Updated – November 2, 2022
1 – Preamble
As Juphy, Inc. (hereinafter referred to as “Juphy”, the “Company“, “we”, and through similar words such as “us”, “our”, etc.), we respect your privacy and are committed to fully explaining how we handle your personal information.
2 – Our Services
We provide a social media customer service tool for businesses that helps you bring your social media accounts together for efficient access and management through a single platform. Through the platform, you can manage your social media and various communication channels, engage your customers, analyze the results of your engagement, and track the performance of your customer service team.
Website; Juphy provides services through https://juphy.com for Visitors.
Platform; Juphy provides services through https://app.juphy.com for registered users (Clients and their Authorized Users).
3 – Acknowledgment of the Policy
By acknowledging this Policy, you are accepting that you have familiarized yourself with the practices described in this Policy, and the Terms of Service (the “Terms”), which governs this Policy and contains all disclaimers of warranties and limitation of liabilities. If you do not agree to the processing activities stipulated in this Policy, please do not further access or use the Website, Platform and related Services.
4 – Applicability of the Policy
This Policy explains how we process your personal information when you connect with Juphy, engage with our team or use our Website or Platform. This Policy applies to the personal information collected during the course of our relationship with you, through your use of the Website, or in relation to your registration, login, and usage of our Platform. For the purposes of this Policy, we are;
Where applicable, we indicate whether and why you must provide us with your personal information, as well as the consequences of failing to do so. If you do not provide personal information when requested, you may not be able to benefit from our Services if that information is necessary to provide you with the Service or if we are legally required to collect it.
We do not act as a controller with respect to the personal information we process on behalf of our Clients. In such cases, our Clients are the controllers of the personal information, and their privacy policies will apply to the personal information they upload or store in our Platform, as well as any personal information they may process from Social Networks through their use of the Platform. Any collection, use, and management of personal information by the Social Networks, including Facebook, Instagram, Twitter, LinkedIn, WhatsApp, Google My Business etc. are governed by their respective privacy policies and terms of services. For detailed information please see the section “Juphy as a Service Provider and Processor”.
Our Services also enable you to customize and connect your Juphy account to Third-Party Services, which may be available to you via our Platform. This Policy also does not apply to personal information that is processed when you access Third Party sites, products and services through our Website or Platform. The collection of your information by these Third Parties is governed by the respective Third-Party Services’ privacy policies and terms. This Policy does not apply to Third-Party sites, products, or services, even if they link to our Services, and you should consider the privacy practices of those Third Parties carefully.
5 – Definitions
Within the context of herein Policy, the following expressions shall bear the meanings ascribed to them below. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
All capitalized terms not defined in this Policy shall have the meanings set forth in the Terms. It is of utmost importance to read the Policy provided herein in tandem with the Terms to better grasp the key concepts provided and explained therein.
for the purpose of the CCPA, means the legal entity that collects Consumers’ personal information and determines the purposes and means of the processing of Consumers’ personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of Consumers’ personal information, that does business in the State of California
means the California Consumer Privacy Act of 2018 and as amended by the California Privacy Rights Act (CPRA) (collectively, “California Privacy Laws”),
means any organization or business that is a client of Juphy’s, has purchased a subscription, and has authorized its Authorized Users to engage on the Platform
means Juphy, Inc., a corporation incorporated and validly operating in the United States of America
for the purpose of the CCPA, means a natural person who is a California resident including (i) every individual who is in the USA for other than a temporary or transitory purpose, and (ii) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose
for the purposes of the GDPR, means the legal person which determines the purposes and means of the process of Personal Data alone or jointly with others
means a natural person who can be identified or rendered identifiable through the personal data related to
means any device that is suitable to access the Service such as a computer, a cellphone or a digital tablet
Do Not Track (DNT)
means a concept that has been promoted by U.S. regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites
means (i) Regulation 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the Processing of Personal Data and on the free movement of such data (General Data Protection Regulation) (the “EU GDPR“); and (ii) the EU GDPR as saved into United Kingdom law by virtue of section 3 of the United Kingdom’s European Union (Withdrawal) Act 2018 (the “UK GDPR“); in each case as may be amended or superseded from time to time
Personal Data Breach
means a breach of security whether accidental or on purpose, resulting in accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data
means any information/data that relates to an identified or identifiable individual
For the purposes of the UK & EU GDPR, Personal Data means any information relating to you such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity.
For the purposes of the CCPA, Personal Information means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with you.
means the platform and all relevant the services, tools and materials offered thereon, and any other content, media, social media accounts linked to or otherwise associated therewith, available only to registered users within a paid or trial subscription
Sale of Data
For the purposes of the CCPA, means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s personal information to another business or a third party for monetary or other valuable consideration
means the services provided by Juphy through Website and Platform as described in our Terms of Service
means any natural or legal person who processes the data on behalf of Juphy and refers to Third-Party companies or individuals contracted by Juphy to facilitate the Service, to provide the Service on behalf of Juphy, to perform services related to the Service or to assist Juphy in analyzing how the Service is used
For the purposes of the GDPR, Service Providers are considered as Data Processors. Our Third-Party Service Providers are considered as our ‘Sub-processors’.
mean the business accounts on the social networking sites, messaging platforms and/or application stores supported by the Platform (such as Twitter, Facebook, LinkedIn, Instagram, YouTube, WhatsApp, Google My Business, Google Play and App Store) that Client desires to connect through the Platform
Social Networks Authorization
means the authorization relating to the Client’s Social Networks, which enable the Platform to interact with Client’s Social Networks
Special Categories of Personal Data
means personal Information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership and genetic and biometric information, information concerning data subject’s sex life or sexual orientation
means any Third-Party Data Processor of Juphy who has or will have access to or process Personal Data
means any other natural or legal person that is not part of Juphy
mean any product that Service Providers submit to Juphy users for the proper performance of the Website, Platform and Services
means the data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit)
mean any natural person who is either a Visitor or an Authorized User of Client who has access to and benefit from the Platform or Services at various levels
means the natural person who accesses and/or uses certain parts of our Website during their visit. For example, a Visitor may request a demo, subscribe to our newsletter, and contact us by e-mail or Website
means the website and subdomains, and other media including all of their respective features and content belongs to Juphy, accessible from www.juphy.com
6 – Personal Information Collected by Juphy
Juphy obtains information about Visitors to our Website, our Clients and their Authorized Users, job applicants, and Customers of our Clients’ social media pages/properties.
We may collect, use, store and transfer different kinds of personal information about you which we collect from various sources as described below:
a – Personal Information We Collect Directly from You
We collect information from and about you and your transactions and other interactions with us. The type of information that we collect directly from you varies based on your interaction with our Website, Platform and our Service.
For example, we collect information directly from you when you register an account with us, make a purchase of paid Services, reach out to us through the support assistant, book a demo, request to receive marketing materials, apply for a job, apply to be an Affiliate, and complete an application or other forms on the Website or Platform. Personal information you may provide includes,
Registration and Account Information
If you desire to have access to the Platform you are required to become a registered user, and to submit the following types of personal information to Juphy: your name, business email address, organization name, full username, password, city; your preferences such as language, time zone; the types of communications you would like to receive from us, and image/avatar (if you choose to provide this).
When you make payments through the Service on behalf of a Client, you will need to provide your billing address. In connection with your purchase, we may process the Services you have acquired from us, including the type of subscription plan, add-ons, number of team members, and transaction information related to the Services.
Communications and Interactions
We may collect information through your communications with our customer support team or other communications that you may send us and their contents which may include email messages, text messages, phone calls that we exchange with you, interactive customer support chat sessions, body of contact messages, reviews, responses, survey answers, demo sessions, comments, feedback, ratings and other Usage Data described below in detail.
In order to allow you to post to your social media platforms, we may ask you to provide your username, account ids, social handle, timezones, and email address.
Requesting a Demo
When you request a demo, we may ask you to provide your name, email address and any other content you provide in your demo request.
Subscribing to our Blog
When subscribing to our blog, you are requested to provide your email address.
Applying for a Job
We collect information you choose to provide to us when applying for employment, which may include contact information, education and employment history, credentials, and LinkedIn profile information.
You may also opt-in to submitting information through other methods, including:
b – Personal Information Collected From Third Parties
Social Media Networks and accounts that are authenticated and connected to Juphy by our Clients, who may provide us with posts, followers, engagement metrics, and messages.
If you connect your Social Networks to your Juphy account, we may collect certain information stored in your Social Networks as follows:
We may collect social media handles, profile images, display names, biography, username/page ID or profile ID, access tokens, sent posts, sent or received comments text and sent or received private message text, follower counts, website URL. This includes the content of your post and engagement data and social account’s insight data (such as click rates, likes, re-shares, impressions, as well as general engagement counts), to the extent permitted by applicable law. This data will only be used by Juphy to provide you with the Service you expect and will not be shared with any third parties.
For details on what Personal Information Juphy may collect on behalf of our Clients, please review the section “Juphy as a Service Provider and Processor”.
Juphy uses Service Providers to provide payment processing and associated services. You will be directed to Third-Party payment systems’ services to enter your card and other billing details. Third-Party payment systems may request various payment information from users (credit card number, CVV, first and last name, expiry date, region, etc.).
On completion of payment, our payment processor will provide us with limited payment details (your name, billing address, billing email, card type, expiry date and the last four digits of your payment card number) so that we can manage payment transactions and your account. Full payment details are held securely by these payment processing services that are prohibited from using personal information for any other purpose and are contractually required to comply with all applicable laws and requirements, which may include Payment Card Industry Data Security Standards when they are processing or transmitting payments for Juphy.
In processing payment transactions, the payment processor acts as a data processor to us but in carrying out fraud monitoring, prevention and detection services, it acts as controller and may monitor insights and patterns of payment transactions and other online signals to reduce the risk of fraud, money laundering and other harmful activity.
Juphy shall not store nor disclose any financial information provided by users to Third Party entities.
We use Third-Party Service Providers to provide certain Services on our behalf when the information is necessary for them to perform their duties.
The Third-Party Service Providers (our Sub-processors) to help us better operate our Website and Platform and for services such as hosting, maintenance, error monitoring, debugging performance monitoring, customer service, database storage and management, SEO services, user onboarding, email automation, product and Client tracking, heat-map and live chat tracking. In some cases, these Service Providers may process or store personal information while providing services. When those Service Providers receive access to personal information, they undergo a security and privacy review to ensure they meet the necessary safeguards and implement ‘the best practice’ in their data processing activities. We are also committed to providing that they are contractually bound by a data protection/processing agreement that requires them to comply with applicable regulations, including having the appropriate access controls in place to protect your data.
We also may use Third Party advertisements, analytics, and tracking tools to better understand who is using the Website, how people are using the Website/Platform, how to improve the effectiveness of the Services, related content, and our products, and to help us or those Third Parties serve more targeted advertising to you across media channels. These Third Parties may use technology such as cookies, web beacons, pixel tags, log files, flash cookies, or other technologies to collect and store information. They may also combine information they collect from your interaction with the Website/Platform with information they collect from other sources, which combination may be subject to the Third Party’s control and privacy practices thereupon. For further details on how these cookies are used please refer to our Cookie Notice.
c – Cookies and Automatic Collection Methods
We may also collect information about your online activities on the Website/Platform and connected Devices over time and across Third-Party websites, devices, apps, and other online features and services. For example, when you use automated chat functionality (chatbots) to make an inquiry, provide feedback, or make another request, we may collect information about you such as your name and email address, your specific feedback or request, and information related to your use of our Services.
This collection includes automatically collected information, and generally does not include personal information unless you provide it through our Website/Platform or you choose to share it with us by other means. Methods we use are described below:
These technologies record information about your usage of our Website and Platform, including:
We use web log analysis software (Google Analytics etc.) on our Website and Platform to help us analyze your use of our Website and Platform and diagnose technical issues.
While using our Service, in order to provide features of our Website/Platform, we may collect, with your prior permission, pictures, files and other information from your Device’s contacts, camera, voice recording/photo library. We use this information to provide features of our Service. The information may be uploaded to Juphy’s servers and/or a Service Provider’s server or it be simply stored on your Device. For example, when you want to upload a profile photo, we will ask your prior permission to access your Device camera. You can enable or disable access to this information at any time, through your Device settings.
7 – How Juphy Uses Personal Information
a – Our Website, Platform and Services
We rely upon several legal grounds to ensure that our use of your personal information is compliant with the applicable law. Most commonly we will use your personal information in the following circumstances:
Purposes for which we will use your personal information;
The purposes for which we will process your personal information and the lawful basis of processing on which we rely are described below:
Pre-contractual, contractual and post-contractual business relationships. We process personal information to enter business relationships with prospective Clients and their respective Authorized Users, as well as the Website Visitors, and to perform the contractual obligations under the contacts that we have with them. Activities that we conduct in this context include:
Lawful basis for processing
to register you as a user of our Platform and create your account so that you may access our Services
Performance of a contract with you
to manage account authentication such as two-factor authentication
Performance of a contract with you
to communicate with you to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance, including by periodically emailing you service-related announcements
Performance of a contract with you
to provide the functionality of our Services that you have requested via our sites;
Performance of a contract with you
for accounting and billing activities
Performance of a contract with you
to administer and support the Services you have requested including to send service notifications, manage and support the provision of your services, to manage payments and to exercise our legal rights
Performance of a contract with you
to manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy notice
(b) Asking you to update your information
(c) Dealing with any issues or feedback you may have or asking you to complete a survey
Performance of a contract with you
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our records updated, to manage and improve our services and the efficient running of our business)
Legal and regulatory compliance. We use personal information to verify the identity of our Users in order to comply with laws. These obligations are imposed on us by the operation of law, industry standards, and by our financial partners, and may require us to report our compliance to Third Parties and to submit to third-party verification audits.
Lawful basis for processing
for accounting, auditing, and billing activities
Legal and regulatory compliance
to respond to court orders, lawsuits, subpoenas, and government requests
Legal and regulatory compliance
to address legal and regulatory compliance
Legal and regulatory compliance
Legitimate business interests. We rely on our legitimate business interests to process certain personal information concerning you. The following list sets out the business purposes that we have identified as legitimate. In determining the content of this list, we balanced our interests against the legitimate interests and rights of the individuals whose personal information we process.
Lawful basis for processing
to mitigate financial loss, claims, liabilities, or other harm to Users or and Juphy
Legitimate business interest
to respond to inquiries, send service notices, and assist communications with the Clients and their Authorized Users
Legitimate business interest
to promote, analyze, modify and improve our products, systems, and tools, and develop new Services
to manage, operate, and improve the performance of our Website, Platform and Services by understanding their effectiveness and optimizing our digital assets
Legitimate business interest
to analyzing and advertise our Services
Legitimate business interest
to follow up sales leads whether sourced by way of sign-up to a trial, demo request or request for information, by third party lead or from internal research
Your consent (if your consent is required)
Legitimate business interest (to qualify sales leads and to make sales of our products and services to grow our business)
to conduct aggregate analysis and develop business intelligence that enables us to operate, protect, make informed decisions, and report on the performance of our business
Legitimate business interest
to share personal information with Service Providers that provide services on our behalf and business partners who help us operate and improve our business
Legitimate business interest
to ensure network and information security, administer, protect and manage our business and websites (including troubleshooting, business operational analysis, testing, system maintenance, support, reporting and hosting of data)
Legitimate business interest (for running our business, provision of administration and IT services, business performance analysis, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)
to protect the security or integrity of our Services and business, such as by protecting against and preventing fraud, unauthorized transactions, claims and other liabilities, and managing risk exposure, including by identifying potential hackers and other unauthorized users
Legitimate business interest
Based on Your Prior Explicit Consent. We rely on your prior explicit consent to process your personal information for the purposes below:
Lawful basis for processing
to send you marketing and commercial emails
to including you to our newsletter
for interest-based advertising activities
b – Marketing and Events-related Communications
We may send you marketing communications about Juphy and its Services, invite you to participate in our events or surveys, or otherwise communicate with you for marketing purposes, and to customize the marketing and advertising that we provide to you (we offer choices about marketing and advertising as set forth below) provided that we do so in accordance with the consent requirements that are imposed by Privacy and Electronic Communications Regulations (“PECR”) and other applicable law.
In order to provide you with all of the benefits of our Service, we ask for your permission to send you information about the latest news, special events, offers, promotions and other benefits. We also ask for your permission to send you, our newsletter. Upon your consent, we will use your email address to contact you with this information.
When we collect your business, contact details through our participation at trade shows or other events, we may use the information to follow-up with you regarding an event, send you information that you have requested on our products and Services, and upon your explicit consent, include you on our marketing information campaigns.
If you decide at any time that you no longer wish to receive such marketing communications from us, please follow the unsubscribe instructions provided in any of the communications. You may also opt-out from receiving commercial emails from us by sending your request to us by email at email@example.com.
To update your preferences, ask us to remove your information from our mailing lists, delete your account or submit a request to exercise your rights under applicable law, please contact us as specified in the “Contact Juphy” section below.
c – Interest-based Advertising
When you visit our sites, both certain Third Parties and we collect information about your online activities over time and across different websites to provide you with advertising products and services tailored to your individual interests (this type of advertising is called “interest-based advertising”). These Third Parties may place or recognize a unique cookie or other technology on your browser. Where required by applicable law, we will obtain your consent prior to processing your information for interest-based advertising.
Since we also participate in advertising networks, you may see our ads on other websites or mobile apps. Ad networks allow us to target our messaging to users based on a range of factors, including demographic data, users’ inferred interests, and browsing context (for example, the time and date of your visit to our Website and Platform, the pages that you viewed, and the links that you clicked on). This technology also helps us track the effectiveness of our marketing efforts and understand if you have seen one of our advertisements.
We work with advertising networks (Google, Facebook, etc.). To learn more about managing your privacy and storage settings and opting out from receiving Network Advertising Initiative member companies ‘cookies, please visit the Network Advertising Initiative’s opt-out page at here. If you wish to prevent your data from being used by Google Analytics, Google has developed the Google Analytics opt-out browser add-on available at here. If you opt-out from interest-based advertising, you may see advertising that is not relevant to you.
To learn more about managing your privacy and storage settings and opting out from receiving other Third Parties’ cookies, please see our “Exercising of Your EU & UK Privacy Rights” and “Exercising of Your California Privacy Rights” sections.
We do not guarantee that all of the Third Parties we work with will honor the elections you make using those options, but we strive to work with Third Parties that do.
d – Social Networks and Third-Party Integrations
We offer parts of our Service through websites, platforms, and services operated or controlled by separate entities. In addition, we integrate technologies operated or controlled by separate entities into parts of our Website, Platform and Service. Some examples include:
Our Website, Platform and Service includes links that hyperlink to websites, platforms, and other services not operated or controlled by us.
Liking, Sharing, and Logging-In
We may embed a pixel or SDK on our Website, Platform and Service that allows you to “like” or “share” content on, or log-in to your account through social media. If you choose to engage with such integration, we may receive information from the Social Network that you have authorized to share with us. Please note that the Social Network may independently collect information about you through the integration. These widgets may collect information such as your IP address and the pages you navigate on the website and may set a cookie to enable the widgets to function properly. Your interactions with these widgets are governed by the privacy policies of the companies providing them.
Brand Pages and Chatbots
We may offer our content through social media. Any information you provide to us when you engage with our content (such as through our brand page) is treated in accordance with this Policy. Also, if you publicly reference our Service on social media (e.g., by using a hashtag associated with Juphy in a tweet or post), we may use your reference on or in connection with our Services.
8 – How Juphy Shares Personal Information
Juphy does not rent or sell your information. We restrict access to your information to authorized employees and we do not share your information with Third Psarties except in the circumstances explained below.
Employees and Authorized Contractors
Our employees and authorized contractors may need to access information about you when they require this information to perform their job. For example, a customer support representative would need access to your account to validate your identity and respond to your question or request; our email communications team would need access to your contact information to ensure this information is sent correctly and any unsubscribe requests are properly managed; and our security staff would need to review information to investigate attempted denial of service attacks, fraudulent account activity, or other attempts to compromise the Services. All our employees and contractors are required to agree to maintain the confidentiality and protect the privacy of your information.
Social Networks and Third-Party Services
By its nature, social media data can be shared with people around the globe. The Social Networks and Third-Party Services that you choose to integrate with our Services may collect, store, and process your information from various locations around the world according to their own terms and privacy policies.
Service Providers and Business Partners
Without prejudice to the foregoing, we share personal information with a limited number of our Service Providers. We have Service Providers that provide services on our behalf, such as website hosting, data analysis, information technology, and related infrastructure, customer service, email delivery. These Service Providers may need to access personal information to perform their services. We authorize such Service Providers to use or disclose personal information only as necessary to perform services on our behalf or comply with legal requirements. We require such Service Providers to contractually commit to protect the security and confidentiality of personal information they process on our behalf. These Third- Party Service Providers may process or store personal data on servers outside of the EEA, UK, and Switzerland, including in the US. We rely on standard contractual clauses (if sent to the US or onward to other countries) to ensure that information about you is lawfully transferred under EU law. In this case, we have implemented supplementary measures as outlined in the Section 13 “How Juphy Protects Your Personal Information”.
Sub-processors and Client Content
We limit the number of Service Providers who are permitted to process Client Content for the purpose of assisting us in delivering the Services. We refer to these service providers as “sub-processors” and they are listed on here. Our service providers are predominantly located in the European Union and the United States of America.
When sharing your information with any of the above, we ensure they agree to obligations consistent with this Policy and any other appropriate confidentiality and security measures, and only use your information to carry out the Services and your requests.
Where your employer or an entity has purchased Services on your behalf, we may disclose information about you such as your name and email address, image/avatar (if you have any) and some usage information including whether a user has logged in to the Service, frequency of login, time spent using the Services, and enrollment and analytics to assist your employer or the entity in managing its use and maximizing the value of the Services.
Law Enforcement, Government Agencies, and Professional Advisors
We also use professional advisors, including lawyers and accountants, and may be required to disclose information about you when engaging them for their services and as necessary for audits, financial and other regulatory reviews.
We may disclose information in the aggregate form to Third Parties relating to user behavior in connection with the actual or prospective business relationship with those Third Parties, such as advertisers and content distributors.
9 – Juphy as a Service Provider and Processor
As part of our Services, we provide our users with an interface and software tools to carry out communication, manage their customer experience and marketing functions, including social media integration and engagement, advertising, benchmarking, research, and customer care support. In order to provide our Services, Juphy allows our Clients to, for example:
Where you are using our Services and making decisions about the personal information that is being processed in the Services (including selecting the Social Networks you wish to connect to the Services, or uploading and using Client Content), you, as a Client, are acting as a data controller and Juphy is acting as a data processor.
As a data processor, Juphy will only access and process Client Content to provide you with the Services in accordance with your instructions (which you provide through the Services), the Terms of Service, the Social Networks’ terms, and applicable laws.
When our Clients process personal information through our Services, they are responsible for ensuring that they do so in compliance with the law, including providing their Customers and users with transparent notices. Our Clients are also responsible for validating any integrations they enable through our Services, as well as ensuring that their use of publicly available personal information complies with the terms of the Social Networks or Third Party Integrations or websites the personal information is obtained from.
Where Juphy is a service provider and processor for our Clients, our Client’s privacy policies, rather than this one, will be applicable to the personal information processed, and we direct individuals to review those policies if they have any questions around how their data is obtained or processed within the Juphy Services.
Juphy’s processing activity as a service provider and processor is governed by the contracts we have with our Clients, including our Terms of Service and Data Processing Addendum (DPA) which includes limits on our processing and defines how we secure and protect the personal information we process for our Clients. Under the terms of those agreements, we will direct any data subject request you make to Juphy for personal information that we process as a processor under this section to our Clients.
By executing our Services, we process all data that our users place on Social Networks through Juphy or receive from those Social Networks. However, due to the terms for integrating Juphy with Social Networks, each of our users (or their associates) holds their accounts within the Social Networks. The social media platform operator is also a data controller based on a separate agreement concluded directly between the operator and the user (or their associate). Hence, within the scope of this data transfer, we only act as a passive intermediary tool by transferring this data between the user (or their associates) and the operators of those social media platforms. These information include;
If you, as a data controller, require Juphy to agree to data protection requirements under Article 28, GDPR Juphy makes available a data processing addendum that meets these requirements at here.
If you are using the Services as an Authorized User of a Client (whether that Client is your employer, another organization, or an individual), that Client determines its own policies (if any) regarding storage, access, modification, deletion, sharing, and retention of personal information and Client Content, which may apply to your use of the Services. Please check with that Client about the policies and settings it has in place.
Data Subject Requests
If you believe that we store, use or process your information on behalf of one of our Clients, please contact the Client if you would like to access, rectify, erase, restrict or object to processing, or export your personal information. We will extend our support to our Client in responding to your request within a reasonable timeframe.
Data Processing Addendum
To enable you to be compliant with your data protection obligation, we are prepared to sign an appropriate Data Processing Addendum (DPA). You can request a DPA from Juphy by emailing at firstname.lastname@example.org. Once we get your request, we’ll forward the DPA to you for your signature.
10 – Your Communication Choices
Legal Communications and Service Announcements
By providing Juphy with your email address and/or using the Website/Platform you affirmatively consent to use of your email address for legal and service notifications or Juphy to send you notifications through pop-ups and etc. regarding important service announcements and other legal and administrative communications related to your use of the Website/Platform. We may send the following to you by email or posting them on the Website/Platform; this Policy, our Terms, Applicable Use Policy, including legal disclosures; future changes to this Policy, Terms, and other notices, legal communications or disclosures and information related to the Services. Such communications are part of the Services which you cannot opt out of receiving. However, if you do not wish to receive certain service and other administrative and legal notifications, your only way to opt out of such messages is to stop using the Website and/or (if any) delete your account on the Platform.
You may receive marketing and advertising communications (e.g., sending your blog posts, informing you of Service benefits and features, letting you know of new features or developments, letting you know of new subscription plans or add-ons, offering you promo codes or coupons, or presenting you with the opportunity to buy selected subscription package) about Juphy, Website, Platform and Services, pursuant to your prior explicit consent. To receive marketing and advertising communications from Juphy, you can subscribe to our newsletter, contact our customer service, support assistant, or give your explicit consent in the applicable areas. Due to our global privacy practices, we provide our Users with the opportunity to “opt-in” and “opt out” of receiving marketing and advertising communications other than those for purposes directly related to your transactions with us and in general legal and administrative communications regarding your account.
If you prefer to opt-in to Promotional Communications, you may receive periodic promotions and other offers or materials that we believe might be of interest to you until you unsubscribe or opt-out.
Withdrawing Your Consent
If you later decide that you do not want to receive future Promotional Communications electronically, you may withdraw your consent. You can opt-out Promotional Communications at any time (i) by following the instructions described in this Policy; or (ii) following the unsubscribe instructions contained in each message; or (iii) (if applicable) changing the communication preferences in your account through your Account Dashboard. In all cases you may email us at email@example.com. Your withdrawal of consent shall be effective within a reasonable time after we receive your withdrawal notice described above.
11 – European Union and UK Privacy Information
Your Rights and Choices Under the UK & EU GDPR
Juphy undertakes to respect the confidentiality of your Personal Data and to guarantee you can exercise your rights.
Juphy makes available a data processing addendum that addresses European Union and UK Privacy Laws at here.
Exercising of Your UK & EU GDPR Privacy Rights
You may exercise your rights of access, rectification, cancellation, and opposition by simply contacting us. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. If You are a resident of United Kingdom, You may complain to Information Commissioner’s Office (ICO) regarding your data protection rights. If you are a resident in the European Economic Area (EEA), please contact your local data protection authority in the EEA.
12 – California Privacy Information
If you are a Consumer as defined in the California Consumer Privacy Act (CCPA) and as amended by the California Privacy Rights Act (CPRA) (collectively, “California Privacy Laws”), the following provisions apply to you.
Juphy makes available an addendum that addresses California Privacy Laws at here.
Do Not Sell My Personal Information
“Sale” means renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for monetary or other valuable consideration. We do not provide personal information about you to Third Parties in exchange for money. We do share personal information with Third Parties that we work with, including to help us market or advertise our products and Services to you and mostly with regard to your prior consent. When this information is in a format that directly identifies you by name, it is not shared with any Third Parties for Third-Party marketing or advertising purposes. You can find more detail about our practices in our Policy, set forth under “Interest-based Advertising” section.
Even though we do not provide personal information to these Third Parties in exchange for money, the CCPA may characterize our providing the following categories of information we share with Third Parties that provide services to you or to us, such as personalizing your experience with us or helping us to market or advertise our products and Services to you, as “sales” of personal information; (i) Device and browsing information and other internet activity information; (ii) purchase or other commercial information; and (iii) identifiers (e.g., ad ID).
The Service Providers we partner with (for example, our advertising partners) may use technology on the Service that “sells” personal information as defined by the CCPA. If you wish to opt out of the use of your personal information for interest-based advertising purposes and these potential sales as defined under CCPA, you may do so by following the instructions below;
You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Service:
The opt out will place a cookie on your computer that is unique to the browser you use to opt out. If you change browsers or delete the cookies saved by your browser, you will need to opt out again.
Please note that any opt out is specific to the browser you use. You may need to opt out on every browser that you use.
Your mobile device may give you the ability to opt-out of the use of information about the apps you use in order to serve you ads that are targeted to your interests:
You can also stop the collection of location information from your mobile device by changing the preferences on your mobile device.
“Do Not Track” Policy as Required by California Online Privacy Protection Act (CalOPPA)
Some internet browsers have enabled ‘Do Not Track’ (DNT) features, which send out a signal (called the DNT signal) to the websites that you visit indicating that you don’t wish to be tracked. Currently, there is no standard that governs what websites can or should do when they receive these signals. For now, we do not take action in response to these signals. However, some third-party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.
California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)
California Business and Professions Code section 22581 allow California residents under the age of 18 who are registered users of online sites, services, or applications to request and obtain removal of content or information they have publicly posted.
We do not knowingly process personal information of California residents under the age of 18. If you have reason to believe that anyone under the age of 18 has provided us with any personal information, please contact us at firstname.lastname@example.org.
Be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
Your Rights and Choices Under California Privacy Laws
Exercising Your California Privacy Rights
In order to exercise any of your rights under the CCPA, as a California resident, you can contact us through channels, features, and functionalities (i.e., email address, interactive support assistant) provided on the Website and Platform.
Once we receive your request, we will validate the information that you provide and send a message to the email address you provide in the request, asking you to verify that it is your email address. Please follow the instructions in that email to verify your email address. We will begin processing your request once the verification is completed.
Juphy will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.
Please note that if you do not include necessary information concerning you in your requests, we may ask you to verify your identity before responding to such requests.
PLEASE NOTE THAT if personal information about you has been processed by us as a service provider on behalf of a Client and you wish to exercise any rights you have with such personal information, please inquire with our Client directly. If you wish to make your request directly to us, please provide the name of our Client on whose behalf we processed your personal information. We will refer your request to that Client.
13 – How Juphy Protects Your Personal Information
We are making reasonable efforts to provide you with an appropriate level of security at the risk associated with the processing of your personal information. We employ organizational, technical, and administrative measures designed to appropriately protect your personal information against unauthorized access, destruction, accidental loss, unauthorized alteration, or abuse. Your personal information may only be accessed by a limited number of personnel who need access to such information in order to perform their duties. Please be aware that no security measures are perfect or impenetrable. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If You have a reason to believe that your interaction with us is no longer secure (for example, if You think your account is compromised), please contact us immediately.
We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored personal information to you via email or conspicuous posting on our Website or Platform in the most expedient time possible and without unreasonable delay, consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system, and any other disclosures that may be required under applicable law. We also take measures to delete your personal information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period. When determining the retention period, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, possible re-enrollment with our products or services, the impact on the services we provide to you if we delete some information from or about you, mandatory retention periods provided by law and the statute of limitations.
We encrypt data in transit and at rest, where appropriate, to ensure that your information is kept private. We undertake service provider security and privacy reviews to ensure that Service Providers follow our stringent requirements to safeguard your information, and we also enter into data protection agreements with our service providers. All payment information is fully encrypted and handled only by PCI certified organizations.
14 – Retention
Your personal information may be retained for as long as is reasonably necessary to perform the purposes listed under “How Juphy Use Personal Information” section. For example, if you register an account, we will store any personal information associated with your account for as long as you remain a registered User or we believe we may be in a position to provide Services to you.
Once you or we terminate your Juphy user account, your data will eventually get deleted from active database during the next clean-up that occurs once in 6 months. The data deleted from active database will be deleted from backups after 3 months.
We retain personal information after we cease providing Services to you, even if you close your account, to the extent necessary to comply with our legal and regulatory obligations. We also retain personal information to comply with our tax, accounting, and financial reporting obligations, where we are required to retain the data due to our contractual commitments to our financial and business partners, and where data retention is mandated by the applicable laws. Where we retain data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law.
The servers and databases in which information may be stored may be located outside the country from which you accessed our Services and, in a country, where the data protection and other laws may differ from your country of residence. Your personal information may be disclosed in response to inquiries or requests from government authorities or to respond to judicial process in the countries in which we operate.
Aggregated data is used by Juphy for analysis, product improvement, and troubleshooting purposes. In some cases, Client Content may continue to exist on the Social Networks even after you or we delete it from our Services, and you will need to contact the relevant Social Network directly if you want it to remove this Client Content.
15 – International Data Transfers
Your personal information will be processed by us in the European Economic Area (EEA). Some of your personal data may be transferred, stored and/or processed outside of the EEA and UK as our Sub-processors sometimes operate from outside of these jurisdictions.
In some cases, in particular when Juphy uses the Sub-processors who support Juphy in its business activities, the personal data may also be accessed or processed outside the EEA and UK. When personal information we collect is processed outside the EEA or UK we have obligations to ensure that personal information is only processed outside the EEA or UK where the European Commission has decided that the territory in question ensures an adequate level of protection (known as a ‘whitelisted’ territory) or, in the absence of a decision by the European Commission, there are appropriate safeguards in place to protect your personal data.
For example, if your personal data is accessed or processed from a territory outside the EEA which is not whitelisted, the appropriate safeguards may be provided by standard data protection clauses adopted by the European Commission (known as ‘standard contractual clauses).
We will only transfer your data outside of the UK and the EEA in compliance with data protection laws and provided appropriate or suitable safeguards are in place to protect your data, Standard Contractual Clauses.
Personal information may be stored and processed in any country where we have operations or where we engage service providers. We may transfer personal information that we maintain about you to recipients in countries other than the country in which the personal information was originally collected, including to the United States. Those countries may have data protection rules that are different from those of your country. However, we will take measures to ensure that any such transfers comply with applicable data protection laws and that your personal information remains protected to the standards described in this Policy. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access your personal information.
16 – Use by Minors
The Services are not directed to individuals under the age of eighteen (18), and they shall not provide personal information through the Services. If you have reason to believe that anyone under the age of 18 has provided us with any personal information, please contact us.
17 – Updates to this Policy and Notifications
18 – Links to Other Websites
The Services may provide the ability to connect to other sites. These sites may operate independently from us and may have their own privacy notices or policies, which we strongly suggest you review. If any linked website is not owned or controlled by us, we are not responsible for its content, any use of the website, or the privacy practices of the operator of the website.
As a safety measure, we recommend that you not share any personal information with these third parties unless you’ve checked their privacy policies and assured yourself of their privacy practices.
19 – Jurisdiction
Juphy focuses on multinational compliance regulations including but not limited to the United States federal and state data privacy laws, General Data Protection Regulation brought by the European Union (“GDPR”), United Kingdom General Data Protection Regulation (“UK GDPR”), California Privacy Laws and other jurisdictions with data protection legislation to make sure privacy is a “go-to” rather than a thing to be worried. You have the right to request further information on our personal data processing activities based on your country’s laws.
20 – Contact Juphy
If You have any questions or complaints about this Policy, or if you wish to exercise your rights under applicable data protection laws, please feel free to contact us by;