their advertisements.
Jepto does not process or respond to web browsers' “do not track” signals or other similar transmissions that indicate a request to disable online tracking of users who visit or use our Platform.
A cookie is a small text file that is stored on a user's computer for record-keeping purposes. When you visit or access the Platform, we may by means of cookies, beacons, tags, scripts, and/or similar technologies automatically collect technical information about the devices and software you used to access the Platform, such as the type of Internet browser or mobile device you use, the website or source that linked or referred you to the Platform, your IP address or device ID (or other persistent identifier that uniquely identifies your computer or mobile device on the Internet), the operating system of your computer or mobile device, and other similar technical information.
We may carry out direct marketing by email if you are a registered user. For example, you might receive our newsletter, which will always contain a link to unsubscribe that you can click on if you no longer wish to receive the newsletter.
Tracking Data, and in particular cookies, help us to deliver website and social advertising that we believe is most relevant to you and to potential new customers of Jepto. The cookies used for this purpose are often placed on our website by our External Partners. This includes retargeting.
If you want more information about Tracking Data, in particular cookies, see Cookies above.
Almost all the cookies that relate to advertising are part of third-party online advertising networks via our External Partners. Certain advertisements that appear on the Platform are sometimes delivered (or “served”) directly to users by our External Partners. Some of these External Partners automatically receive certain of your Personal Data through your interaction with an advertisement, as described above in Cookies.
We may use social plugins on our Platform and may include icons that allow you to interact with third-party social networks. If you use any social plugins, the relevant third-party may set a cookie when your browser creates a connection to the servers of such social networks and the plugin may transmit your data to the social networks.
The table below shows the different ways that we use Personal Data, and which of the legal bases we rely on to do so.
Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data.
We do not carry out any automated decision-making.
Please contact us if you have any questions.
We have implemented a number of security measures designed to protect your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. For instance, we use firewalls, password protection, secure socket layer, encryption, and other security measures to help prevent unauthorized access to your personal data.
In addition, we limit access to your Personal Data to our 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.
We have implemented procedures to handle any suspected Personal Data breach (or unauthorized access) and will notify you and any applicable regulator of a breach as legally required.
We will only keep your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. In some circumstances you can ask us to delete your data; see EEA Rights: Staying in Control of Your Information: Your Legal Rights below for further information.
Subject to exceptions as required or permitted by applicable law, we retain Personal Data that is necessary for your use of the Platform as long as you are a user of the Platform. Given the nature of our services and tax-related matters, we retain certain Financial Data and related information for as long as required by law.
Metadata on the Platform which is needed for the purposes of IT security and maintaining the Platform in general, can be retained for the prevention of fraud and abuse, and therefore will be retained for such purpose, generally for a period of up to three years. This includes (for instance) IP address.
There are exceptions from static retention periods that have to be taken into consideration. For instance, we cannot delete Personal Data when there are legal obligations to retain the Personal Data (e.g. arising from tax or commercial law). This is particularly true of data Financial Data and payment information.
Additionally, we cannot delete Personal Data when it is needed for the establishment, exercise or defense of legal claims (“litigation hold”). In this case, the Personal Data can be retained as long as needed for exercising respective potential legal claims.
If Personal Data can no longer be retained it will be erased without undue delay, generally within one month, unless exceptions apply.
In some instances, we may choose to anonymize your Personal Data instead of deleting it, for statistical use, for instance. When we choose to anonymize, we make sure that there is no way that the Personal Data can be linked back to you or any specific user.
With respect to all the rights listed below, please click in order to exercise your rights.
These rights are subject to certain rules around when you can exercise them. You can see a lot more information on them, if you are interested, on the UK Information Commissioner’s Office website, for instance.
For all requests mentioned above, we may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data 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.
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 unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
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 (see How to Contact Jepto About Privacy).