JAZZ PRIVACY POLICY
Jazz Inc. and our affiliates (“Jazz,” “we,” “us”) are committed to protecting the privacy of the personal information we collect in connection with https://jazz.security/ (the “Website”) and other affiliated platforms or services that link to this policy (collectively, our “Services”). This Privacy Policy describes how we collect, use, share, and protect personal data from and about users of our Services or their devices. If you are located in the European Economic Area (“EEA”) or the United Kingdom (“UK”), we process your personal information consistent with the lawful bases described below. If you do not want your personal data processed as described in this Privacy Policy, please do not use our Services.
- WHAT PERSONAL DATA WE COLLECT & HOW WE COLLECT IT
We may collect the following categories of personal information from and about you:
- Identifiers, such as name, email address, IP address.
- Commercial information, including records of products or services purchased, obtained or considered.
- Internet or other electronic network activity information, such as information regarding your interaction with our online Services.
- Payment information, such as credit or debit card number or other financial information.
- Professional or employment-related information, such as your resume or CV, or other information you may provide when applying for a job with us.
We collect a variety of personal data from or about you or your devices, including:
- Information You Provide to Us Directly, when you:
- Book a Demo or Register for Our Services. If you sign up for our Services, including by booking a demonstration, we collect your full name, email address, company name, job title and any other personal data you provide to us.
- Communicate with Us Electronically. If you contact us directly, including through the Website, we may receive additional personal information about you such as your contact information, the content of your message to us, and any other information you choose to provide. If you subscribe to receive updates from us, then we will collect certain personal data from you, such as your first and last name, email address, and your area(s) of interest. When we send you emails, we may track whether you open them to better understand and improve our Services and customer experience.
- Apply to Work with Us. If you decide to apply for a job with us, you may submit your contact information and your resume online. We will collect your contact information, current and historical employment information, information on your resume or CV, and other information you choose to submit with your application. If you apply for a job with us through a third-party platform (such as LinkedIn), we will collect the information you make available to us through such third-party platform.
- Information We Collect Automatically from Online Interactions. If you engage with our Website, attend a webinar, contact us via social media, or otherwise interact with our business online, including as a representative of a current or prospective customer, supplier or partner, we track and make a record of those interactions, which may contain your contact details, such as full name, email address, messages and any other information that you decide to provide us with, and other information related to:
- Your Device(s). We receive information about the device and software you use to access our Services, including internet protocol (“IP”) address, web browser type, operating system version, internet traffic data, service usage data, and unique device identifiers.
- Your Use of our Services. We automatically receive information about how you use and interact with our Services, such as log files, performance logs, diagnostic reports, the pages or other content you view, the searches you conduct, pages you request, the websites you visited before using our Services, and the dates, times, and durations of your visits. We use this information to better understand engagement and the user experience, and to improve our Services.
- Cookies. We and our third-party partners may collect personal data using cookies, beacons, invisible tags, and similar tracking technologies (collectively, “cookies”) to automatically collect and store information about your device(s) and engagement with our Services. We use this information to better understand how our Services are used, for performance management and analytics purposes, and for functionality management. For more information about how we use cookies, including a list of the cookies that we use, their purpose and retention period, along with information about how to delete them, please visit our Cookie Notice.
Where required by applicable law, we will obtain your consent before using non-essential cookies.
- Information from Other Sources. Jazz may also obtain information about you from other sources, including publicly or commercially available information, and through third-party data platforms, partners, service providers, and its customers (i.e., if you are an employee of one of our customers).
- HOW WE USE PERSONAL DATA
We use and process personal data for the following purposes:
- To Provide, Maintain, Improve, and Enhance Our Services. We will use your personal data to allow you to make full use of our Services, including, (i) if you request a demo, we will use your personal data to process and answer your request for a demo; (ii) to answer your questions and to allow you to communicate with us (e.g., by using the Website chat); (iii) to analyze your use of our Website and to improve our Website; and (iv) to customize your experience.
- For Administrative Purposes. Jazz may use your personal data (i) to respond to your questions, comments, and other requests for customer support or information, including information about potential or future services; (ii) for internal quality control purposes; (iii) to establish and maintain a business relationship; (iv) to conduct research to understand and analyze how you use our Services and develop new products, services, and features; and (v) to generally administer the Services.
- To Market Our Services. Jazz may use personal data to market our Services. Such uses include (i) notifying you about offers and services that may be of interest to you; (ii) developing and marketing new products and services, and measuring interest in the Services; and (iii) otherwise providing promotional and advertising materials that may be useful, relevant, valuable, or otherwise of interest.
- For Security and Compliance Purposes. Some of the abovementioned personal data will be used for detecting, taking steps to prevent and prosecuting fraud or other illegal activity; to identify and repair errors; to conduct audits; and for security purposes. Personal data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and to exercise or defend legal claims.
- For Other Purposes for which we provide specific notice and to which you consent.
We may also anonymize or de-identify your personal data and further use it for internal and external purposes, including, without limitation, to analyze and improve the Services (including through the use of artificial intelligence) and for research purposes. We may use this anonymous or de-identified information or disclose it to third parties without restriction.
Sensitive Personal Data. We do not intentionally collect sensitive personal data through our Services, nor do we use or disclose sensitive personal data for any purpose other than those permitted by applicable law. If we become aware that sensitive personal data has been inadvertently collected, we will delete it unless retention is required by law.
- LEGAL BASES FOR PROCESSING PERSONAL DATA
When required under applicable law, we rely on the following bases to process your personal data:
- Consent. For certain activities, we will obtain your consent to use your personal data. Where we rely on consent, you have the right to withdraw your consent at any time by contacting us at [email protected]. Withdrawing consent does not affect the lawfulness of processing based on consent prior to its withdrawal.
- Contractual Necessity. We may process your personal data where it is necessary for the performance of a contract to which you (or your employer as our customer) are a party or in order to take steps at your (or your employer’s) request prior to entering into a contract, such as your request (or that of your employer as our customer) for more information or to sign up for a trial, which may require the processing of personal data like contact information.
- Compliance with a Legal Obligation. We may process your personal data where it is necessary to comply with a legal obligation to which we are subject.
- Legitimate Interest. We or a third party may have a legitimate interest in using your personal data, provided such interest is not outweighed by your privacy interests. Specifically, we rely on legitimate interests to process your personal data for: (a) marketing and business development; (b) maintaining, improving and securing our Services; (c) establishing and managing business relationships; (d) analytics, service optimization, and product development; and (e) preventing fraud and exercising and defending potential legal claims.
- HOW WE DISCLOSE YOUR PERSONAL DATA
We may disclose personal data we collect from or about you for the purposes described above, or as otherwise disclosed to you at the time of collection or disclosure, to the following:
- Partners and Affiliates. We may disclose personal information we receive from or about you with our partners and affiliates for the purposes described in this Privacy Policy.
- Vendors and Service Providers. We may disclose personal data we receive with contractors, vendors, service providers, and other third parties retained in connection with the provision of our Services, including, without limitation with: (a) cloud service providers for hosting purposes; (b) websites and web content creation platforms in order to help us manage our Website; (c) email providers, recording call services, marketing, CRM, and other similar tool providers; and (d) artificial intelligence tools and features (such as chatbots).
- Analytics Partners. We may disclose personal data with analytics companies or services, such as Google analytics, to help us understand and analyze information we collect in accordance with this policy. These companies or services may also collect information about your use of other websites, apps, and online resources.
- Advertising Partners. We work with third-party advertising partners to show you ads that we think may interest you. These advertising partners may set and access their own Cookies, pixel tags and similar technologies on our Services and they may otherwise collect or have access to information about you which they may collect over time and across different online services.
- As Required by Law and Similar Disclosures. To the extent necessary, we may disclose personal data to regulators, courts, banks or competent authorities, to comply with applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies, or if required to do so by court order, as well as for internal compliance procedures and to protect the safety, security, and integrity of Jazz, our Services, customers, employees, property, and the public.
- Merger, Sale, or Other Asset Transfer. If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares, or assets to a third party, we may disclose personal data to such third party in connection with the consideration, negotiation, or completion of such a corporate transaction. If we are acquired by, or merged with, a third-party entity, or in the event of bankruptcy or a comparable event, we may sell, liquidate, or transfer all or a portion of our business or assets (of which personal data may form a part).
- Consent. We may also disclose personal data from or about you or your devices where you have otherwise provided your consent.
- YOUR PRIVACY RIGHTS
The following rights may apply (subject to certain exemptions or derogations), depending on the jurisdiction in which you reside. You have the right:
- To withdraw consent to the processing of your personal data, where consent is the basis of our processing.
- To know or be informed of what personal data we have collected about you, including the categories of personal data, the categories of sources from which the personal data is collected, the business or commercial purpose for collecting, selling, or sharing personal data, and the categories of third parties to whom we disclose personal data.
- Under certain conditions, to access the personal data that we hold and request further details about how we process it.
- Subject to certain conditions, to data portability of personal data concerning you that you provided us in a structured, commonly used, and machine-readable format.
- To correct or rectify inaccurate personal data that we maintain about you.
- To object to unlawful data processing under certain conditions.
- To request deletion or erasure of the personal data that we have collected about you (your “right to be forgotten”), subject to certain conditions.
- Under certain conditions, to object to certain processing (i.e., if you believe we have exceeded the legitimate basis for processing) or to limit our use or disclosure of your sensitive personal data. (We do not intentionally collect, use or disclose sensitive personal data.)
- To opt out of the sale of personal data, or the sharing of personal data for cross-context behavioral advertising.
- Not to be subject to automated decision-making without human review. The personal data we collect is not used for automated decision-making and profiling, except for automated processes in the context of marketing. As stated above, you can opt out of direct marketing by Jazz by contacting Jazz directly or by following the instructions through the unsubscribe options in our email messages.
- To be free from discriminatory treatment for the exercise of your privacy rights.
You can exercise your rights by contacting us at [email protected]. To protect your privacy, we may take steps to verify your identity, including by requesting additional information, before fulfilling your request. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request or inform you if we require further information in order to fulfil your request; we will do so promptly and in accordance with timeframes set by applicable law. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, if it would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, in accordance with applicable law.
Authorized Agents. You may use an authorized agent to submit a request on your behalf if you provide the authorized agent written permission signed by you. We may also require you to verify your identity directly with us. Authorized agents may submit requests to [email protected] with proof of authorization.
Lodge Complaint. If you are located in the EEA or UK, you have the right to lodge a complaint with your local data protection supervisory authority. A list of supervisory authorities is available at: https://edpb.europa.eu/about-edpb/about-edpb/members_en.
Opting Out of Marketing Emails. If you provide Jazz with your email address, we may contact you for marketing purposes. You may choose not to receive marketing emails by following the unsubscribe link found at the bottom of the email you have received, or emailing [email protected] with the subject “BLOCK.” Please note that the email must come from the email account you wish to block. We will process your request within a reasonable time after receiving it.
Please be aware that if you are a customer, we may continue to contact you via email for administrative or informational purposes.
- HOW WE PROTECT AND RETAIN YOUR PERSONAL DATA
Security. We have implemented and maintain reasonable technical, organizational and security measures designed to protect your information. However, no method of electronic transmission or storage of personal data can be entirely secure. We cannot guarantee the absolute security of your personal data. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.
Retention of your information. We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected as described in this Privacy Policy, subject to legal obligations. When determining the specific retention period, we consider various factors to determine appropriate retention, such as the nature and sensitivity of the data, type of service provided to you and the purposes of processing, applicable legal requirements and statutes of limitations, and whether the purpose can be fulfilled by other means.
- INTERNATIONAL TRANSFERS OF PERSONAL DATA
We store personal data on Google Cloud Platform infrastructure located in the United States (US East and US Central regions). If you choose to use our Services from the EEA, the UK or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States for storage and processing.
We transfer personal data from the EEA, UK, and other jurisdictions to the United States and other countries. For transfers from the EEA/UK to countries not subject to an adequacy decision by a supervisory authority of competent jurisdiction, we rely on the European Commission-approved Standard Contractual Clauses (“SCCs”), the UK Information Commissioner-approved addendum to the SCCs or international data transfer agreement, or your explicit consent. For more information on such international transfers, please contact us at [email protected].
- USE BY MINORS. We do not offer our products or Services for use by minors and no part of our Services are directed to minors under 18, therefore, we do not knowingly collect personal data from or about minors under the age of 18. If you are under the age of 18, do not provide any information to us without the involvement of a parent or a guardian. If you believe that we might have any such information, please contact us at [email protected]. If we become aware that we have collected the personal data of minors under 18, we will take steps to delete it.
- INTERACTION WITH THIRD PARTY PRODUCTS. We enable you to interact with third party websites, mobile software applications and products or services that are not owned, or controlled, by us (each, a “Third-Party Service”). We are not responsible for the privacy practices or the content of such Third-Party Services. Please be aware that Third-Party Services can collect information from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third-Party Service.
- CHANGES TO THIS PRIVACY POLICY
This Privacy Policy may be revised from time to time. We will post any adjustments to the Privacy Policy on this page, indicating the “last updated date” above, and the revised version will be effective as of the last updated date.
CONTACT US. If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at [email protected].
Data controller: Jazz Inc
Address: 1460 Broadway, New York, NY 10036