There are many different ways you can use our services - to share information, to communicate with other people, or to create new content.
When you share information with us, for example by creating an account with us, we can make those services even better - to help you connect with people or to make sharing with others quicker and easier. As you use our services, we want you to be clear how we're using information and the ways in which you can protect your privacy.
Where our processing of your information is covered by the General Data Protection Regulation 2016/679 ("GDPR").
We've tried to keep it as simple as possible, but if you're not familiar with terms like cookies, IP addresses and browsers, then read about these key terms first. Your privacy matters to us; whether you are new to JRS Innovation or a long-time user, please do take the time to get to know our practices - and if you have any questions, contact us.
You may also set your browser to block all cookies, including cookies associated with our services, or to indicate when a cookie is being set by us. However, it's important to remember that many of our services may not function properly if your cookies are disabled. For example, you may not be able to login to JRS Innovation or utilise other services.
We collect information to provide better services to all of our users - from figuring out basic stuff like which language you speak, to more complex things like what content of ours matters most to you.
We collect information in the following ways:
We may use the information we collect, including your personal information and transaction information, from all of our services in any one or more of the locations that JRS Innovation has operations or otherwise conducts business for the following purposes:
We’re required to keep some of your information for certain periods of time under law. When we no longer require your information, we’ll ensure that your information is destroyed or de-identified.
We may need to retain certain personal information after we cease providing you with products or services to enforce our terms, for fraud prevention, to identify, issue or resolve legal claims and/or for proper record keeping.
Many of our services let you share information with others. Remember that when you share information publicly, it may be indexable by search engines. Our services provide you with different options on sharing and removing your content.
We do not share personal information with companies, organizations and individuals outside of JRS Innovation unless one of the following circumstances apply:
With your consent
We will share personal information with companies, organizations or individuals outside of JRS Innovation when we have your consent to do so.
With account administrators
If your account is managed for you by an organisation administrator then your organisation’s administrator and resellers who provide user support to your organization will have access to your information (including your email and other data). Your account administrator may be able to:
Third Party Service Providers
We may disclose personal information to
Fraud, security, technical issues
We will share your personal information with trusted third parties where necessary to detect, prevent or otherwise address fraud, security or technical issues.
For legal reasons
We may disclose your information if required by applicable law, regulation or as part of any actual or prospective legal process (including if reasonably necessary to enforce applicable Terms of Service or in order to establish, exercise or defend our legal rights). If we receive a request from a regulatory body or law enforcement agency, and if permitted under GDPR and other laws, we may disclose certain information to such bodies or agencies.
Merger or acquisition
We may share aggregated, non-personally identifiable information publicly and with our partners - like publishers, advertisers or connected sites. For example, we may share information publicly to show trends about the general use of our services. This could also include government bodies, industry groups, insurers and educational/training facilities.
We have put in place robust measures regarding the security of the information we collect and store about you (including through the use of network and database security measures) and will use our reasonable endeavours to protect your personal data from unauthorised access to or unauthorised alteration, disclosure or destruction. In particular:
Given that the Internet is a global environment, using the Internet to collect and process personal data necessarily involves the transmission of data on an international basis.
The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our servers via third party networks; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
You may choose to restrict the collection or use of your personal information. If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below.
You may request details of the personal information that we hold about you. An administrative fee may be payable for the provision of such information. In certain circumstances, as set out in the Privacy Act 1988 (Cth), we may refuse to provide you with personal information that we hold about you.
If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.
If you believe that we have breached the Privacy Principles and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint.
Please note that clicking on links and banner advertisements on our websites can result in your browser accessing a third party website, where data privacy practices are different to that of JRS Innovation.
We are not responsible for, and have no control over, information that is submitted to or collected by these third parties and you should consult their privacy policies.
If you have any enquiries or if you would like to contact us about our processing of your personal information, please contact us by any of the methods below. When you contact us, we will ask you to verify your identity.
Contact name: Privacy Officer
Telephone: (888) 688-0762
930 Hampton Oaks
Drive, Alpharetta GA - 30004
Under GDPR, the main grounds that we rely upon in order to process personal data collected via our websites and services are the following:
(a) Necessary for entering into, or performing, a contract – in order to perform obligations that we undertake in providing a service to you, or in order to take steps at your request to enter into a contract with us, it will be necessary for us to process your personal data;
(b) Necessary for compliance with a legal obligation – we are subject to certain legal requirements which may require us to process your personal data. We may also be obliged by law to disclose your personal data to a regulatory body or law enforcement agency;
(c) Necessary for the purposes of legitimate interests - either we, or a third party, will need to process your personal data for the purposes of our (or a third party's) legitimate interests, provided we have established that those interests are not overridden by your rights and freedoms, including your right to have your personal data protected. Our legitimate interests include responding to requests and enquiries from you or a third party, optimising our website, applications and customer experience, informing you about our products and services and ensuring that our operations are conducted in an appropriate and efficient manner;
(d) Consent – in some circumstances, we may ask for your consent to process your personal data in a particular way.
As mentioned above, we will share your personal information with trusted third parties where we have retained them to provide services that you or our clients have requested, and to perform maintenance or respond to technical incidents affecting our services.
Where we disclose personal information to third parties, we require minimum standards of confidentiality and data protection from such third parties.
To the extent that any personal information is provided to third parties outside the EEA, or who will access the information from outside the EEA, we will ensure that approved safeguards are in place to ensure that we comply with GDPR, such as the standard contractual clauses approved by the European Commission or the EU/US Privacy Shield.
JRS Innovation processes personal information on our servers in many countries around the world. We may process your personal information on a server located outside the country where you live, including outside the EEA. The primary location of user data and data uploaded to App and Spotlight is a datacentre in the U.S. operated by our third-party cloud hosting provider, Amazon Web Services ("AWS"). AWS is a participant in the EU/US Privacy Shield, under which transfers of personal data to the U.S. are authorised.
You have certain rights in relation to personal information we hold about you. Details of these rights and how to exercise them are set out below. We will require evidence of your identity before we are able to act on your request.
Right of Access
You have the right at any time to ask us for a copy of the personal information about you that we hold. Where we have good reason, and if the GDPR permits, we can refuse your request for a copy of your personal information, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reasons for doing so.
Right of Correction or Completion
If personal information we hold about you is not accurate, out of date or incomplete, you have a right to have the data rectified, updated or completed. You can let us know by contacting us at [email protected]
Right of Erasure
In certain circumstances, you have the right to request that personal information we hold about you is erased e.g. if the information is no longer necessary for the purposes for which it was collected or processed or our processing of the information is based on your consent and there are no other legal grounds on which we may process the information.
Right to object to or restrict processing
In certain circumstances, you have the right to object to our processing of your personal information by contacting us at [email protected] For example, if we are processing your information on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which override your rights and interests. You also have the right to object to use of your personal information for direct marketing purposes.
You may also have the right to restrict our use of your personal information, such as in circumstances where you have challenged the accuracy of the information and during the period where we are verifying its accuracy
Right of Data Portability
In certain instances, you have a right to receive any personal information that we hold about you in a structured, commonly used and machine-readable format. You can ask us to transmit that information to you or directly to a third party organisation.
The above right exists only in respect of personal information that:
While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third party organisation's systems. We are also unable to comply with requests that relate to personal information of others without their consent.
You can exercise any of the above rights by contacting us using any of the methods in the Contact section above.
Most of the above rights are subject to limitations and exceptions. We will provide reasons if we are unable to comply with any request for the exercise of your rights.
To the extent that we are processing your personal information based on your consent, you have the right to withdraw your consent at any time. You can do this by contacting us using the details in the Contact section above.