Jungo Connectivity Ltd. - PRIVACY POLICY
Last updated: 2021-12-16
Jungo Connectivity Ltd. respects your privacy. Jungo Connectivity Ltd. and their affiliates ("Jungo" or the "Company" ) offer software, driver applications and community based services to users of www.jungo.com and www.vudrive.net and www.vudrive.com and www.dataum.com (the "Website") and/or users of Jungo's hardware application VuDrive (the "Application") (collectively referred to as the "Services").
This Privacy Policy describes:-
o the information that Jungo collects from users;
o how that information is used by Jungo; and
o the rights and options available to users.
This Privacy Policy is incorporated as part of the Jungo Terms of Use (the "Terms of Use" or the "Terms").
Any personal information processed by Jungo in connection with this Privacy Policy is controlled by Jungo Connectivity Ltd., which is considered the “data controller” of your personal information under European Union and UK data protection law. Our address is Data Protection Officer, Jungo Connectivity Ltd., 1 Hamachshev st., Netanya 4250711, Israel. Our email is privacy@jungo.com.
Your use of the Services is subject to the Terms of Use, Copyright Policy and this Privacy Policy and indicates your consent to them.
The Services are not intended for use by persons under the age of 13. If you are under 13, you may not download or use the Application.
In this Privacy Policy, the term "personal information" means any information collected by us or provided by you that, with reasonable efforts, may be used to identify you, which may include name, email address, phone, title, work organization, and similar information, and in certain circumstances, your location and route information, and images or videos taken using the application.
== Contact Jungo / Abuse reports ==
If you believe that your privacy has been compromised by any person, in the course of using the Services, then please contact Jungo at: privacy@jungo.com.
You may send Jungo other requests, responses, questions and complaints by email at support@jungo.com.
== Information that is being collected ==
Jungo collects information about you provided in the various web forms in the Web site, including name, email address, phone, title, work organization, and similar information. Jungo also collects information provided by you using the Application.
Jungo allows you to use the Services, link all of your information with your account and a unique identifier generated by Jungo (typically related to your provided email address) in accordance with this Privacy Policy.
The categories of information collected by Jungo will include all or just some of the following, depending on how you choose to use the Services.
Whenever you use the Services, Jungo may collect:-
o information you provide to us about yourself, such as name, email address, phone, title, work organization, and similar information.
o detailed location and route information, for example in the form of GPS signals, accelerometer, gyro, compass and other information provided by the mobile application or hardware device on which the Application is installed and activated. and
o information about your use of the Services. See “Meta-data that we collect”, below; and
o events related to car sensors, road events, driver events or other driving related events; and
o anonymized statistical information (such as trips distrances and durations); and
o images short video clips related to such events, used to analyze and improve our algorithms and create database of events.
Please note that when you first provide your personal information in the Web site forms or install the Application on your mobile device, Jungo will set up an account associated with you (the “Account” ) based on the email you specify. Jungo will collect and use your information, in accordance with this Privacy Policy, whenever you access the Web site or activate the Application on that mobile device. This use includes linking your information with your Account.
In order to access certain features of the Services (for example, storing of data and events in the our clouds), you will need to specify an email.
o Jungo will link all of your information with your Account and that email. This includes information received from all mobile devices running the Application on which you have chosen to sign in using your email and password;
o with the exception described in the bullet below, your Account and information associated with your Account will be visible only to Jungo; and
o when using the Application, your approximate location and other information you may choose to contribute will be visible to other users associated with that email.
== Uses of information ==
Jungo may use information collected from or provided by you for the following purposes:
o to provide you with the Services. For example, Jungo may:- use your location and route information to provide real time alerts about other drivers and to provide information and advertisements about sites, shops and other places and attractions in your close vicinity, or that we believe, based on your search query history, you may find interesting.
o to contact you for marketing or sales purposes around Jungo products, or enable Jungo local regional partners to contact you sales of Jungo products you expressed interest in (e.g filled web forms on).
o to operate the Services and to improve and customize your experience with the Services. For example, Jungo may use your videos to improve our algorithms and deliver better experience to all the users;
o to improve the experience of other users. For example, Jungo may use your road and driver events information to improve the safety of other users;
o to provide you with support and handle requests and complaints;
o to send you updates, notices, announcements, and additional information related to the Services;
o to display or send to you marketing and advertising material when you are using the Application, in accordance with the section titled 'Advertising Campaigns' under this Privacy Policy. For example, Jungo may use your location information to display advertisements for businesses in your close vicinity;
o subject to your prior indication of consent, we may also use the email address that you provide when setting up an account to send you marketing material. At any time you may choose not to receive such material by clicking on the “Unsubscribe” link in the e-mail messages that we may send to you. In any case, Jungo will not knowingly share your personal information with any advertisers, without your explicit consent and as allowed for under this Privacy Policy;
o to create aggregated data (where such data does not enable the identification of a specific user). See “How does Jungo use aggregated information”, below;
o to use anonymized data for any purpose (where such data does not enable the identification of a specific user);
o to conduct surveys and questionnaires;
o to share your submissions with other users of the Services and to facilitate communication between you, Jungo and other users;
o to enforce the Terms of Use;
o to contact you when Jungo believes it to be necessary;
o to comply with any applicable law and assist law enforcement agencies under any applicable law, when Jungo has a good faith belief that Jungo’s cooperation with the law enforcement agencies is legally mandated or meets the applicable legal standards and procedures;
o to prevent fraud, misappropriation, infringements, identity theft and other illegal activities and misuse of the Services;
o to handle breakdowns and malfunctions;
o to take any action in any case of dispute, or legal proceeding of any kind between you and the Service, or between you and other users or third parties with respect to, or in relation with the Service;
o for purposes provided under this Privacy Policy and the Terms of Use.
Please note that the email you provide will be used to identify you when you use the Services. Your email will be included along with any information you submit for posting (such as traffic reports or chat messages). It will therefore be visible to others. If you prefer to remain invisible to other users of the Services for a particular drive, you can set the Application not to show your location on the map. To do so you should go to the Application Settings Menu and adjust accordingly. If you make this choice, while you will be invisible to other users, your location and route information will continue to be collected by Jungo for the purposes listed in this Privacy Policy.
You may also provide additional information that will be used to personalize the Services and enhance your experience with the Services.
Further information may be collected when Jungo exchanges communications with you, for example, if you submit a request, contact Jungo's support team, or report a violation to the abuse team.
== Personal information that you share ==
The Services are based on a community of users publicly sharing information with Jungo and with other members of that community.
In particular, users choose to share personal information such as name, picture, their location information and reports. This information may be shared either directly to the Service and to all users, such as in the case of traffic reports, or just to your friends on Jungo via the ‘find friends’ feature . This information may also be shared via third party services (such as social networks) which interact with the Service upon such users' choice.
The content that you share to all users is neither private nor confidential and you should not have any expectation of privacy with respect to it. Information you upload will be posted along with other personal information. Certain road incidents you report may include your driving path within the vicinity of those incidents. Therefore, you must exercise caution and common sense when submitting information. At the very least you should demonstrate the same degree of caution as when publishing personal information by means other than the Internet and cellular services.
You can decide whether or not to upload content to the Services. However any content that you submit for posting, may be viewed by all users of the Services and by Jungo.
For any content you upload on behalf of your users or employees (e.g drivers, people, patients, subjects, service providers), you confirm you have obtained their permission and concent to upload such content.
In any event (but except as detailed below with respect to information shared from your social network accounts according to your privacy settings for such social network accounts), your email address will not be visible to others through any reports or user posts that you share or upload.
We, at Jungo, take great measures to provide you with the best experience you can have while using the Service. However, Jungo has no control over the conduct of any user and disclaims all liability in this regard. Users are advised to carefully and thoroughly consider whether or not to make public or available any information and carefully examine all necessary details related to any communication with other users prior to any engagement or communication being made.
Participating in any user's activities as a result, directly or indirectly, from using Jungo, is entirely at your own risk. Jungo is not a party to any agreement entered into between the users in any circumstances. The user has the sole and ultimate responsibility regarding compliance with all laws, regulation or any other duty. We do not accept any liability for any loss, damage, cost or expense that you may suffer or incur as a result of or in connection with your participation in any activity or event initiated, held or conducted by a user or a third party nor in connection to any agreement between the users or third parties, including any activity or event related in any way, directly or indirectly, the Services or the use thereof.
== Meta-data that we collect ==
Jungo collects information about the use of the Services. For example, Jungo may record video clips while using the application, the frequency and scope of your use of the Services, the duration of your sessions, information about the device on which you have installed the Application, the web pages that you visit via the Application, information that you read, content that you use or create, advertisements that you view or click on, your communications with other users and third parties, the Internet protocol (IP) address and the name of the domain that serve you to access the Services, and the geographic location of the computer system that you are using to log-in.
== Accessing the Services ==
In order to access certain features of the Services, you will need to set up an account using your email address.
Jungo may also establish and require from time to time additional or different means of identification and authentication for logging in and accessing the Services or for accessing certain features or designated sections of the Services.
Your log-in details are your responsibility. You are fully accountable for any use or misuse of your Account and personal details as a result of conveying your details to someone else. You must maintain your log-in details in absolute confidentiality and avoid disclosing them to others. Make sure that you change your password frequently and at least once every six months.
== Sharing information with others and third parties ==
Jungo will not share your personal information with others, without your consent, except for the following purposes and to the extent necessary in Jungo's good-faith discretion:
o As necessary for the operation of the Services.
o With suppliers/partners/service providers that are required as part of the Service.
o For local business, support or sales representatives of Jungo partnersrelated to one of Jungo services.
o For communicating with you using third party services such as mailing list management or cloud hosting companies.
o If Jungo reasonably believes that you have breached the Terms of Use, or abused your rights to use the Services, or performed any act or omission that Jungo reasonably believes to be violating any applicable law, rules, or regulations. Jungo may share your information in these cases, with law enforcement agencies and other competent authorities and with any third party as may be required to handle any result of your wrongdoing;
o If Jungo is required, or reasonably believes that it is required by law to share or disclose your information;
o In any case of dispute, or legal proceeding of any kind between you and Jungo, or between you and other users with respect to, or in relation with the Services;
o In any case where Jungo reasonably believes that sharing information is necessary to prevent imminent physical damage or damage to property;
o If Jungo organizes the operation of the Services within a different framework, or through another legal structure or entity, or if Jungo is acquired by, or merged into or with another entity, or if Jungo enters bankruptcy, provided however, that those entities agree to be bound by the provisions of this Privacy Policy, with respective changes taken into consideration;
o For facilitating the Service and to store your data on servers located in the U.S.A and the European Union.
o To collect, hold and manage your personal information through cloud based or hosting services or a third party or a party affiliated or connected to Jungo, as reasonable for business purposes, which may be located in countries outside of your jurisdiction, including but not limited to the United States of America.
o Jungo may also share personal information with companies or organizations connected or affiliated with Jungo, such as subsidiaries, sister-companies and parent companies. Personal information may also be shared with Jungo's other partners and service providers to process it for us, based on our instructions and in compliance with this policy and any other appropriate confidentiality and security measures.
== Controlling your personal information ==
If you would like us to delete your Account, your email and your personal information, please contact us at privacy@jungo.com.
On receiving such a request, Jungo will use reasonable efforts to delete such information, however please note we may not delete information immediately from our back-up systems.
If you choose to set up a username, you can view your route history via the function on the Jungo website.
Your location and video clips are associated with your Account and your username.
This information is held by Jungo associated with your Account and username/ unique identifier for such limited period of time as is necessary in order for Jungo to be able to use the information for the purposes described in this Privacy Policy. At the end of this period of time, Jungo will then anonymize or delete your location and route information.
If you find that the information associated with your Account is not accurate, complete or updated, then you must make all necessary changes to correct it. Please keep in mind that false, incorrect, or outdated information may prevent you from setting up a username and impair the ability to provide you with Services.
== How does Jungo use aggregated information? ==
Jungo may use anonymous, statistical or aggregated information (including anonymous location information), in a form that does not enable the identification of a specific user, to properly operate the Services, to improve the quality of the Services, to enhance your experience, to create new services and features, including customized services, to change or cancel existing content or service, and for further internal, commercial and statistical purposes.
Jungo may also use anonymous, statistical or aggregated information collected on the Services, in a form that does not enable the identification of a specific user, by posting, disseminating, transmitting or otherwise communicating or making available such information to users of the Services, to the Services' providers, partners and any other third party. For example, GPS information that we receive from your mobile device may be provided to map editors in an aggregated and/ or anonymous form to help improve the map and solve map problems.
== What is our legal basis for using your personal information? ==
Jungo will only process your personal information where we have a legal basis to do so. The legal basis will depend on the reason or reasons Jungo collected and needs to use your information. Under EU data protection laws in almost all cases the legal basis will be:
o Because we need to use your information so that we can provide you the Service for you.
o Because it is in Jungo’ legitimate interests as a business to use your personal information to operate and improve our Service to you.
o Because Jungo needs to use your personal information to comply with a legal obligation.
o To protect the vital interests of you or another person.
o Because you have consented to Jungo using your information for a particular purpose.
If processing of your data is subject to any other laws, then the basis of processing your data may be different to that set out above and may in those circumstances be based on your consent in all cases.
== How long do we keep personal information? ==
We will keep your information for as long as we need it for the purpose it is being processed for. For example, where you provided your personal and route information, we will keep the information related to your route so you can later access it. The information may also be retained so that we can continue to improve your experience with us.
We will actively review the information we hold and delete it securely, or in some cases anonymise it, when there is no longer a legal, business or customer need for it to be retained. If you stop interacting with us as a customer, we will remove or anonymise your information after 7 years.
== Requesting a copy of your personal information ==
You may request a copy of any personal data about you held by Jungo. There is no fee for this request.
The request must be in writing to privacy@jungo.com and must contain the following:
Your name and email address.
Details of your request.
== What are your legal rights in relation to the personal information we hold about you? ==
Under data protection laws in the European Union, you have certain rights in relation to your personal information. Responses to exercise your rights will be provided within one month and generally there is no fee for making these requests. If your request is particularly complicated we may extend the deadline for responding to three months, but we will let you know if this is the case.
We will handle all requests in accordance with applicable law. However, depending on the right you wish to exercise, and the nature of the personal information involved, there may be legal reasons why we cannot grant your request. Further explanation of those rights and the exceptions to them are set out below.
Details of how to exercise your rights are set out in the section below “How can you exercise your legal rights and change how we use your data?
Your rights include the following:
You may request us to stop sending you marketing. You will have the appropriate "unsubscribe" link in the various marketing emails.
You may request us to stop processing of your personal information for marketing purposes including analytics for the purposes of targeted marketing, including online advertising.
You may access the personal information we hold on you.
There are some limited exceptions to this right, such as information relating to others who have not consented to the disclosure of their information and information which is legally privileged.
You may ask us to correct your personal information (the 'right of rectification’) if that information is inaccurate.
You may ask for personal information which identifies you to be erased (or forgotten).
To do this we will remove the information that identifies you from the data we hold in our active systems (“anonymise”). However, a separate and restricted copy of the identifying information will be kept for 7 years to meet the obligations we have to law enforcement, national authorities and legal proceedings.
Considerations:
We may need to retain certain elements that relate to a contract between you and Jungo because we need it for our own legal and auditing purposes.
A record of your request including the personal information you supplied will be retained in the application used to carry this out for 3 years.
== What countries will your personal information be sent to? ==
Your personal information may be sent to and stored by us and third parties in countries outside the country in which you are located and outside the European Economic Area.
For example, some servers and third party services we use are located in the USA.
== Cookies ==
Jungo may use cookies on the Services. Cookies are packets of information sent by the Website's servers to your web browser and then sent back by the browser each time it accesses the Website's servers.
Jungo may use cookies for various purposes, such as to save you the need to re-enter your username and password each time you log-in, to facilitate the use of the Website, to collect statistical information (e.g using Google Analytics), to verify information, and to customize the Website to your personal preferences and for information security purposes.
Some of the cookies may expire when the session ends and you exit your browser. Other cookies are saved on your computer's hard drive. If you wish to block the Website's cookies, then please use the help button in your browser and follow the necessary instructions. However, bear in mind that disabling cookies may complicate or even prevent your use of the Website, or certain features thereof.
== Information Security ==
Jungo considers information security to be a top priority. Jungo implements systems, applications and procedures to secure your personal information, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. However, these measures are unable to provide absolute assurance. Therefore, although Jungo takes great efforts to protect your personal information, Jungo cannot guarantee and you cannot reasonably expect that Jungo's databases will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.
== Changes to this Privacy Policy ==
Jungo may from time to time change the terms of this Privacy Policy. Substantial changes will take effect 30 days after Jungo has posted a:
o system message to users notifying them of changes to the Privacy Policy; and
o notification on the Website's homepage or any other relevant web pages, explaining the changes to the Privacy Policy alongside a comparison of the “old” and “new” versions of the Privacy Policy.
Other changes will take effect 7 days after their initial posting on the Website. However, if Jungo amends this Privacy Policy to comply with legal requirements, the amendments will become effective immediately upon their initial posting, or as required.
You agree to be bound by any of the changes made in the terms of this Privacy Policy. Continuing to use the Services will indicate your acceptance of the amended terms. If you do not agree with any of the amended terms, you must avoid any further use of the Services.