Privacy Policy

Effective as of December 22, 2022 Jot Technology Solutions Inc. (“Jot Tech” or “we” or “us” or “our”) have updated our Privacy Policy (“Policy”).

 

Consent

IF YOU DO NOT AGREE WITH ANYTHING CONTAINED IN THIS POLICY, DO NOT USE JOT TECH’s PRODUCTS OR SERVICES, INCLUDING THE JOT™ APP.  

YOUR CONTINUED USE OF JOT TECH's PRODUCTS OR SERVICES IS CONSIDERED CONSENT TO THE USES OF YOUR PERSONAL INFORMATION AS DESCRIBED IN THIS POLICY, INCLUDING THE CROSS-BORDER TRANSFERS OF SUCH INFORMATION (AS DETAILED BELOW IN SECTION 5).

 

User Data Privacy - Background

Jot Tech provides its users (“Users”, “you”, “yours”) in Europe, the UK and North America with a mobile application for professionals to manage their contacts and relationships.  With the Jot™ App, Users have power and control over their own data.

Maintaining the privacy of Users’ data is an important priority of Jot Tech’s data management activities.  As a data processor, Jot Tech implements and maintains technical and organizational measures designed to keep User data secure and private.  User data is processed according to the User’s chosen settings for the functionality of the Jot™ App and the app’s ongoing improvement.

IF WE DECIDE TO CHANGE OUR PRIVACY POLICY, WE WILL PROVIDE ADVANCE NOTICE AS SET OUT IN THIS POLICY SO THAT YOU ARE AWARE OF WHAT PERSONAL DATA WE COLLECT, HOW WE USE IT AND UNDER WHAT CIRCUMSTANCES WE DISCLOSE IT.

NOTWITHSTANDING THE OTHER PROVISIONS OF THIS POLICY, (i) JOT TECHNOLOGY SOLUTIONS INC. RESERVES THE RIGHT TO DISCLOSE ALL INFORMATION, INCLUDING PERSONAL DATA, TO REGULATORY AUTHORITIES, LAW ENFORCEMENT AGENCIES OR AS REQUIRED BY APPLICABLE LAW, AND (ii) JOT TECHNOLOGY SOLUTIONS INC. MAY ALSO USE YOUR INFORMATION, INCLUDING PERSONAL DATA, AS PERMITTED BY LAW TO ENFORCE OUR RIGHTS AND TO PROTECT: OUR RIGHTS OR PROPERTY INCLUDING THE JOT™APP, OUR SERVICES, AND/OR OUR OTHER USERS.

Certain Definitions

Please note that “including”, the phrases “e.g.,” or “for example” and any derivatives of any of the foregoing mean “including, without limitation”; and the examples provided should not be considered to be all-inclusive or limiting.

For the purposes of this Policy, “personal data” (sometimes referred to in legislation and this Policy as “personal information” or "PII") means information or data relating to an identified or identifiable natural person (i.e., an individual).  A natural person is considered identifiable if they can be identified directly, or indirectly, by reference to an identification number or to one or more factors that can indicate their identity.

Any capitalized terms not defined in this Policy have the meanings in our Terms of Use.

 

1. Introduction

This Policy describes how we collect, use and disclose personal data when you use the following:

· any website(s) that Jot Tech operates and which display or link to this Policy (“website(s)”), including www.jottech.app  

· the Jot™ App, which is a mobile application that is available to Jot Tech registered Users after they have accepted the Jot Tech Terms of Use.  The Jot™ App is installed on the User selected device(s), and enables a User to manage their contacts and relationships within the Jot™ App capabilities.

Our website(s) may contain links to other websites that are operated by third parties.  This Policy does not apply to those websites.  We strongly suggest that you carefully review the privacy policies and statements of any third-party websites to properly understand their information practices.

 

2. Information Provided to or Collected by Jot Tech

Registering as a User

In order for the Jot™ App to function after you download it from the Apple App Store or Google Play you must set up a Jot™ App account with at a minimum the mandatory personal data noted below.

To use the Jot™ App, a User must (mandatory) set up an account and provide us with the following:

· First name

· Last name

· Phone number

· Email address

· A username of their own choice (provided it is unique within the Jot™ App (“JotID”)

           

In addition, at the User’s option they may (optional) enter the following:

· Picture

· Job title

· Company

· Address

· Website

· Additional phone number(s)

· Additional email address(es)

 

A User can log in to the Jot™ App as follows depending on which email they have added in their registration,

(1) directly in the Jot™ App, or

(2) through Google using their Google email address, or

(3) through Facebook using the email address registered to their Facebook account, or

(4) through Apple (iOS devices only) using the email address registered to their Apple ID or using their private email relay provided by Apple.

If you sign into the Jot™ App through Apple, Facebook or Google, the use of such feature is governed by the privacy policies of the feature owner (i.e., as applicable, Facebook, Apple or Google).

 

Payment

When you upgrade to Jot Tech’s Premium Package, either Google or Apple will handle all payment information for this option.  Jot Tech, however, does get confirmation of your payment using the personal data that you have associated with your Jot™ App account from Google or Apple as applicable.  Jot Tech uses this to provide you with access to the features of the Premium Package.

 

Jot Tech Website(s) and the Jot™ App Tracking/Usage

We and our authorized service providers may also collect information using cookies and other information gathering technologies for a variety of reasons.

The Jot Tech website(s) may also use web beacons, tags, and scripts or use them in email or other electronic communications we send to you.  These assist us in sending cookies and counting visits to our website(s) while helping us understand usage and the effectiveness of promotions.  Furthermore, we may receive and develop reports based on the use of these technologies by our third-party service providers on an aggregated basis.  For more information on how we use cookies, web beacons, tags, and scripts, please review our COOKIE POLICY.

We collect information about your activities on the Jot Tech website(s) and the Jot™ App using the following applications: 

• Google Firebase

• Amazon S3

• Amazon Document DB

• Amazon EC2

• Amazon CloudFront

• Plivo

• Sendbird

• Segment

• MongoDB

• Realm

Note:  All of the above listed companies are sub-processors of data for the Jot™ App except for Google Firebase and Realm.

We collect personal data from our website(s) and the Jot™ App in the event you use the interactive features of the website(s), for example participating in surveys or providing comments.

If you provide feedback or seek support in your use of the Jot™ App, we will collect certain personal data about you, including that which you include in your comments.

When you download the Jot™ App to your device, the Jot™ App will collect information about your device, such as the version of its operating system.

As you use the Jot™ App, we track your use of features and functions.  For example, we track the number of contacts that you add, your use of email verifications, your requests for Jot User contacts and number of referrals for new Users that may you provide us using the Jot™ App.

If you contact us through the Jot Tech website(s) via the Contact Us page, you are providing your consent for us to use your information for the purpose that you contacted us and share it with certain Jot Tech service providers so that we can properly respond to your inquiry.

User’s Contact Data

Jot Tech’s Jot™ App is comprised of software that can be installed on a mobile device that enables Users to collect contact information from individuals and to record other useful information such as how you met, notes from your meetings and interactions, action items to be completed and more (“Contact Data”).

Contact Data entered by a User is stored by the Jot™ App and is encrypted and transmitted to the cloud hosted database through the User’s Wi-Fi or Cellular data (as chosen by the User) and stored on encrypted cloud servers.  For more information, see the Jot Tech Terms of Use.

Please note that to the extent such Contact Data includes personal data related to your contacts, you are the controller of that data and you are solely responsible for complying with any laws and regulations that apply to your collection and use of your contacts personal data, including personal data you collect about them from using Jot™ App’s functionality.

 

3. Jot Tech’s Use of Personal Data

WE DO NOT SELL YOUR PERSONAL DATA TO THIRD PARTIES.

When you are using the Jot™ App the personal data associated with your Jot™ App account is used as follows:

Jot Tech’s Support

We use your personal data entered into or collected through the Jot™ App or our website(s) to provide Users with our services and support.  In this regard we may associate your Jot ID with your device data to enable us to provide customer support.  When you provide details of your use of the Jot™ App in order to engage our customer support, we will use that personal data to render support to you.  Similarly, when you provide feedback, we may use the personal data you provide to communicate with you about your feedback. 

We use your personal data associated with payment for the Premium Package to provide you the additional features of that option.

Support does include communicating technical notices, updates, security alerts, and administrative messages related to the Jot™ App.  You cannot opt out of receiving technical notices, updates, security alerts, and administrative messages in respect of the Jot™ App.  These are required for the functioning of the Jot™ App.

Jot™ App Functionality and Improvement

We use your personal data to provide and support the interactive features of the Jot™ App.  When another Jot User requests your Jot ID contact information, we use your Jot ID to inform you of the request and enable you to authorize the sharing of your personal data with the requesting Jot User.

We use your personal data to provide and support certain features of the Jot™ App, including those that are subject to availability limits such as the number of contacts you add in a month (limited if you are a Basic Plan Jot™ App User) and your use email verification (available at set intervals for Premium Plan Jot™ Users).  We use this personal data and your Jot ID to communicate with you about the feature, its limits and your ability to remove limits through upgrading your plan or to re-access the feature after a lapse of time.  We may also use this data to provide you support in using these features.

We may aggregate the personal data you provide for customer support or feedback purposes or personal data that we collect (so it can no longer be linked to you) for the purpose of maintaining, improving and promoting the Jot™ App.  We use the aggregated personal data to monitor and analyze trends, usage, and activities in connection with our website(s) and the Jot™ App generally in respect of all users.  This enables us to recognize and address common issues, trends and preferences.  It also assists us in planning upgrades and developing features for future releases of the Jot™ App and updates on our website(s).

Promotional Materials

Where permitted by applicable law, we may also send you promotional communications from time to time to inform you about Jot Tech products, services, features, surveys, offers, or promotions.

In this regard, if you provide us with contact details about a person as a referral through the Jot™ App, we will use it to send to that person information about the Jot™ App.

You can opt out of marketing communications at any time by contacting us or by following the unsubscribe or opt-out instructions included in marketing communications. 

Again, you cannot opt out of receiving technical notices, updates, security alerts, and administrative messages in respect of the Jot™ App.  These are required for the functioning of the Jot™ App.

Data in the Jot™ App

When you enter data, we process it and any personal data contained in it in accordance with your User preferences as chosen by you in the Jot™ App.

Other Use

The Jot™ App has certain features that you can choose to use, and when you choose to use them you are consenting to our using your personal data in order to communicate about the features and to administer them. 

We use your personal data to investigate and prevent fraudulent transactions, unauthorized access to the Jot™ App, and other illegal activities.  We may also use personal data for any other purpose for which we have obtained your consent or where permitted or required by applicable law.

To the extent that personal data about you may be inferred from information collected from the device you are using the Jot™ App on, we process such personal data in accordance with this Policy.

Jot Tech works diligently on its security policies, application development and data storage and processing.  However, please be aware that other Users to whom you have provided data, including personal data, using the Jot™ App may choose to process and/or store data, including personal data, outside of the Jot™ App.  By using Jot™ App, you acknowledge that your data, including personal data, that you provide to other Users may be processed and/or stored outside of the Jot™ App, and accordingly Jot Tech does not warrant or endorse, nor does it assume nor will it have any liability or responsibility for the data handling, storage or security practices of others.

We maintain technological and organizational measures intended to safeguard your information.

 

4. Sharing of Information

Service Providers

Jot Tech shares data, including personal data, with our third-party service providers that we engage for providing hosting, for maintenance of our website(s) and the Jot™ App, payment processing, analytics, and other services.  We do not allow our service providers with whom we share personal data to use that information for marketing or any other purpose other than in connection with the services they provide to Jot Tech.

The following chart indicates what third-party services providers we use and for what purposes they are processing data for us including in some instances your personal data:

• Google Firebase

• Amazon Document DB

• Amazon S3

• Amazon EC2

• Plivo

• Amazon CloudFront

• Sendgrid

• Facebook SDK

• Google Identity

• The Checker

• Squarespace

• Sendbird

• Mongo DB

• Segment

Complying with the Law and Law Enforcement Requests

In some circumstances, we may receive a request from public authorities to disclose personal data in response to a legally binding request to meet national security or law enforcement requirements.  As applicable, we may disclose personal data to comply with subpoenas, court orders, or legal process, or to enforce our legal rights and defend against legal claims.  In some cases, we may also share personal data if we believe that illegal or fraudulent activity is or has taken place so that we can investigate, prevent, and take appropriate action regarding such activities that may pose a potential threat to the physical safety of any person, violations of our Terms of Use, or to comply with the law.  If your personal data becomes subject to a legal disclosure requirement and we are permitted to do so, we will attempt to notify you of said disclosure, if we have current contact information on file.

 

5. International Transfers of Data

Jot Tech stores data on cloud servers located in Canada operated by Amazon Web Services.  Please note, however, that Amazon Web Services advises that it has cloud servers in countries other than Canada (as noted in their privacy policy).

Accordingly, your personal data and the Contact Data in your database may be stored on servers in Canada (or elsewhere, including the European Union and/or United Kingdom).

Personal Data Transfers outside of the European Economic Area (“EEA”) and the United Kingdom (Applicable to EEA and UK only)

To the extent Jot Tech is a controller of your personal data and you reside in the EEA or the UK, please note the following: we transmit your personal data to an international organization or a country where the data protection laws may not provide a level of protection equivalent to the laws in your jurisdiction as noted above.

As required by applicable law, we will provide an adequate level of protection for your personal data using various means, including, where appropriate:

relying on a formal decision by the European Commission that a certain country ensures an adequate level of protection for personal data;

entering into appropriate data transfer agreements based on language approved by the European Commission, such as the Standard Contractual Clauses, and;

implementing appropriate commercially available physical, commercially available technical and organizational security measures to protect personal data against accidental or unlawful destruction, accidental loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing.

 

6.  Legal Basis for Processing Personal Data (European Economic Area (“EEA”) and United Kingdom (“UK”)

If you are located in the EEA or UK, our legal basis for collecting and using the personal data described above will depend on the personal data concerned and the specific context in which we collect it.

In our normal course, we will only process personal data that (i) has been provided to us by you through the Jot™ App or our website(s).   We will normally collect personal data from you only (i) where we need the personal data to perform a contract with you; (ii) where the processing is in our legitimate interests and not overridden by your rights; or (iii) where we have your consent to do so.  We have a legitimate interest in operating our services and providing our products, and communicating with you as necessary to provide these services and products, for example when responding to your queries, improving our services and products, undertaking our marketing to you (subject to applicable laws), or for the purposes of detecting or preventing illegal activities.

In some cases, we may also have a legal obligation to collect personal data from you or may otherwise need the personal data to protect your vital interests or those of another person.

If we ask you to provide personal data to comply with a legal requirement or to perform a contract (e.g., Terms of Use) with you, we will make this clear at the relevant time and advise you whether the provision of your personal data is mandatory or not (as well as of the possible consequences if you do not provide your personal data e.g., reduced functionality).

 

7. Correcting, Updating, and Removing Your Information

General

Users may change or update the information associated with their Jot™ App accounts by logging into these services and editing their profile.

You may request to have personal data that we maintain returned or removed by contacting us by email as noted below.  Jot Tech reserves the right to validate requests to ensure legitimacy.  Valid requests will typically be handled within 30 days.

An individual who seeks access to, or wishes to correct, amend, or delete inaccuracies in personal data stored or processed by Jot Tech may have to direct such inquiries to the User who has access to the Jot™ App and acts as the data controller i.e. the User who has entered the individual’s personal data into the User’s Jot™ App account as Contact Data.  An individual may, if they do not get a response from the User they have contacted, then make a request to Jot Tech who will act on valid requests within 30 days by itself contacting the data controller User and requesting them to make the corrections or deletion.  

Notwithstanding a request to delete personal data, information (including personal data) will be retained and used as necessary to enable us to comply with our legal obligations, resolve disputes, support our Users, and to comply with and enforce our agreements including our Terms of Use. 

Data Retention

We retain personal data that we store and process on behalf of Users and website(s) visitors for as long as necessary to provide our services.  Information (including personal data) will be retained and used as necessary to enable us to comply with our legal obligations, resolve disputes, support our Users, and to comply with and enforce our agreements including our Terms of Use.

Jot Tech will retain your personal data for as long as needed to fulfill the purposes for which the data was provided.  For personal data that we process on behalf of Users, we will retain such personal data in accordance with the Terms of Use, subject to applicable laws.

Unless otherwise required by law, Jot Tech will retain a User's data and personal data for twelve (12) months after the User's last activity using the Jot™ App.  You may, however, contact Jot Tech to request deletion of your data in a shorter time frame.

Jot Tech will delete or irreversibly anonymize your personal data when we no longer have a legitimate business need for it or in compliance with applicable law.  If it is no longer possible to delete it because, for example, it has been backed up in archives, then we will securely store the personal data and isolate it from further processing until deletion is possible.

Additional Rights for EEA, UK and Certain Other Jurisdictions

If you reside in the EEA, the UK or certain other jurisdictions, you have the right to exercise additional rights available to you under the local law that applies to you:

Right of erasure: you may have a broader right to have personal data that we hold about you erased or deleted.

Right to object to processing: you may have the right to request that Jot Tech stop processing your personal data, but please note that in doing so some of the features of the Jot™ App may no longer function.

Right to restrict processing: you may have the right to request that Jot Tech limit the processing of your personal data in some circumstances (e.g., where you believe that the personal data we hold about you is inaccurate or was obtained unlawfully).

Right to data portability: you may have the right to receive a copy of your data in machine readable, commonly used format and to request that we transfer personal data to another controller.

In the event you would like to inquire about exercising these rights, you may contact us by emailing us at privacyofficer@jottech.app.  In order to protect your privacy and that of others, we may take steps to verify your identity and the validity of your request before we comply.

You also have the right to communicate with a data protection authority about our collection and processing of your personal data.  You may contact your local data protection authority for more information.

 

8. Children’s Personal Data

We do not knowingly or intentionally collect or process any personal data from individuals who are considered a child under applicable data protection laws (“under the age of majority").  If you are under the age of majority, do not submit any personal data through our website(s) or the Jot™ App. Parents and legal guardians are encouraged to monitor their children’s internet use and assist in helping us enforce this Policy by teaching their children never to provide personal data through our website(s) or the Jot™ App.  If you have reason to believe that we may have been sent personal data of a child or person under the age of majority without their guardian’s approval, contact us at privacyofficer@jottech.app and we will use reasonable efforts to delete such information.

 

9. Assignment or Transfer

If we're involved in a reorganization, merger, acquisition or sale of some or all of our assets, your personal data may be transferred as part of that deal or the negotiation of contemplated deals; and we may assign or transfer this Policy as well as your account and related data (including personal data) in accordance with applicable law.

 

10. Changes to This Policy

If we make any changes to this Policy, we will post an updated policy on our website(s) and provide you with an advance notice through the Jot™ App. You should periodically review this page for the latest information on our privacy practices.  The updated Policy will become effective as of the date stated in the Policy and following any additional steps we may be required to take under applicable law.

 

11. How to Contact Us

If you have questions about this Policy or about Jot Tech’s privacy practices, you can contact us by email at privacyofficer@jottech.app.