Importantly, we may collect Personal Information directly from you when you visit our Platform or access and use the JOW Services.
We may collect certain information from you when you use the JOW Services. We collect and obtain your information in a few ways: there is information that you choose to give to us, information we obtain through your use of the JOW Services and information we obtain from third parties. Each of these is detailed below:
Some Services may contain functionality that can enable us to access your location and tailor your experience based on your location (“Location-based Services”). To use Location-based Services, you must enable certain features of your mobile device (e.g., GPS, Wi-Fi, or Bluetooth) to allow us to identify your location. To the extent your location is collected through Wi-Fi___33 or Bluetooth sensors, such sensors, and the associated data services, may be provided by a third party that may access such information for the purpose of providing such data services to us. You agree to such access by such third parties. You may enable or disable such Location-based Services at any time via a menu within the JOW Services. If you choose to disable any Location-based Services on your device and/or opt out of any Location-based Services through the menu, you will not be able to utilize certain features of the JOW Services. By enabling Location-based Services on your device, you agree and acknowledge that (i) device data we collect from you is directly relevant to your use of the JOW Services; (ii) we may provide Location-based Services related to and based on your then-current location; and (iii) we may use any such information collected in connection with the provision of Location-based Services in providing the JOW Services. PLEASE NOTE THAT LOCATION DATA MAY NOT ALWAYS BE ACCURATE, AND WE DISCLAIM ANY AND ALL WARRANTIES RELATED TO LOCATION-BASED SERVICES.
We may use your location to provide you with advertisements, offers, and other promotional content as part of the JOW Services.
Except as provided herein, we collect and use your personal and non-personal information for internal purposes only or for gathering aggregate and anonymized data. We may use, store, and process your information in the following ways:
In order to improve the JOW Services and provide more convenient, relevant experiences to our users, we and our agents may use “cookies,” “web beacons,” and similar devices to track your activities. A cookie is a small amount of data that is transferred to your browser by a web server and can only be read by the server that gave it to you. It functions as your identification card and enables us to record your passwords and preferences. It cannot be executed as code or deliver viruses. A web beacon is a small transparent .gif image that is embedded in an HTML page or email used to track when the page or email has been viewed. Most browsers are initially set to accept cookies, and most services that include similar devices are typically initially activated to collect data. You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether to accept it. We do not support browsers’ Do Not Track features. You can enable or disable Do Not Track by visiting the preferences or settings page of your browser. If you disable cookies, you may lose some of the features and functionality of using our Platform, as cookies may be necessary to track and enhance your use and access.
We may, either directly or indirectly, track your behavior on the JOW Services for purposes of our own user support, analytics, research, product development, fraud prevention, risk assessment, regulatory compliance, investigation, as well as to enable you to use and access the JOW Services and pay for your activities on the JOW Services. We may also, either directly or through third parties we engage to provide services to us, track your behavior on the JOW Services.
We use a variety of security measures, including SSL, encryption, and authentication tools, to help protect your information. We do not retain your Personal Information for longer than is necessary for our business purposes. When we no longer need your Personal Information, we dispose of it safely.
Our security measures include standard international data protection measures as well as those described in the EU GDPR implementing regulations. These measures may also include periodic system-wide password resets with high password strength requirements. We strongly discourage password sharing. Due to the nature of the information and related technology, we cannot be held responsible if you share your own login credentials with others. If we learn of a security breach, then we will immediately reset your account password and attempt to notify you as per GDPR guidelines to take appropriate steps.
In submitting any third-party Personal Data within the context of the JOW Services (“Third-Party Data”), the parties agree that you shall be the Data Controller and you appoint us as a Data Processor of such data, for the purpose of providing the JOW Services. To the extent that we are a Data Processor for you in respect of such Third-Party Data, we will:
You represent and warrant that you have all the appropriate consents from data subjects whose Personal Data are submitted to us in the course of the provision of the JOW Services.
We will not share your Personal Information with third parties without your express consent, except in the limited circumstances described below:
If you are visiting this Platform or utilizing JOW Services from a country other than the United States, the various communications you send and receive may result in the transfer of information across international boundaries. If you are located in the European Union, you should be aware that information you provide, or which is otherwise collected on this Platform or through any Services rendered may be transferred to countries (including the United States) which may not have data protection laws deemed as adequate as those in the EU.
We will ensure that you can exercise your rights pertaining to your Personal Information, including rights as provided by various data protection laws. We therefore inform you that, where applicable under relevant law, you are entitled:
Under certain laws, you may also have the right to “opt-out” of having your Personal Information sold to a third party. However, we do not sell your Personal Information to any other party. Only in the case of a merger, sale, financing, acquisition, or other transaction involving all or part of us may your information be involved in a transaction.
For deletion/“right to be forgotten” requests, we will undertake a good faith effort to accommodate requests for access to or deletion of personal information. However, these requests may be subject to the evaluation of additional factors, including disproportionate burden or expense, or the risk to the rights, including the privacy rights, of others.
We will strive and work to resolve any inquiry you may have regarding our privacy practices. EU residents may also file a complaint before a competent data protection authority regarding the processing of your Personal Data. While we suggest that you contact us beforehand, if you wish to exercise this right, you should contact the competent data protection authority directly.
If you have any questions, would like to exercise any of these rights, or if you need any assistance with privacy related matters, please contact us as described in the “How to Contact Us” section below. We will take the necessary steps to respond to you as soon as possible.
If you have any questions regarding this Policy or our privacy practices, you can contact us at:
Jow Inc (at JADE - Fiducial)
55 East 59th Street, 9th floor
New York, NY 10022
Privacy Point of Contact: Antoine Maillard, CTO & Co-Founder
Last Updated: 7 June 2023