Jomo process personal data of their users of Jomo’s services (“Jomo App”) and the visitors of the website jomo.events (“Website”).
In this Privacy Statement, the word “Jomo Services” refers jointly to the Website and the Jomo App. In this Privacy Statement, the word “User” or “you” refers jointly to our and our group companies’ customers, representatives and other authorized users of our customer organizations, potential customers and the users of the Jomo Services. You become a customer of Jomo when you register to the Jomo Services and create a user account.
Our Privacy Statement explains, for example, the types of personal data we process, how we process the personal data and how you may exercise your rights as a data subject (e.g. right to object, right of access).
Some of our services might be subject to a separate privacy policy. If a separate privacy policy applies to a particular service, we will post it in connection with the service in question.
This Privacy Statement may be updated from time to time in order to reflect the changes in data processing practices or otherwise. You can find the current version on the Website. We will not make substantial changes to this Privacy Statement or reduce the rights of the Users under this Privacy Statement without providing a notice thereof.
Name: Gleb Klimov
E-mail address: klgleb@gmail.com.
The personal data collected and processed by us can be divided into two general data categories: User Data and Analytics Data.
User Data
User Data is personal data collected directly from you or from our customer organization on behalf of which you are using the Jomo Services (“Customer Organization”), as the case may be. We may collect User Data from our Users and Customer Organizations in a variety of ways, including, after conclusion of a service agreement with the Customer Organization or when Users register to the Jomo Services, subscribe to a newsletter or fill out a form. Further, please note that we also collect details of any transactions and payments you carry out through the Jomo Services.
User Data that is necessary in order to use the Jomo Services
The following personal data collected and processed by us is necessary in order for a proper performance of the contract between you and us as well as for our legitimate interest whilst fulfilling our contractual obligations towards our Customer Organizations and for the compliance with our legal obligations.
After conclusion of the service agreement between us and the Customer Organization, the Customer Organization provides us with your full name and email address.
When you register to the Jomo Services and create a user account, you need to provide us with the following information:
information relating to your payment instrument(s) such as the number of your payment instrument(s) and the expiration date of your payment instrument(s) (required for the purposes of providing services via the Jomo Services, however not stored by Jomo, since Jomo uses a third party payment service provider for processing of payments)
User Data you give us voluntarily
Your user or customer experience may be enhanced by providing us with the following information:
Additional Account Information:
Other Information. We may also process other information provided by you voluntarily such as:
In addition to User Data collected from you and the Customer Organization, we process certain personal data third party service providers provide about you.
If you connect or login to your account with Facebook, Facebook shares with us personal information about you such as your profile picture, a sample of your Facebook friends and your Facebook ID.
Analytics Data
Although we do not normally use Analytics Data to identify you as an individual, you can sometimes be recognized from it, either alone or when combined or linked with User Data. In such situations, Analytics Data can also be considered personal data under applicable laws and we will treat such data as personal data.
We may automatically collect the following Analytics Data when you visit or interact with the Jomo Services:
Device Information. We collect the following information relating to the technical device you use when using the Jomo Services:
device and device identification number, device IMEI
country
IP address
browser type and version
operating system
Internet service providers
advertising identifier of your device
visitor identifier
Usage Information. We collect information on your use of the Jomo Services, such as:
time spent on the Jomo Services
interaction with the Jomo Services
information on your orders made through the Jomo Services
the time and date of your visits to the Jomo Services
the sections of the Jomo Services you visited
the events you searched for while using the Jomo Services
Cookies
We use various technologies to collect and store Analytics Data and other information when the Users visit the Jomo Services, including cookies and web beacons.
Cookies are small text files sent and saved on your device that allows us to identify visitors of the Jomo Services and facilitate the use of the Jomo Services and to create aggregate information of our visitors. This helps us to improve the Jomo Services and better serve our Users. The cookies will not harm your device or files. We use cookies to tailor the Jomo Services and the information we provide in accordance with the individual interests of our Users. Some cookies are necessary for using and running a seamless experience on the Jomo Services and they are used e.g. for remembering your choice of language and country. Other cookies collect information about how the Jomo Services are used, e.g. which content is frequently visited, in order to improve the Jomo Services. We may also use cookies to serve our ads on the Jomo Services or on selected third-party platforms.
The Users may choose to set their web browser to refuse cookies, or to alert when cookies are being sent. For example, the following links provide information on how to adjust the cookie settings on some popular browsers:
Please note that some parts of the Jomo Services may not function properly if use of cookies is refused.
A web beacon is a technology that allows identifying readers of websites and emails e.g. for identifying whether an email has been read.
Web analytics services
The Jomo Services use Google Analytics and other web analytics services to compile Analytics Data and reports on visitor usage and to help us improve the Jomo Services. For an overview of Google Analytics, please visit Google Analytics. It is possible to opt-out of Google Analytics with the following browser add-on tool: Google Analytics opt-out add-on.
Purposes
There are several purposes of the processing of your personal data by Jomo. One or more of the following purposes may apply simultaneously:
To provide the Jomo Services and carry out our contractual obligations (legal ground: performance of a contract and legitimate interest)
Jomo may process personal data when it is necessary for an interest which is lawful and important for Jomo.
We use the data for example to process your requests, to communicate with you, to handle your payments or any refunds (where applicable). If you contact our customer service, we will use the information provided by you to answer your questions or solve your complaint.
For our legal obligations (legal ground: compliance with a legal obligation)
Jomo processes data to enable us to administer and fulfil our obligations under law. This includes data processed for complying with our bookkeeping obligations and providing information to relevant authorities such as tax authorities.
For claims handling and legal processes (legal ground: legitimate interest)
Jomo may process personal data in relation to claims handling, debt collection and legal processes. We may also process data for the prevention of fraud, misuse of our services and for data, system and network security.
For customer communication and marketing (legal ground: legitimate interest)
Jomo processes your personal data to contact you regarding the Jomo Services and to inform you of changes relating to them. Your personal data are also used for the purposes of marketing the Jomo Services to you. Legitimate interest is the basis for processing e.g. when we personalize our offerings and provide you with services which are more relevant to you and when we analyze information on your interests and feedback to develop our services.
For quality improvement and trend analysis (legal ground: legitimate interest)
We may also process information about your use of the Jomo Services to improve the quality of the Jomo Services e.g. by analyzing any trends in the use of the Jomo Services. In order to ensure that our services are in line with your needs, personal data can be used for things like customer satisfaction surveys. When possible, we will do this using only aggregated, non-personally identifiable data.
Legal grounds for processing
Jomo processes your personal data to perform our contractual obligations towards you or the Customer Organization and to comply with legal obligations. Furthermore, we process your personal data to pursue our legitimate interest to run, maintain and develop our business and to create and maintain customer relationships. When choosing to use your data on the basis of our legitimate interests, we weigh our own interests against your right to privacy and e.g. provide you with easy to use opt-out from our marketing communications and use pseudonymized or non-personally identifiable data when possible.
In some parts of the Jomo Services, you may be requested to grant your consent for the processing of personal data. In this event, your personal data is not processed before you give consent and you may withdraw your consent at any time.
Jomo stores your personal data primarily within the European Economic Area. However, we have service providers and operations in several geographical locations. As such, we and our service providers may transfer your personal data to, or access it in, jurisdictions outside the European Economic Area or the User’s domicile.
We will take steps to ensure that the Users’ personal data receives an adequate level of protection in the jurisdictions in which they are processed. We provide adequate protection for the transfers of personal data to countries outside of the European Economic Area through a series of agreements with our service providers based on the Standard Contractual Clauses or through other appropriate safeguards, such as the Privacy Shield Framework.
More information regarding the transfers of personal data may be obtained by contacting us on any of the addresses indicated above.
We only share your personal data within the organization of Jomo if and as far as reasonably necessary for the purposes of this Privacy Statement.
We do not share your personal data with third parties outside of Jomo’s organization unless one of the following circumstances applies:
For the purposes set out in this Privacy Statement and to authorized service providers
To the extent that third parties need access to personal data in order for us and such third parties to perform the Jomo Services, we provide such third parties with your data. Furthermore, we may provide your personal data to our affiliates or to authorized service providers and partners who perform services for us or in collaboration with us (including data storage, accounting, sales and marketing) to process the data and to payment service providers to process your payments to us.
When data is processed by third parties on behalf of Jomo, Jomo has taken the appropriate contractual and organizational measures to ensure that your data are processed exclusively for the purposes specified in this Privacy Statement and in accordance with all applicable laws and regulations and subject to our instructions and appropriate obligations of confidentiality and security measures.
Please bear in mind that if you provide personal data directly to a third party, such as through a link in the Jomo Services, the processing is typically based on their policies and standards.
For legal reasons and legal processes
We may share your personal data with third parties outside Jomo if we have a good-faith belief that access to and use of the personal data is reasonably necessary to: (i) meet any applicable law, regulation, and/or court order; (ii) detect, prevent, or otherwise address fraud, crime, security or technical issues; and/or (iii) protect the interests, properties or safety of Jomo, the Users or the public as far as in accordance with the law. When possible, we will inform you about such processing.
For other legitimate reasons
If Jomo is involved in a merger, acquisition or asset sale, we may transfer your personal data to the third party involved. However, we will continue to ensure the confidentiality of all personal data. We will give notice to all the Users concerned when the personal data are transferred or become subject to a different privacy statement.
With your explicit consent
We may share your personal data with third parties outside Jomo when we have your explicit consent to do so. You have the right to withdraw this consent at all times free of charge by contacting us.
Jomo does not store your personal data longer than is legally permitted and necessary for the purposes of providing the Jomo Services or the relevant parts thereof. The storage period depends on the nature of the information and on the purposes of processing. The maximum period may therefore vary per use. Jomo takes reasonable steps to keep the personal data accurate and to delete incorrect or unnecessary personal data.
Most personal data relating to a User’s user account with the Jomo Services will be deleted after a period of 90 days have lapsed after the User has deleted its user account with the Jomo Services. Thereafter, a part of the personal data relating to a User’s user account with the Jomo Services may be stored only as long as such processing is required by law or is reasonably necessary for our legal obligations or legitimate interests such as claims handling, bookkeeping, internal reporting and reconciliation purposes. All personal data relating to a User’s user account with the Jomo Services will be deleted within a period of 10 years after the User has deleted its user account with the Jomo Services, with the exception of personal data required in certain rare situations such as legal proceedings.
We will store Analytics Data of Users that do not have an account with the Jomo Services for a period of 90 days.
Right of access
You have the right to access and be informed about your personal data processed by us. We give you the possibility to view certain data through your user account with the Jomo Services or request a copy of your personal data using the contact details above.
Right to withdraw consent
In case the processing is based on a consent granted by the User, the User may withdraw the consent at any time free of charge. Withdrawing a consent may lead to fewer possibilities to use the Jomo Services. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
Right to rectify
You have the right to have incorrect or incomplete personal data we have stored about you corrected or completed by contacting us. You can correct or update some of your personal data through your user account in the Jomo Services.
Right to erasure
You may also ask us to delete your personal data from our systems for example when the data is no longer necessary for the purposes for which it was collected. We will comply with such request unless we have a legitimate ground to not delete the data. Please note that if you want to delete such information, we may not be able to provide you the Jomo Services or certain features thereof.
Right to object
You may have the right to object to certain use of your personal data if such data are processed for other purposes than necessary for the performance of the Jomo Services or for compliance with a legal obligation. For example, you can request that we stop processing your personal data for direct marketing or profiling purposes based on legitimate interest. If you object to the further processing of your personal data, this may lead to fewer possibilities to use the Jomo Services.
Right to restriction of processing
You may request us to restrict processing of personal data for example when your data erasure, rectification or objection requests are pending and/or when we do not have legitimate grounds to process your data. When the processing has been restricted, your data will only be stored and not processed further. For example, if you contest the accuracy of your data, such data will be restricted from processing until it is ensured that the data is accurate. This may however lead to fewer possibilities to use the Jomo Services.
Right to data portability
When processing is carried out by automated means and based on a contract or consent, you have the right to receive the personal data you have provided to us yourself in a structured and commonly used format and to independently transmit those data to a third party.
How to use your rights
The abovementioned rights may be used by sending a letter or an e-mail to us on the addresses set out above, including the following information: the full name, address, e-mail address and a phone number. We may request the provision of additional information necessary to confirm the identity of the User. We may reject or charge requests that are unreasonably repetitive, excessive or manifestly unfounded.
We may send you information, news and offers about the Jomo Services based on the customer relationship between you and Jomo. In other cases, we do not send you direct marketing without your explicit consent. The User has the right to prohibit us from using the User’s personal data for direct marketing purposes, market research and profiling made for direct marketing purposes anytime by contacting us on the addresses indicated above or by using the functionalities of the Jomo Services (on Profile tab) or the unsubscribe possibility offered in connection with any direct marketing messages.
In case the User considers our processing of personal data to be inconsistent with the applicable data protection laws, the User may lodge a complaint with the local supervisory authority for data protection of the User’s country of domicile.
We use administrative, organizational, technical, and physical safeguards to protect the personal data we collect and process. Measures include for example, where appropriate, encryption, pseudonymization, firewalls, secure facilities and access right systems. Our security controls are designed to maintain an appropriate level of data confidentiality, integrity, availability, resilience and ability to restore the data. We regularly test the Jomo Services, systems, and other assets for security vulnerabilities.
Should despite of the security measures, a security breach occur that is likely to have negative effects to the privacy of the Users, we will inform the relevant Users and other affected parties, as well as relevant authorities when required by applicable data protection laws, about the breach as soon as possible.