Effective: 01 June 2022

Jangle Ltd t/a “Jangle” ("Jangle", "we", or "us") is committed to protecting the privacy of our users and strives to provide a safe user experience. As a UK based entity, we observe the statutory provisions of the Data Protection Act (“DPA”), the General Data Protection Regulations (“GDPR”), the Telecommunications Act (“TCA”) and other applicable data protection provisions of United Kingdom and international law, in particular where applicable EU law.

This Privacy Policy describes how your personal information is collected, used, shared, and secured, as well as your choices regarding use, access, and correction of your personal information. Jangle does not sell your personal information.

You may revoke your consent if provided to conduct the processing activities described in this Privacy Policy or exercise your privacy rights. If you revoke your consent, your account and profile information will be removed from our website. To do so, please contact us at dataprivacy@jangle.co.uk.

This Privacy Policy applies when you use our websites, mobile applications, and other online products and services that link to this Privacy Policy, contact our customer service team, engage with us on social media, or otherwise interact with us (collectively, our “Services”). Our Cookie Policy forms part of this Privacy Policy.

We may change this Privacy Policy from time to time. The most updated Privacy Policy is published on our website, if we make changes, we will revise the date at the top of this Privacy Policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website or providing you with a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

If you have any questions regarding data protection, you can contact us at:

Jangle
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dataprivacy@jangle.co.uk

USE OF INFORMATION

We use the information we collect to provide, maintain, and improve our Services, which includes publishing and distributing user-generated content, personalizing the posts you see and operating our metered paywall. We also use the information we collect to:

  • Create and maintain your account with Jangle.
  • Process transactions and send related information, such as confirmations, receipts, and user experience surveys.
  • Send you technical notices, security alerts, and support and administrative messages.
  • Respond to your comments and questions and provide customer service.
  • Communicate with you about new content, products, services, and features offered by Jangle and provide other news and information we think will interest you (see Your Preferences below for information about how to opt out of these communications at any time).
  • Monitor and analyse trends, usage, and activities in connection with our Services.
  • Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of Jangle and others.
  • Debug to identify and repair errors in our Services.
  • Comply with our legal and financial obligations.
  • Carry out any other purpose described to you at the time the information was collected.

The legal basis for the processing activities conducted to achieve these purposes are explained in more detail below (cf. collection of information).

COLLECTION OF INFORMATION

Information You Provide to Us

We process information you provide directly to us. For example, you share information directly with us when you create an account, fill out a form, submit or post content through our Services, purchase a membership, communicate with us via third-party platforms, request customer support, or otherwise communicate with us. The types of personal information we may collect include your name, display name, username, bio, email address, business information, your content, including your avatar image, photos, posts, responses, and series published by you, and any other information you choose to provide.

The types of services you may use from Jangle which entail such data collection include the following examples. Although this is not an exhaustive list and we may add additional collection points, we will make it clear when data is being collected. The processing of such data is based on your consent to provide the data. We will only collect the data that you provide voluntarily and freely.

  • Customer account/registration.
  • Subscriptions.
  • Order processing: The data you submit when ordering goods and/or services from us will have to be processed in order to fulfil your order. Please note that orders cannot be processed without providing this data. After your order has been completed, your personal data will be deleted, but only after the retention periods required by tax and commercial law. In order to process your order, we will share your data with the shipping company responsible for delivery to the extent required to deliver your order and/or with the payment service provider to the extent required to process your payment.
  • Newsletter: If you register for our free newsletter, the data requested from you for this purpose, i.e., your email address and, optionally, your name and address, will be sent to us. We also store the IP address of your computer and the date and time of your registration. During the registration process, we will obtain your consent (opt-in) to receive this newsletter and the type of content it will offer, with reference made to this Privacy Policy. You are entitled to withdraw your consent at any given time (opt-out). You can do that by either contacting us directly or by using our Unsubscribe links. The data collected will be used exclusively to send the newsletter and will not be passed on to third parties.
  • Submission of online forms, including direct contacts: If you contact us via email or the contact form, the data you provide will be used for the purpose of processing your request. We must have this data in order to process and answer your inquiry; otherwise, we will not be able to answer it in full or at all.
  • Sharing or Posting to Social Media services or by email and SMS.
  • User posts, comments, and ratings: We offer you the opportunity to post questions, answers, opinions, and ratings on our website, hereinafter referred to jointly as “posts.” If you make use of this opportunity, we will process and publish your post, the date and time you submitted it, and any pseudonym you may have used. In addition, we will also process your IP address and email address. The IP address is processed because we might have a legitimate interest in taking or supporting further action if your post infringes the rights of third parties and/or is otherwise unlawful.
  • Follow-up comments: If you make posts on our website, we also offer you the opportunity to subscribe to any subsequent follow-up comments made by third parties. In order to be able to inform you about these follow-up comments, we will need to process your email address.

We do not collect payment information through our Services. We rely on third parties to process payments in connection with our Services. We cannot influence what data these third parties process. Any information you provide to facilitate such a payment is subject to the third-party payment processor’s privacy policy, and we encourage you to review this policy before you provide any information to the payment processor.

Information We Collect Automatically When You Interact with Us

When you use our services, we automatically collect certain information, including:

  • Activity Information: We collect information about your activity on our Services, such as your reading history and when you share links, follow users, highlight posts, and clap for posts.
  • Transactional Information: When you purchase a membership, we collect information about the transaction, such as subscription details, purchase price, and the date of the transaction.
  • Device and Usage Information: We collect information about how you access our Services, including data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, browser type, and app version. We also collect information about your activity on our Services, such as access times, pages viewed, links clicked, and the page you visited before navigating to our Services.
  • Information Collected by Cookies and Similar Tracking Technologies: Please refer to our Cookie Policy for more information about this.

The collection and processing of these data are carried out for the purpose of enabling the use of our Services (e.g., establishing a connection), ensuring system security and stability over the long term and optimising our presence as well as for internal statistical purposes. It is within our legitimate interest to process such data to offer you well-functioning Services.

The IP address may also be used together with the other data in the event of attacks on the network infrastructure or other unauthorised or abusive use of the website or similar services to identify offenders in connection with civil or criminal proceedings. The processing of this data is in our legitimate interest to track your visit to our website and to improve our Services including their security accordingly.

Information We Collect from Other Sources

We obtain information from third-party sources. For example, we may collect information about you from social networks, accounting services providers and data analytics providers. Additionally, if you create or log into your Jangle account through a third-party platform (such as Apple, Facebook, Google, or Twitter), we will have access to certain information from that platform, such as your name, lists of friends or followers, birthday, and profile picture, in accordance with the authorization procedures determined by such platform.

We process such data within our legitimate interest to evaluate the use of our Services, compile reports, do research relating to our Services, make use of the data for market research and need-based design of our Services. Note that this information may also be transferred to third parties if this is required by law or if third parties process this data on our behalf.

Information We Derive

We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your location based on your IP address or infer reading preferences based on your reading history.

We process such data within our legitimate interest to evaluate the use of our Services, compile reports, do research relating to our Services, make use of the data for market research and need-based design of our Services.

SHARING OF INFORMATION

We only disclose your personal data to other third parties if you have consented, if there is a legal obligation to do so or if it is necessary to enforce our rights, in particular, to enforce claims arising from a contractual relationship. In addition, we disclose your data to third parties insofar as this is necessary for the use of our Services and the execution of contracts (also outside our Services).

For example, we share personal information in the following circumstances or as otherwise described in this Privacy Policy:

  • We share personal information with other users of the Services. For example, if you use our Services to publish content, post comments or send private notes, certain information about you will be visible to others, such as your name, photo, bio, other account information you may provide, and information about your activities on our Services (e.g., recent posts, likes, dislikes, your followers and who you follow, claps, highlights, and responses).
  • We share personal information with vendors, service providers, and consultants that need access to personal information in order to perform services for us, such as companies that assist us with web hosting, storage, and other infrastructure, analytics, payment processing, fraud prevention and security, customer service, communications, and marketing.
  • We may disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements. If we are going to disclose your personal information in response to legal process, we will give you notice so you can challenge it (for example by seeking court intervention), unless we are prohibited by law or believe doing so may endanger others or cause illegal conduct. We will object to legal requests for information about users of our Services that we believe are improper.
  • We may share personal information if we believe that your actions are inconsistent with our user agreements or policies (e.g., Terms of Use), if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of Jangle, our users, the public, or others.
  • We share personal information with our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
  • We may share personal information in connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
  • Personal information is shared between and among Jangle and our current and future parent companies, affiliates, and subsidiaries and other companies under common control and ownership.
  • We also share personal information with your consent or at your direction.
  • We also share aggregated or de-identified information that cannot reasonably be used to identify you.

We are entitled to transfer your personal data to third parties (e.g., contracted service providers) abroad for the purpose of the data processing described in this Privacy Policy. If we use third parties outside of Europe, we will make you aware of this. These are bound to protect data to the same extent as we are. If the level of data protection in a country does not correspond to that in UK or the rest of Europe, we will contractually ensure that the protection of your personal data always corresponds to that in the UK or the rest of Europe.

Specifically, this applies to data transfers to the USA, which from the point of view of the European Union, the European Economic Area and UK does not have an adequate level of data protection. We will make sure that we implement guarantees to ensure an appropriate level of data protection. To do so we will make use of the guarantees recognised as sufficient to ensure an adequate level of data protection in the EEA.

 

THIRD-PARTY SERVICES AND EMBEDDED CONTENT

Jangle does not host some of the content displayed on our Services. Users have the ability to post content that is actually hosted by a third party but is embedded in our Services (an “Embed”). When you interact with an Embed, it can send information about your interaction to the hosting third party just as if you were visiting the third party’s site directly. For example, when you load a Jangle post page with a YouTube video Embed and watch the video, YouTube receives information about your activity, such as your IP address and how much of the video you watch. Jangle does not control what information third parties collect through Embeds or what they do with the information. This Privacy Policy does not apply to information collected through Embeds or their providers. We cannot influence what data these third parties process. The privacy policy belonging to the third party hosting the Embed applies to any information the Embed collects, and we recommend you review that policy before interacting with the Embed.

Our Use of Social Media

  • We maintain an online presence on Twitter to present our company and our services and to communicate with customers/prospects. Twitter is a service provided by Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. The privacy policy of Twitter can be found at https://twitter.com/privacy
  • We maintain an online presence on Pinterest to present our company and our services and to communicate with customers/prospects. Pinterest is a service of Pinterest Inc., 651 Brannan Street, San Francisco, CA, 94107, USA. The Pinterest privacy policy can be found here: https://policy.pinterest.com/de/privacy-policy
  • We maintain an online presence on YouTube to present our company and our services and to communicate with customers/prospects. YouTube is a service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, a subsidiary of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA. The YouTube privacy policy can be found here: https://policies.google.com/privacy
  • We maintain an online presence on LinkedIn to present our company and our services and to communicate with customers/prospects. LinkedIn is a service of LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Irland, a subsidiary of LinkedIn Corporation, 1000 W. Maude Avenue, Sunnyvale, CA 94085, USA. The LinkedIn privacy policy can be found here: https://www.linkedin.com/legal/privacy-policy
  • To advertise our products and services as well as to communicate with interested parties or customers, we have a presence on the Facebook platform. Facebook is a service of Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland. When accessing our online presence on the Facebook platform, Facebook Ireland Ltd. as the operator of the platform in the EU will process your data (e.g., personal information, IP address, etc.). This data of the user is used for statistical information on the use of our company presence on Facebook. Facebook Ireland Ltd. uses this data for market research and advertising purposes as well as for the creation of user profiles. Based on these profiles, Facebook Ireland Ltd. can provide advertising both within and outside of Facebook based on your interests. If you are logged into Facebook at the time, you access our site, Facebook Ireland Ltd. will also link this data to your user account. If you contact us via Facebook, the personal data you provide at that time will be used to process the request. We will delete this data once we have completely responded to your query, unless there are legal obligations to retain the data, such as for subsequent fulfilment of contracts. Facebook Ireland Ltd. might also set cookies when processing your data. If you do not agree to this processing, you have the option of preventing the installation of cookies by making the appropriate settings in your browser. Details on the processing activities, their suppression, and the deletion of the data processed by Facebook can be found in its privacy policy: https://www.facebook.com/privacy/explanation
  • To advertise our products and services as well as to communicate with interested parties or customers, we have a presence on the Instagram platform. As this social media platform is owned and operated by Facebook, the same address, contacts, and terms apply to Instagram as they do to Facebook (cf. above).

Please, note that in the EU we are considered a joint controller of certain social media platform providers (e.g., Facebook). Therefore, we have defined or are in the process of defining our joint responsibility with such social media platforms in joint controllership agreements. The already concluded agreements are available by clicking on the below link(s):

Also, we would like to point out that the use of these social media platforms might cause user data to be processed outside the European Union, the European Economic Area, the United Kingdom. Data will likely be processed in the United States. This may increase the difficulty for users that, for example, want to make access request to their data. We also do not have access to this user data. Access is only available to Twitter.

 

Social media links via graphics

We also integrate the social media sites into our Services. The integration takes place via a linked graphic of the respective site. The use of these graphics stored on our own servers prevents the automatic connection to the servers of these networks for their display. Only by clicking on the corresponding graphic will you be forwarded to the service of the respective social network.

Once you click on the graphic, the network may record information about you and your visit to our Services. It cannot be ruled out that such data will be processed in the United States.

Initially, this data includes such things as your IP address, the date and time of your visit, and the page visited. If you are logged into your user account on that network, however, the network operator might assign the information collected about your visit to our site to your personal account. If you interact by clicking “Like”, “Share” etc., this information can be stored onto your personal user account and possibly posted on the respective network. To prevent this, you need to log out of your social media account before clicking on the graphic. The various social media networks also offer settings that you can configure your settings accordingly.

Google Analytics and other Google Services

We use Google Analytics and other Google Services in our Services. These services are provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter “Google”).

The Google Analytics service is used to analyse how our Services are used. Our legitimate interest lies in the analysis, optimization, and economic operation of our Services.

Usage and user-related information in relation to the Google Analytics service includes IP address, place, time, or frequency as well as the type of device and software being used of your visits to our Services will be transmitted to a Google server in the United States and stored there. However, we use Google Analytics with the so-called anonymization function, whereby Google truncates the IP address within the EU or the EEA before it is transmitted to the US.

The data collected in this way is in turn used by Google to provide us with an evaluation of our Services and what visitors do once there. This data can also be used to provide other services related to the use of our Services and of the internet in general.

Google states that it will not connect your IP address to other data. In addition, Google provides further information with regard to its data protection practices at https://www.google.com/intl/de/policies/privacy/partners, including options you can exercise to prevent such use of your data.

In addition, Google offers an opt-out add-on  at https://tools.google.com/dlpage/gaoptout?hl=en in addition with further information. This add-on can be installed on the most popular browsers and offers you further control over the data that Google collects when you visit our website. The add-on informs Google Analytics’ JavaScript (ga.js) that no information about the website visit should be transmitted to Google Analytics. However, this does not prevent information from being transmitted to us or to other web analytics services we may use as detailed herein.

 

TRANSFER OF INFORMATION ACROSSS NATIONAL BORDERS TO OTHER COUNTRIES

Jangle headquarters are in UK, and we have operations and service providers in UK and other countries. Therefore, we and our service providers may transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. For example, if we transfer personal data to Amazon Web Services, one of our service providers that processes personal information for us in various data centre locations across the globe, including those listed here. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it.

YOUR PREFERENCES

Account Information

You may access, correct, delete and export your account information at any time by logging into the Services and navigating to the settings page. Please note that if you choose to delete your account, we may continue to retain certain information about you as required by law or for our legitimate business purposes.

Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies may affect the availability and functionality of our Services. Please refer to our Cookie Policy for more information about this.

Communications Preferences

You may opt out of receiving certain communications from us, such as digests, newsletters, and activity notifications, by following the instructions in those communications or through your account’s settings page. If you opt out, we may still send you administrative emails, such as those about your account or our ongoing business relations.

Mobile Push Notifications

With your consent, we may send push notifications to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

RIGHT OF ACCESS, RECTIFICATION, DELETION AND LIMITATION OF THE PROCESSING AS WELL AS OF DATA TRANSFERABILITY

You have a right to request information about the personal data that we store about you. In addition, you have a right to correct incorrect data and a right to request deletion of your personal data, as long as there is no legal obligation to retain such data and no legal basis for further processing the existing data.

You also have a right to request the data that you have provided to us (right to data portability) to be transferred to a third party of your choice. You have a right to receive the data in a common file format.

You can contact us for the aforementioned purposes via the e-mail address dataprivacy@jangle.co.uk or our “Contact Us” form. In order to process your requests, we may request proof of your identity.

In many countries, you also have the right to file a complaint with the relevant data protection authority if you have concerns about how we process your data.

These rights depend on the applicable data protection legislation and may be either more limited or more comprehensive.

We will not discriminate against you if you exercise your rights under the CCPA.

 

ADDITIONAL DISCLOSURES REGARDING OUR PROCESSING OF YOUR DATA

Data Security

We use suitable technical and organisational security measures to protect your personal data stored with us against manipulation, partial or complete loss and against unauthorised access by third parties. Our security measures are continuously improved in line with technological developments.

You should always treat your access data confidentially and close the browser window when you have finished communicating with us, especially if you share your computer, tablet, or smartphone with others.

We also care about data protection internally. Our employees and the service providers are contractually obliged to ensure confidentiality of personal data and compliance with applicable data protection laws.

Data Retention

We store personal data associated with your account for as long as your account remains active. If you close your account, we will delete your account data within 14 days, unless we are required to retain this for legal reasons. We store other personal data for as long as necessary to carry out the purposes for which we originally collected it and for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.

Applicable Law and Venue

This Privacy Policy and the contracts concluded on the basis of or in connection with this Privacy Policy are subject to UK law unless the law of another country is mandatory. The place of jurisdiction shall be the registered office of Jangle, unless another place of jurisdiction is mandatory.

Questions or Complaints

If you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the Data Protection Authority where you reside. Contact details for your Data Protection Authority can be found using the links below:

CONTACT US

If you have any questions about this Privacy Policy, please contact us at dataprivacy@jangle.co.uk.

Jangle
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UK


Our EU representative and data protection officer is:

J Rosenblatt
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Data Protection Officer
Email: dpo@jangle.co.uk

 

Jangle © 2022 hello@jangle.co.uk

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