Jenna’s Privacy Policy

Jenna’s Privacy Policy

Last Updated: 11th of February 2019

Introduction

We, at Jenna Ai Inc.. and its affiliates, (“JENNA” “we,” or “us”) have created this privacy policy (“Privacy Policy”) in order to describe the practices that Jenna follows with respect to the collection, use and disclosure of information collected from our online users, job applicants and clients (collectively, “User” or “you“).

This Privacy Policy describes how we maintain your privacy and protect the confidentiality of the information which we collect when you use our JENNA platform (the “Platform”), the website [URL] (the “Website”) and which you may share with us directly or via other online platforms (collectively, “Services”).

We encourage you to read the Privacy Policy carefully and use it to make informed decisions. By using the Services you agree to the terms of this Privacy Policy and your continued use of the Services constitutes your ongoing agreement to this Privacy Policy.

In this Privacy Policy, you can read about:

• The information we collect
• How we use the information
• How we share the information
• User’s rights and retention
• Security
• International Transfer of Data
• External Platforms
• Marketing
• Mobile Push Notifications and Alerts
• Changes to privacy policy
• How to contact us

What information do we collect?

JENNA collects the following types of information from its Users:

• Personal Information

We may collect individually identifiable information which is related to Users, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Information”), including the following:

• Data submitted when applying through our Service: We collect information you provide directly to us. For example, if you want to review or submit a job application to open positions through our service .The types of personal information we may collect from you through our Service includes but is not limited to your basic user information and contact information such as your name, address or IP location, telephone number, fax number, email address, your skill or trade, photograph, feedback and any other personal information you choose to provide. We may also collect other information about your employment history and professional experience and any other information required to provide you our Services.
• Voluntary information: We also collect information which you provide us voluntarily. We collect your information when you apply for a job through our Services, respond to communications from us, contact our support, communicate with us via email, the JENNA platform and through any online platform. Please note that when you apply for a job through our Services, you may be required to share with us your CV and other required information in order for the relevant employer to consider your application.
• Device Information: We may also collect Personal Information from your device, such as geolocation data, IP address and other online identifiers (i.e. online data collected from User’s devices, applications and protocols which leave traces which may be used to identify Users).

It should be made clear that you have no legal obligation to provide us with any Personal Information and the submission of such information is entirely subject to your sole discretion and consent. However, if you will not provide us with the required information we may not be able to provide you with the information/services requested by you.

• Other Information

We may collect additional information which is non-identifiable information and when taken alone, cannot be used to identify or contact our Users (collectively, the “Other Information”). As such, we are not aware of the identity of the User from which the Other Information was collected. Such Other Information may include:

Your Activity: Information that we or our technology providers may automatically collect when you visit, access, and/or use the Service, such as Internet service provider, domain server, type of computer, browser type and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, what sections/features of our Service that you visit/utilize, number of links you click while on the Service, search terms, and operating system. We may also collect statistical and other data related to your use of our Services as well as information on your online usage patterns. This information is collected and used as non-individually identifiable information.

Cookies and JavaScript Tags: We may use session identifiers, web beacons, cookies, JavaScript tags, and other tracking technologies. A cookie is a piece of data stored on a User’s hard drive containing information about the User. We use these technologies to enhance the User experience of our Services, and as a result, these technologies may be deployed by JENNA in any portion of the Services. Usually an Internet browser is set by default to accept cookies. If a User rejects the cookie, he/she may still use our Services, though certain features, tools and applications may be disabled or otherwise unavailable. We may also use cookies to track and monitor usage of the Services by Users for the marketing and quality improvement purposes. Most browsers will allow you to erase cookies from your computer/device hard drive, block acceptance of cookies, or receive a warning before a cookie is stored.

We may use JavaScript tags to trigger a sequence of events that includes viewing a first-party cookie (or setting that cookie if it does not already exist) and to help us tailor and optimize our Services for our Users and clients.

You may remove cookies and JavaScript tags by following the instructions of your browser preferences.

In addition to the foregoing, JENNA reserves the right to use the Google AdWords Remarketing Service (the “Google Service”) for advertising purposes. By using the Google Service, visitors of those sites, apps and other digital properties belonging to JENNA’s clients and partners may see advertisements in third parties’ websites (including, without limitation on Google’s search results page or a site in the Google Display Network). Any data collected by JENNA using the Google Service will be subject to both this Privacy Policy as well as Google’s Privacy Policy.

Social Media Widgets: Our Services includes Social Media features, such as the Facebook Like button. These features may collect which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social Media features and Widgets are either hosted by a third party or hosted directly on our Service. Your interactions with these features are governed by the privacy policy of the company providing it.

Location Information:  We may collect information about the location of your device each time you access or use one of our mobile applications or otherwise consent to the collection of this information.  For more details, please see “Your Choices” below.

How We Use Information

In addition to the purposes listed above, the information we collect, which may include your Personal Information, is used for the following purposes:

• To provide you our Services;
• Analysis and process of the application data to identify candidate – employer compatibility;
• To process your job application to the relevant enterprise;
• To communicate with you and to keep you informed of our latest updates and provide you with notifications;
• To perform a research or to conduct analysis to improve and customize our Services to your needs and interests;
• To process any of your requests regarding User’s rights (e.g. right to access, right to be forgotten, etc.);
• To support and troubleshoot our Services and to respond to your queries; and
• To investigate violations and enforce our policies, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process or respond to a government request.

How We Share the Information

We do not share, distribute, sell or rent any of your Personal Information with third parties, except in the following circumstances:

• Through our platform, enterprise users may seek employees or consultants. Upon your submission of an application, including but not limited to your answers to applicant questions, CV and additional information, these users will have access to your application, including any ratings or review of the application. We may also share aggregated or de-identified information without restriction, including for analytics, business intelligence and benchmarking purposes, provided such data cannot be re-identified.
• If the information is required by law in order to prevent, investigate, or take action regarding illegal activities. In addition, we will share information in response to legal process, court orders, subpoenas, or to establish or exercise our legal rights or defend against legal claims;
• We may also disclose the Information to any government or law enforcement authority or regulatory agency in response to lawful requests by applicable local law enforcement agencies or regulatory agencies, or agencies with responsibility to oversee and enforce national security;
• We may share some or all of your Information with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us.
• Information collected from Users of the Services may be transferred as part of or in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our shares or stock and/or assets or other corporate change, including, during the course of any due diligence process. By making available your data through the Services in any manner, you agree that your information may be transferred to third parties under such or similar circumstances.
• For the purpose of providing and operating the Services we may share Personal Information with trusted third-party service providers that require access to such data for purpose of providing Services-related services to us only (e.g. storing information on our behalf; processing information to assist us with our business operations; processing your payments; performing research, technical diagnostics or analytics; etc.); and
• If we have your permission to do so.

User Rights and Retention

You may have some or all of the following rights in respect of your personal information:

• To access and obtain a copy of your personal information in our control or possession, and information about how and on what basis this personal information is processed by us.
• You may update, correct or delete information about you at any time by logging into your online account, emailing us at contact+privacy@jenna.ai.  We encourage you to update or correct your information if your details change, or if you think that the information we hold about you is incorrect, inaccurate or out of date.
• To request that we restrict processing of your personal information where: (i) the accuracy of the personal information is contested, (ii) the processing is unlawful but you object to your personal information being erased, (iii) where it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims, or (iv) you have exercised the right to object, and verification of overriding grounds is pending. You may also have the right to challenge processing which we have justified on the basis of a legitimate interest.
• To ask us to provide all of your aggregated personal information to you in a structured, commonly used, machine-readable format, or you can ask to have it ‘ported’ directly to another data controller, but in each case only where, the processing is based on your consent or on the performance of a contract with you; and the processing is carried out by automated means.
• If you wish to deactivate your account, or where processing is based on consent, to withdraw your consent to our collection, use and/or disclosure of your personal information at any time, please email us at contact+delete@jenna.ai, but note that we may retain certain information as required by law or for legitimate business purposes.  We may also retain cached or archived copies of information about you for a certain period of time in accordance with applicable laws and regulations.
• In limited circumstances, you may request that we erase your personal information, for example, where it is no longer necessary in relation to the purposes for which it was collected or processed.

Security

We follow generally accepted industry standards to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, due to the nature of Internet communications and evolving technologies, unauthorized entry or use, hardware or software failure, and other factors, the security of User information may be compromised at any time. Therefore, we cannot guarantee the absolute security of the Information and disclaim any assurance that such information will remain free from loss, misuse, or alteration by third parties who, despite our efforts, obtain unauthorized access.

International Transfer of Data

In the process of making available the Services to its Users, JENNA may transfer information that it collects to affiliated entities or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. By using the Services, you consent to the transfer of your information to the United States and elsewhere, including outside of the EEA.

If you are located in the EEA, your personal information will only be transferred to locations outside of the EEA where we are satisfied that adequate or comparable levels of protection are in place to protect personal information. We will take reasonable steps to ensure that: (i) internal transfers will be covered by an intra-group agreement which gives specific contractual protections designed to ensure that your personal information receives an adequate and consistent level of protection when it is transferred between our affiliates; and (ii) we have appropriate contractual arrangements with our third parties to ensure adequate safeguards are in place such that the risks of your personal information being unlawfully used, amended, deleted, lost or stolen are minimized, and that such third parties will act at all times in compliance with applicable personal information protection laws. You may have a right to details of the mechanism under which your data is transferred outside of the EEA.

External Platforms

The Service may contain links to third-party websites and platforms. JENNA has no control over the privacy practices or the content of these websites or platforms. As such, we are not responsible for the content or the privacy policies of those third-party websites or platforms. You should check the applicable third-party privacy policy and terms of use when visiting any other websites or platforms.

From time to time, we would like to send you information either via SMS, telephone, push notifications/alerts, post or email that we think may be of interest to you (including in relation to our products and services, and the products and services of our selected partners, subsidiaries and affiliates), but, in certain cases, we can only do so with your prior written consent. You may opt out of receiving direct marketing and promotional communications from us by following the instructions in those communications or by emailing contact@jenna.ai .  If you opt out of these communications, we may still send you non-promotional communications, such as those about your account or our ongoing business relations, unless you have also withdrawn your consent more generally to our collection, use and/or disclosure of your personal information.

Mobile Push Notifications/Alerts.

With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device.  You can deactivate these messages at any time by changing the notification settings on your mobile device or by contacting us (see below).

Changes to This Privacy Policy

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time. By accessing and/or using the after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, our use of the Information is governed by the Privacy Policy in effect at the time we collect the Information. Please refer back to this Privacy Policy on a regular basis.

How to Contact Us

To make any requests as outlined above or if you have any questions about this Privacy Policy or for more information, please contact us at: contact@spartans.tech or at Menachem Begin 121, Tel-Aviv, Israel. You also have the right to lodge a complaint with your local supervisory authority, in respect of our collection, use or disclosure of your personal information.

Please note, we will not ask for a fee to exercise any of your rights in relation to your personal information, unless your request for access to information is unfounded, respective or excessive, in which case we will charge a reasonable amount in the circumstances.