Introductions

This Privacy Policy is effective from 20/08, 2019

JetOctopus OU (hereinafter - “we”, "our", “us”, “JetOctopus”) is an Estonian company that operates the website jetoctopus.com (hereinafter - the “Website”) that allows its users to gain access to the use of “JetOctopus” software via SaaS.

We, at JetOctopus, have created a Privacy Policy that aims to help you understand what data we collect, what we use it for and how you can exercise your rights. It is important to reading this Privacy Policy carefully and understand it clearly, so we hope you will give it time and attention.

Privacy and security of our customers and visitors are of paramount importance for us. We are committed to protecting the data you share with us. This Privacy Policy explains how we process information that can be used to directly or indirectly identify individuals (“Personal Data”) collected through the use of our Website.

For the purposes of this Privacy Policy, we define the term “Customer” as a person who has created his or her own account on the Website, and the term “Visitor” - as an individual who visits our Website.

In order to carry out our obligations under contracts between Customers and us, we have to process the information (including Personal Data) they give us.

We adhere to the following principles in order to protect your privacy:

  • principle of purposefulness - we process Personal Data fairly and in a transparent manner only, aiming to achieve determined and lawful objectives, and they shall not be processed in a manner not conforming to the objectives of data processing;

  • principle of minimalism - we collect Personal Data only to the extent necessary to achieve  determined purposes. We do not keep Personal Data if it is no longer needed;

  • principle of restricted use - we use Personal Data for all other purposes only with the consent of the data subject or if permitted by a competent authority;

  • principle of data quality - we always keep Personal Data up-to-date and complete in order to achieve the end purpose of the data processing more efficiently;

  • principle of security - security measures shall be applied in order to protect Personal Data from unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical and organisational measures;

  • principle of individual participation - our Customers and Visitors shall be notified of data collected in connection to them. They shall be granted access to their Personal Data and have the right to demand a correction of inaccurate or misleading data.

  1. Data we collect and purposes of data processing

  1. Website Visitors

  1. We may collect, record and analyze information of Visitors of our website.

  1. We collect email address only when Visitor wants to contact us in order to book a demo or subscribe to our newsletter and fills our contact form. We use the collected Personal Data only to communicate with you. If you don’t want us to collect your Personal Data, please do not use our contact form and don’t give your consent for it.

  1. We collect email address only when Visitor wants to contact us and writes us on our email address that is available on the Website. We use the collected Personal Data only to communicate with you, as you reasonably expect us to answer you.

  1. While processing Personal Data of our Visitors, we rely on your consent to the processing of your Personal Data for the purpose of  communicating with you. We use such Personal Data in ways you would reasonably expect and which have a minimal privacy impact. You can withdraw your consent at any time by sending us an email to _____ with your withdrawal request and your Personal Data will be deleted within seventy-two (72) hours.

  1. If you contact us via online chat on our Website, we  may record your request and our reply in order to increase the efficiency of the organisation of our support service. We keep personally identifiable information associated with your message, such as your name and email (if you provided such data to us), so as to be able to track our communications with you in order to provide you with high quality service.

  1. We also record Usage Data. It is information collected automatically through our Website (or third-party services employed by JetOctopus), which may  include:

  • the IP addresses or domain names of the computers utilized by the Visitors who use the Website;

  • the URI addresses (Uniform Resource Identifier);

  • the time of the request;

  • the method utilized to submit the request to the server;

  • the size of the file received in response;

  • the numerical code indicating the status of the server's answer (successful outcome, error, etc.);

 

  • the country of origin;

 

  • the features of the browser and the operating system utilized by the Visitor;

 

  • the various time details per visit (e.g., the time spent on each page) and the details about the path followed with special reference to the sequence of pages visited; and

  • other parameters about the device operating system and/or the Visitors’ IT environment.

  1. We use this information in aggregate to assess the popularity of the web pages on our Website and how we perform in providing content to you. When combined with other information we know about you from previous visits, the data could possibly be used to identify you personally, even if you are not signed into our website. We use Google Analytics, Google Tag Manager and LinkedIn Analytics to analyze data. Information collected this way is stored for no longer than one year.

  1. Processing of Usage Data is relied on our legitimate interests. It is necessary for managing and running our business efficiently and effectively, providing quality services including website support, developing and improving products, determining who may be interested in them.

  1. Wherever possible, we aim to obtain your explicit consent to process your Personal Data, for example, by asking you to agree to use Cookies.

  1. Visitors can control the use of Cookies at the individual browser level. If you reject Cookies, you may still use our website, but your ability to use some features or areas of our website may be limited. To learn more and for a detailed Cookie notice, Visitors may refer to our Cookie Policy.

  1. Customers

  1. In order to provide services to our Customers, we collect their personally identifiable information.

  1. When you create an account on our Website, a contract is formed between you and us. In order to carry out our obligations under that contract we must process the information you give us.

  1. During the creation of your account on our Website, you provide us with your first and last name, your country and email address. This information is used by us to identify our Customers and provide you with services, billing, mailings, notification and support.

  1. We may verify Your identity by asking You to submit scan copies of Your documents. We process this information on the basis there is a contract between us, and our legitimate interests (prevention of fraud and infringements of intellectual property rights). We use such information to identify our Customers, prevent and detect improper use of intellectual property objects available on the Website, respond to any Customer complaints and comply with any laws and regulations that apply to us. We use such data in ways you would reasonably expect and which have a minimal privacy impact.

  1. We may obtain your Personal Data from third parties such as payment service providers, whose services we use. We may receive your name, telephone number and shortened payment information (4 last digits of your card number).

  1. We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.

  1. Payment information is never taken by us or transferred to us either through our Website or otherwise. Our employees and contractors never have access to it. At the point of payment, you are transferred to a secure page on the website of FastSpring  or PayPal payment service provider.

  1. Processing of Personal Data for marketing purposes is also relied on the consent obtained from you. We use data in ways you would reasonably expect and which have a minimal privacy impact.

  1. Compliance with General Data Protection Regulation (GDPR)

  1. For Visitors and Customers located in the European Economic Area (EEA) privacy rights are granted and all processing of Personal Data is performed in accordance with regulations and rules of   Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, known as the General Data Protection Regulation (GDPR).

  1. We process Personal Data as a Controller, as defined in the GDPR:

  • JetOctopus, with which, you as a Customer, have entered into an agreement when you created your account at the Website, will be the Controller of Customer Data, as outlined above in the “Customer” section.

  • Also, JetOctopus will be the Controller for Visitor Data, as outlined above in the “Visitor” section.

  • JetOctopus will not be the Processor of personal data on behalf of the Сustomers, who use JetOctopus software, as JetOctopus software is not intended for any Personal Data collection and processing.

  1. The processing and transfer of Personal Data is carried out in accordance with the requirements set out in regulations and rules of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, known as the General Data Protection Regulation (GDPR).

  1. Our Privacy Policy is compliant with the laws of every country or legal jurisdiction within which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, we should like to hear from you. However, ultimately it is your choice as to whether you wish to use our Website.

  1. Your rights as a data subject

  1. Visitors and Сustomers can review, correct, update, delete or transfer their personally identifiable information. For that, contact us directly at support@jetoctopus.com. We will acknowledge your request within seventy-two (72) hours and handle it promptly and as required by law.

  1. Right to object to processing of your Personal Data. Visitors and Customers have the right to object to the processing of their Personal Data by us.

  1. Right to access to your Personal Data. Visitors and Customers have the right to learn if Personal Data is being processed by Data Controller, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Personal Data undergoing processing.

  1. Right to verify and seek rectification. Visitors and Customers have the right to verify the accuracy of their Personal Data and ask for it to be updated or corrected.

  1. Right to restrict the processing of your Personal Data. Visitors and Customers have the right, under certain circumstances, to restrict the processing of their Personal Data. In this case, Data Controller will not process their Personal Data for any purpose other than storing it.

  1. Right to have your Personal Data deleted or otherwise removed. Visitors and Customers have the right, under certain circumstances, to obtain the erasure of their Personal Data from Data Controller.

  1. Right to receive your Personal Data and have it transferred to another controller. Visitors and Customers have the right to receive their Personal Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.

  1. You can withdraw your consent at any time by replying to the email with your withdrawal request and your Personal Data will be deleted within seventy-two (72) hours.

  1. Also, you have the right to lodge a complaint with a supervisory authority if you think that we violate your rights. But we kindly ask you to contact us first so that we can help you.

  1. When we receive any request to access, edit or delete personally identifiable information, we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

  1. Data Retention

  1. Personal Data shall be processed and stored only for as long as required for the purpose they have been collected for.

  1. We will keep your Personal Data for the period that you are our Customer. If you are no longer a Visitor or Customer of JetOctopus, we will keep your Personal Data for the minimum length of time required to comply with the purposes set out in this Privacy Policy and relevant legal or regulatory obligations, but not more than twelve (12) months. Personal Data collected and processed with your consent shall be retained as long as we have your consent.

  1. Information obtained via contact forms is deleted on an annual basis. Your information will be deleted if you did not communicate with the support team for more than twelve  (12) months.

  1. Any Usage Data collected for the purpose of analytics will be deleted in not more than twelve  (12) months after being collected.

  1. Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to Personal Data portability cannot be enforced after expiration of the retention period.
  2. Please note that you cannot unsubscribe from certain email correspondence from us, such as messages relating to your account transactions, purchases, software updates and instructions.

  1. Information Security

  1. We care to ensure the security of your Personal Data. We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. We maintain technical, physical, and administrative security measures to provide reasonable protection for your Personal Data. When we or our contractors process your information, we also make sure that your information is protected from unauthorized access, loss, manipulation, falsification, destruction or unauthorized disclosure. This is done through appropriate administrative, technical and physical measures.

  1. We always use pseudonymisation as a method of securing Personal Data, where it is possible. 

  1. There is no 100% secure method of transmission over the Internet or electronic storage. We therefore cannot guarantee its absolute security.

  1. We never process any kind of sensitive data and/or criminal offence data. Also, we never undertake profiling of Personal Data.

  1. Contractors

  1. We work with third party service providers which provide website development, hosting, maintenance, sending emails, marketing, technical support and assistance, processing credit card payments, IT and cyber security services, fraud checking services, customer service and other services for us. These contractors may have access to, or process Personal Data on behalf of us, as part of providing those services to us. We limit the information provided to these service providers to the extent it is reasonably necessary for them to perform their functions.

  1. We use Google Analytics to monitor and analyze web traffic. Google Analytics is a web analysis service provided by Google LLC. (“Google”). Google utilizes the Data collected to track and examine the use of our website, to prepare reports on its activities and share them with other Google services. Google may use the Personal Data collected to contextualize and personalize the ads of its own advertising network. Personal Data collected: Cookies and Usage Data. Place of processing: USA – Privacy Policy – Opt Out. Privacy Shield participant.

  1. We use Google Tag Manager to monitor and analyze web traffic. Google Tag Manager is a tag management system provided by Google. Google utilizes the Data collected to track and examine the use of our website, to prepare reports on its activities and share them with other Google services. Google may use the Personal Data collected to contextualize and personalize the ads of its own advertising network. Personal Data collected: Cookies and Usage Data. Place of processing: USA – Privacy Policy – Opt Out. Privacy Shield participant.

  1. We use Google Ads to optimize our online advertisements. Google Ads is a online advertising platform provided by Google. Google utilizes the Data collected to retarget our advertisements, to prepare reports on advertisements efficiency and share them with other Google services. Google may use the Personal Data collected to contextualize and personalize the ads of its own advertising network. Personal Data collected: Cookies and Usage Data. Place of processing: USA – Privacy Policy – Opt Out. Privacy Shield participant.

  1. We use LinkedIn Analytics to monitor and analyze web traffic. LinkedIn Analytics is a web analysis service provided by LinkedIn Ireland Unlimited Company (“LinkedIn Ireland”). LinkedIn Ireland utilizes the Data collected to track and examine the use of our website, to prepare reports on its activities and share them with other LinkedIn services. LinkedIn Ireland may use the Personal Data collected to contextualize and personalize the ads of its own advertising network. Personal Data collected: Cookies and Usage Data. Place of processing: the Republic of Ireland – Privacy Policy – Opt Out. Privacy Shield participant.

  1. We use Chatra for customer support. Chatra is an online chat service provided by Roger Wilco LLC (“Chatra”). Chatra utilizes the Personal Data of the Customers to allow us to identify, which Customer is contacting us and respond to such Customer’s query properly. Personal Data collected: Customers’ names and emails, Cookies and Usage Data. Place of processing: Germany – Privacy Policy – Opt Out. Privacy Shield participant.

  1. For more detailed information about the international information transfers to our business partners, service providers and developers outside of the EU/EEA, please contact us using the details given in the “Contact us” section below.

  1. We use OVH provided by OVH SAS as secure hosting facilities. Place of processing: France - Privacy Policy. The infrastructure is secured through a defense-in-depth layered approach.

  1. We may need to share your Personal Data with the third parties that provide those services. Where your Personal Data are transferred outside of the European Economic Area (“EEA”), we require that appropriate safeguards are in place. These contractors may have access to, or process Personal Data on behalf of us, as part of providing those services to us. We limit the information provided to these service providers to the extent it is reasonably necessary for them to perform their functions.

  1. Use of site by children

  1. We do not provide services to children. Visitors declare themselves to be adult according to their applicable legislation.

  1. Our website is not directed to persons under the age of 16. Minors may use our website only with the assistance of a parent or guardian. Under no circumstance persons under the age of 13 may use the website.

  1. We collect data about all Customers and Visitors regardless of age. We do anticipate that some of those users and visitors will be children.

  1. Application of this Privacy Policy

  1. This Privacy Policy is applicable only to our Website. This version of the Privacy Policy is effective from 20/08/ 2019.

  1. Please be aware while visiting our Website. Our Website contains links to other websites. Once redirected to another website, this Policy is no longer applicable. We are not responsible for the content or privacy policies of these other websites.

  1. Acceptance of these Conditions

  1. We assume that all Visitors and Customers have carefully read this document, understand its contents and agree to the terms and conditions stated in the Privacy Policy above. If one does not agree with this Privacy Policy, they should refrain from using our website.

  1. Changes and Updates to our Privacy Policy

  1. We may update this Privacy Policy from time to time, so please review it frequently. All changes to this Privacy Policy are effective upon being posted on this page.

  1. If any material changes are made to this Privacy Policy, we will use reasonable endeavours to inform you in advance by email or notice on the website. When we change this Privacy Policy in a material manner, we will let you know via email prior to the changes becoming effective and update the effective date at the top of this page.

  1. Contact us!

  1. If you have any questions about the practices of this website or your dealings with this website, please contact us at support@jetoctopus.com.

JetOctopus OU

Company number: 14483580  

Registered address: Estonia, Harju maakond,

Tallinn, Kesklinna linnaosa,

Narva mnt 7-kabinet 634,

10117

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