Privacy Policy

Last updated: April 29, 2024

This Privacy Policy describes how Joyo Ltd. (together with its affiliated companies – “Joyo”, “we”, “our” or “us”) collects, stores, uses and discloses the following categories of personal data:

(i) Customer Data: personal data that we collect, process and manage on behalf of our business customers (“Customers”), submitted to the Joyo cloud-based services, including our platforms, products, applications, application programming interface (“API”), tools, and any ancillary or supplementary Joyo products and services (including Upgrades (as defined in the Terms of Service)), offered online and via a mobile application (collectively, “Platform”).

We process such Customer Data on behalf and under the instruction of the respective Customer in our capacity as a “data processor”, in accordance with our Data Processing Addendum with them.

Accordingly, this Privacy Policy – which describes Joyo’s independent privacy and data processing practices as a “data controller” – with respect to the Platform, Sites (as defined below) and any other services provided to Customer by Joyo (“Services”), and does not apply to the processing of Customer Data.

1. Data Collection & Processing

When we use the term “personal data” in this Privacy Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. It does not include aggregated or anonymized information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual.

We collect or generate the following categories of personal data in relation to the Services:

Usage and device information concerning our Users, Prospects and Technology Partners:

Connectivity, technical and usage data, such as IP addresses and approximate general locations derived from such IP addresses, device and application data (like type, operating system, mobile device or app id, browser version, location and language settings used), activity logs, the relevant cookies and pixels installed or utilized on your device, and the recorded activity (sessions, clicks, use of features, logged activities and other interactions) of Prospects, Users and Technology Partners in connection with our Services.

We collect and generate this information automatically, including through the use of analytics tools (including cookies and pixels) – which collect data such as: how often Prospects or Technology Partners visit or use the Sites, which pages they visit and when, which website, ad or email message brought them there, and how Users interact with and use the Platform and its various features.

2. Data Uses & Legal Bases

We use personal data as necessary for the performance of our Services (“Performance of Contract”); to comply with our legal and contractual obligations (“Legal Obligations”); and to support our legitimate interests in maintaining and improving our Services, e.g. in understanding how our Services are used and how our campaigns are performing, and gaining insights which help us dedicate our resources and efforts more efficiently; in marketing, advertising and selling our Services to you and others; providing customer services and technical support; and protecting and securing our Users, Customers, Prospects and Technology Partners, ourselves and our Services (“Legitimate Interests”).

3. Data Retention

Data Retention: We may retain your personal data for as long as it is reasonably needed to maintain and expand our relationship and provide you with our Services and offerings; in order to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (e.g. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our data retention policy and at our reasonable discretion. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of such data, the potential risk of harm from unauthorized use or disclosure of such data, the purposes for which we process it, and the applicable legal requirements. If you have any questions about our data retention policy, please contact us by email at joyoopollookgo@outlook.com.

4. Data Disclosure

We may disclose personal data in the following instances:

Feedback or Recommendations: If you submit a public review or feedback, note that we may (at our discretion) store and present your review publicly, on our Sites and Services. If you wish to remove your public review, please contact us at joyoopollookgo@outlook.com. If you choose to send others an email or message inviting them to use the Services, we may use the contact information you provide us to automatically send such invitation email or message on your behalf. Your name and email address may be included in the invitation email or message.

Legal Compliance: In exceptional circumstances, we may disclose or allow government and law enforcement officials access to your personal data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect the security or integrity of our products and Services.

Protecting Rights and Safety: We may disclose your personal data to others if we believe in good faith that this will help protect the rights, property or safety of Joyo, any of our Users or Customers, or any members of the general public.

5. Cookies and Tracking Technologies

Our Sites and Services (including some of our Services Providers) utilize “cookies”, anonymous identifiers, pixels, container tags and other technologies in order for us to provide and monitor our Services and Sites, to ensure that they perform properly, to analyze our performance and marketing activities, and to personalize your experience. Such cookies and similar files or tags may also be temporarily placed on your device. Certain cookies and other technologies serve to recall personal data, such as an IP address, as indicated by a Prospect, User or Technology Partner. To learn more about our practices concerning cookies and tracking, please see our Cookie Policy. You may also use the “Cookie settings” feature available in our Services depending on your location and activity on our Services, as applicable.

Please note that we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, however, most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or to block or remove cookies altogether.

6. Communications

We engage in Services and promotional communications, through email, phone, SMS and notifications.

Services Communications: We may contact you with important information regarding our Services. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Services, billing issues, log-in attempts or password reset notices, etc. Our Customers, and other Users on the same Account, may also send you notifications, messages and other updates regarding their or your use of the Services. You can control your communications and notifications settings from your User Profile settings, or otherwise in accordance with the instructions that may be included in the communications sent to you. However, please note that you will not be able to opt-out of receiving certain Services communications which are integral to your use (like password resets or billing notices).

Promotional Communications: We may also notify you about new features, additional offerings, events and special opportunities or any other information we think you will find valuable, as our Customer, User, Prospect or Technology Partner. We may provide such notices through any of the contact means available to us (e.g. phone, mobile or email), through the Services, or through our marketing campaigns on any other sites or platforms. If you do not wish to receive such promotional communications, you may notify Joyo at any time by sending an email to joyoopollookgo@outlook.com, changing your communications preferences in your User Profile settings, or by following the “unsubscribe”, “stop”, “opt-out” or “change email preferences” instructions contained in the promotional communications you receive.

7. Data Security

In order to protect your personal data held with us, we use industry-standard physical, procedural and technical security measures, including encryption as appropriate. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any personal data stored with us or with any third parties as described in Section 4 above.

8. Data Subject Rights

If you wish to exercise your privacy rights under applicable law (including the EU or UK GDPR, Swiss Federal Data Protection Act or the CCPA), such as (each to the extent applicable to you under the laws which apply to you) – the right to know/request access to (specific pieces of personal data collected; categories of personal data collected; categories of sources from whom the personal data was collected; purpose of collecting personal data; categories of third parties with whom we have disclosed personal data), to request rectification or erasure of your personal data held with Joyo, or to restrict or object to such personal data’s processing (including the right to direct us not to sell your personal data to third parties now or in the future), or to obtain a copy or port such personal data, or the right to equal Services and prices (e.g. freedom from discrimination) – please contact us by email at joyoopollookgo@outlook.com. If you are a GDPR-protected individual, you also have the right to lodge a complaint with the relevant supervisory authority in the EEA or the UK, as applicable.

You may designate an authorized agent, in writing or through a power of attorney, to request to exercise your privacy rights on your behalf. The authorized agent may submit a request to exercise these rights by emailing us. In such cases, we may request further information to verify such power of attorney and authorization.

Please note that when you ask us to exercise any of your rights under this Privacy Policy or applicable law, we may instruct you on how to fulfill your request independently through your User Profile settings; refer you to your Account Admin; or require additional information and documents, including certain personal data and credentials in order to process your request in a proper manner (e.g. in order to authenticate and validate your identity so that we know which data in our systems relates to you, and where necessary, to better understand the nature and scope of your request). Such additional information will be then retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request, and of how each request was handled), in accordance with Section 3 above.

We may redact from the data which we make available to you, any personal or confidential data related to others.

9. Additional Notices

Updates and Amendments: We may update and amend this Privacy Policy from time to time by posting an amended version on our Services. The amended version will be effective as of the date it is published. When we make material changes to this Privacy Policy, we will give notice as appropriate under the circumstances, e.g., by displaying a prominent notice within the Services or by sending an email. Your continued use of the Services after the changes have been implemented will constitute your acceptance of the changes.

Accessibility: Upon request, this Privacy Policy can be read by a screen reader. For more information, please contact joyoopollookgo@outlook.com.

If you have any questions or would like to exercise your rights under the CCPA, you can contact joyoopollookgo@outlook.com.

Our Services are not directed to children under the age of 16: We do not knowingly collect personal data from children and do not wish to do so. If we learn that a person under the age of 16 is using the Services, we will attempt to prohibit and block such use and will make our best efforts to promptly delete any personal data stored with us with regard to such child. If you believe that we might have any such data, please contact us by email at joyoopollookgo@outlook.com.

Questions, concerns or general complaints: If you have any comments or questions regarding our privacy policy or practices, or if you have any concerns regarding your personal data held with us, or if you wish to make a complaint about how your personal data is being processed by Joyo, please contact Joyo’s support at joyoopollookgo@outlook.com, or our Data Protection Officer at joyoopollookgo@outlook.com.