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Last updated 10/12/24
Jiminny, Inc. (together with its affiliate companies – “Jiminny”, “we”, “our” or “us”) respects your privacy and is committed to transparent privacy practices. This “Privacy Notice”, together with our "Cookie Policy" describes how we collect, use, store and share the personal data provided to us or otherwise collected by us.
If you are our customer, user, visitor or prospect (“you”), please read this Privacy Notice carefully and make sure that you fully understand and agree to it.
You are not legally required to provide us with any personal data, and may do so (or avoid doing so) at your own free will. If you do not wish to provide us with your personal data, or to have it processed by us or any of our Service Providers (defined below), please avoid any interaction with us or use of our Services. If you are a user of the Platform on behalf of any of our customers, we suggest that you contact your account administrator with any questions.
Customer Data is data relating to identifiable individuals (“Personal Data”), which we analyze, process and manage on our customers’ behalf, as part of the Jiminny Conversation Intelligence Services (“Services”). Specifically, this is data which is contained in call and video recordings, transcripts, e-mails, text messages and other communications and content, as well as data submitted by our Customers (including by connecting their systems with the Services);
Our Services enable Jiminny Customers to record, transcribe, analyze and share the contents of their business communications, including phone calls, video conferences, emails and text messages, as well as their CRM and customer contacts (collectively, “Customer Data”).
Customer Data typically contains data which relates to identifiable individuals, such as the customer’s sales representatives, prospects, and other parties either taking part in their communications or mentioned there.
Certain privacy and data protection laws require that call recordings may only be initialized pursuant to one or more of the parties’ consent (whether explicit or implicit, depending on applicable law), or subject to certain restrictions. Accordingly, whilst Jiminny supports these laws by providing our customers with features and options for how they use our Services – our customer is solely responsible for determining whether and how they wish to use our Services and such features, and to ensure that all individuals using Jiminny on their behalf or at their request have given their informed consent to these practices, and that all legal requirements applicable to the collection, recording and use of data through our Services are fully met by them, including specifically in the context of an employment relationship.
Jiminny processes Customer Data, and the personal data contained in it, strictly on our customer’s behalf, in accordance with their reasonable instructions and as further stipulated in our Data Processing Addendum and other commercial agreements with such customer.
Accordingly, to the extent that the EU’s General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), UK’s General Data Protection Act, UK Data Protection Act (UKDPA) or any similar laws apply, our Customers will be deemed the ‘Data Controllers’ (under the GDPR, UK GDPR, UKDPA and similar laws) or ‘business’ (under the CCPA or similar laws) which controls such Customer Data; and Jiminny will be deemed the ‘Data Processor’ or ‘service provider’ when processing such data.
User Data is account, contact and activity data relating to individuals who use the Jiminny platform, Sidekick application, mobile application, and other tools and features provided by us as part of the Services (collectively – “Platform”);
We collect and generate the following types of personal data concerning users of our Platform:
Whilst Jiminny processes such User Data on its customers’ behalf (where it is included in Customer Data), we also use it for our own purposes, as described in Section 3 below. Accordingly, to the extent applicable – our customer will be deemed the ‘Data Controller’ or ‘business’ with respect to such data; Jiminny will also be deemed an independent and separate ‘Data Controller’ or ‘business’ with respect to such data; and with respect to those portions or copies of User Data that we process on behalf of our customer – we will also be deemed a ‘Data Processor’ or ‘service provider’.
Website, CRM & Prospect Data is data relating to our customers, visitors of our website (www.jiminny.com), participants at our events, and any other prospective customer or partner who visits or otherwise interacts with any of our websites, online ads and content, emails or communications under our control (“Sites”).
We collect and generate the following types of personal data concerning our website visitors, customers and prospects:
We collect such data either automatically, through the data subject’s interaction with us or with our website, Platform or Services; or through third party services, social media, analytics tools, events we organize or participate in, and other business initiatives.
Certain data protection laws and regulations, such as the GDPR or the CCPA, typically distinguish between two main roles for parties processing Personal Data: the “Data Controller” (or under the CCPA, “business”), who determines the purposes and means of processing; and the “Data Processor” (or under the CCPA, “service provider”), who processes the data on behalf of the Data Controller (or business). Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.
Jiminny is the “Data Processor” of Customer Data, which we process on behalf of our Customer’s (who are the “Data Controllers” of such data. Our Service Providers who process such Customer Data on our behalf are the “sub-Processors” of such Customer data.
Accordingly, Jiminny processes Customer Data strictly in accordance with such Customer’s reasonable instructions and as further stipulated in our Data Processing Addendum and other Commercial Agreements with such Customer. The Customer, as Controller of such data, will be responsible for meeting any legal requirements applicable to Data Controllers (such as establishing a legal basis for processing and responding to Data Subject Requests concerning the data they control).
For the avoidance of doubt, each Customer is solely responsible for providing adequate notice to their Account Users and Customers whose data may be contained in Customer Data – including sufficient reference to the processing of their Personal Data via the Services, and any other information necessary to comply with all applicable privacy and data protection laws; and to obtain all approvals and consents from such individuals as required under such laws.
Jiminny is both a “Data Controller” and “Data Processor” of User Data. Such data is processed by Jiminny for its own purposes (as described in Section 3 below), as an independent ‘Controller’; whilst those certain portions of it which are included in Customer Data will be processed by us on our Customer’s behalf, as a ‘Processor’.
With respect to such data, we assume the responsibilities of "Data Controller" (solely to the extent applicable under law), as set forth in this Privacy Notice. In such instances, our Service Providers processing such data will assume the role of “Data Processor”.
Jiminny processes Customer Data, and the personal data contained in it, strictly on our Customer’s behalf, in accordance with their reasonable instructions and as further stipulated in our Data Processing Addendum and other Commercial Agreements with such Customer.
We use other types of Personal Data as necessary for the performance of our Services; to comply with our legal and contractual obligations; and to support our legitimate interests in maintaining and improving our Services, e.g. in understanding how our Services are used and how our campaigns are performing, and gaining insights which help us dedicate our resources and efforts more efficiently; in marketing, advertising and selling our Services; providing customer service and technical support; and protecting and securing our Customers, Users, Visitors, Prospects, Ourselves and our Services.
If you reside or are using the Services in a territory governed by privacy laws under which “consent” is the only or most appropriate legal basis for the processing of Personal Data as described herein (in general, or specifically with respect to the types of Personal Data you expect or elect to process or have processed by or via the Services, e.g. ‘special categories’ under the GDPR), your acceptance of our Terms and Conditions and acknowledgement that you have read and understood this Privacy Notice will be deemed as your consent to the processing of your Personal Data for all purposes detailed in this Notice. If you wish to revoke such consent, please contact us at privacy@jiminny.com.
Specifically, we use this type of Personal Data for the following purposes:
We retain Customer Data strictly on our Customer’s behalf, in accordance with their reasonable instructions and as further stipulated in our Data Processing Addendum and other Commercial Agreements with such Customer.
We will only retain your personal information for no longer than is reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.
We and our authorized Service Providers (defined below) maintain, store and process Personal Data in the United States of America, Ireland, the United Kingdom and other locations, as reasonably necessary for the proper performance and delivery of our Services, or as may be required by law; provided that Customer Data may only be processed in such locations as permitted in our Data Processing Addendum and other Commercial Agreements with such Customer.
While privacy laws may vary between jurisdictions, Jiminny and its affiliates and Service Providers are each committed to protecting Personal Data in accordance with this Privacy Notice and customary industry standards, regardless of any lesser legal requirements that may apply in their jurisdiction. Among others, we have ensured that all transfers of Personal Data which originates from the EEA and made at our direction or control are based on appropriate data transfer mechanisms as established under the GDPR.
Jiminny complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce and will be further liable in cases of onward transfers of your personal data to third parties (including our Service Providers).
Jiminny complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Jiminny has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF.
Jiminny has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms of this Privacy Notice and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.
Types of Data Shared
Categories of Data Recipients or Third Parties
Business or Commercial Purpose
Legal Basis
Marketing Information;
Enquiry Information;
Customer Data;
Cookie Data.
Third-Party Data Processors, who provide/facilitate the following services:
To send you marketing communications (where requested)
To analyze the effectiveness of our marketing materials;
To contact you;
To fulfill your requests;
To provide our services to you;
To store our emails and data;
To store our documents;
Fulfillment of a Contract
Legitimate interest
Consent
We engage selected Third-Party Companies and individuals to perform services complementary to our own. Such service providers include hosting and server co-location services, communications and content delivery networks (CDNs), speech-to-text services, data and cyber security services, billing and payment processing services, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session or activity recording services, remote access services, performance measurement, data optimization and marketing services, social and advertising networks, content providers, e-mail, voicemails, support and Customer Relation Management systems, and our legal, financial and compliance advisors (collectively, “Service Providers“).
Our Service Providers shall each be deemed as a ‘Data Processor’ or ‘service provider’ in circumstances where Jiminny assumes the role of ‘Data Controller’; and where Jiminny acts as the ‘Data Processor’ or ‘service provider’ for our Customer, the Service Provider shall be deemed as our ‘sub-Processor’ or ‘service provider’ (as further described in Section 2 above).
Accordingly, these Service Providers may have access to User Data and Website, CRM & Prospect Data; and if we have expressly listed them in our Sub-Processor List, they may also have access to Customer Data — all depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use it for such limited purposes as determined in our Agreements with them.
Our Sites and Platform may include links to third-party websites, and integrations with third-party services. Such websites and third-party services, and any information you process, submit, transmit or otherwise use with such websites and third-party services, are governed by such third party’s terms and privacy practices and policies, and not by this Privacy Notice. We encourage you to carefully read the terms and privacy policies of such website and third-party services. Jiminny’s use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.
We may share Personal Data internally within our group, for the purposes described in this Privacy Notice. In addition, should Jiminny or any of its subsidiaries or affiliates undergo any change in control or ownership, including by means of merger, acquisition or purchase of substantially all or part of its assets, Personal Data may be shared with or transferred to the parties involved in such an event. If we believe that such change in control might materially affect your Customer Data or Personal Data then stored with us, we will notify you of this event and the choices you may have via e-mail or prominent notice on our Services.
Customer Data is typically shared and is available to the users belonging to such Customer’s Account. User Data is shared with the administrator(s) of the Customer’s Account to which such user belongs (including data and communications concerning such user’s account). In such cases, sharing such data means that the administrator(s) or other users of the same account may access it on behalf of the Customer, and will be able to monitor, process and analyze the Personal Data contained therein. This includes instances where you may contact us for help in resolving an issue specific to a team of which you are a member (and which is managed by the same Customer).
Please note that Jiminny is not responsible for and does not control any further disclosure, use or monitoring by or on behalf of the Customer, that itself acts as the ‘Data Controller’ of such data (as further described in Section 2 above).
In exceptional circumstances, and except as stipulated otherwise in our Data Processing Addendum and other Commercial Agreements with you, we may disclose or allow government and law enforcement officials access to your Personal Data, in response to a Subpoena, Search Warrant or Court Order (or similar requirement), or in compliance with Applicable Laws and Regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our products and services.
We and our Service Providers use cookies, pixels, and other technologies to enhance and improve our services, track site performance, perform analytics, and gain insights into service usage and activity performance, as well as for personalization purposes.
Cookies are small data packets sent to your web browser, which then sends them back to the server each time it accesses the site. Some cookies are deleted when you close your browser session, known as "Session Cookies." Others last for longer periods and are called "Persistent Cookies." We use both types.
"Persistent Cookies" help us remember your login details, making it easier for you to log in the next time you access the platform. We may also use these cookies and session cookies for additional purposes, such as facilitating the use of service features and tools.
Certain cookies are essential for our services to function properly and cannot be declined or disabled unless you delete and block them through your web browser settings. Other cookies, used for functional, performance, analytics, and marketing purposes, are optional. These include Google Analytics, which helps us understand user behavior on our services by tracking page content, clicks, movements, scrolls, and keystroke activities. You can find more information about Google Analytics' privacy practices at: https://www.google.com/policies/privacy/partners/. To opt out visit: https://tools.google.com/dlpage/gaoptout.
You can opt-in or opt-out of the use of optional cookies through the "Cookie Declaration" feature on our website. Opting out of certain cookies typically generates a new cookie that preserves your choice and informs our services during future visits so that the opted-out cookies are not utilized. You can also manage your cookie preferences and accept, remove, or entirely block cookies through your browser settings.
Please note that if you get a new device, install a new browser, or erase or otherwise alter your browser's cookie file (including upgrading certain browsers), you may clear the opt-out cookies installed once you opt-out. Therefore, you may need to opt-out again to prevent additional tracking.
We use appropriate security measures to protect the security of your personal information both online and offline. These measures vary based on the sensitivity of the personal information we collect, process and store and the current state of technology. We also take measures to ensure Service Providers that process personal data on our behalf also have appropriate security controls in place.
Please note that no service is completely secure. While we strive to protect your data, we cannot guarantee that any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse will never occur.
To protect the confidentiality of your account and protect from unauthorized use of your account, we recommend enabling two-factor authentication for all of your external accounts used to sign-in to our Sites, Platform or Services.
If you are resident in Europe (or a country that has adopted GDPR into their local legislation, such as the UK), you will have certain rights and we are obliged to provide you with specific information about how we use your Data.
You have certain rights with respect to your Data. These are:
If you are resident in California, the California Consumer Privacy Act of 2018 requires us to provide you with information about your rights and how we have used your Data in the past 12 months. Defined terms used in this section have the meaning given to them in the CCPA, which is available here.
You have the right to request information about whether we process your personal data and to obtain details necessary to ensure transparency and exercise your rights. This includes:
We will provide this information free of charge within 30 days, except where exceptions apply under Swiss law. For requests involving health-related data, we can communicate this through a healthcare professional of your choice, if required.
If you are resident in California, the California Consumer Privacy Act of 2018 requires us to provide you with information about your rights and how we have used your Data in the past 12 months. Defined terms used in this section have the meaning given to them in the CCPA, which is available here.
You have certain rights with respect to your Data:
The CCPA defines a specific list of categories of Personal Information and requires that we indicate each category of personal information we collect, why we collect it, where we get it from, and to whom we disclose it for a business purpose. Each of these is addressed below.
The categories of Personal Information we have Collected about Consumers in the previous 12 months is set out below as well as those we have disclosed for a Business Purpose.
CCPA Category
Collected
Disclosed
(A) Identifiers such as real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
Yes
No
(B) Consumer Records (Personal Information described in subdivision (e) of s. 1798.80 of the Californian Civil Code) including name, signature, social security number, physical characteristics or description, telephone number, state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
No
No
(C) Protected characteristics (as set out under California or federal law)
No
No
(D) Commercial information including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
No
No
(E) Biometric information.
No
No
(F) Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.
Yes
No
(G) Geolocation data.
Yes
No
(H) Audio, electronic, visual, thermal, olfactory, or similar information.
Yes
No
(I) Professional or employment-related information.
Yes
No
(J) Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, Sec. 1232g; 34 C.F.R. Part 99)
No
No
(K) Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Yes
No
(L) Sensitive Personal Information
No
No
We have not Sold or Shared any Personal Information of Consumers in the previous 12 months
Information about the sources from which Personal Information is Collected is set out in the ‘Data Collection & Processing’ section of the part of this Privacy Notice that relates to how you are interacting with us.
Information about our Business or Commercial Purposes is set out in the ‘Our Legal Basis for Processing’ section of the part of this Privacy Notice that relates to how you are interacting with us.
Information about the categories of third parties to whom we disclose Personal Information is set out in the ‘Data Sharing’ section of the part of this Privacy Notice that relates to how you interact with us.
Jiminny does not sell personal data to third parties. Where the definition of “sale” includes data sharing for monetary or other valuable considerations, We confirm that We do not engage in such activities. Any sharing of personal data is limited to purposes outlined in this Privacy Notice, such as providing our services, complying with legal obligations, or based on your explicit consent, where required. All data sharing is governed by stringent contractual or legal safeguards to ensure the security and integrity of your information.
10.4.2. Jiminny’s Compliance with the DPF Requirements, Compliant Resolution and Oversight by the FTC
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Jiminny commits to cooperate and comply respectively with the advice of the panel established by the EU Data Protection Authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF.
Please note that under certain conditions (as described under the DPF Principles that Jiminny adheres to), you can invoke a binding arbitration by delivering a notice to us via dpo@jiminny.com. Please also note that Jiminny is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
In accordance with global data privacy regulations, including the GDPR and CCPA, we respect your choices regarding the use and disclosure of your personal data. This means that we are committed to providing you with clear options and the ability to control how your personal information is handled. Our approach is designed to ensure that your data is used in ways that you have explicitly agreed to, and that you are fully informed about any potential uses or disclosures of your information.
We will obtain your affirmative express consent (opt-in) before:
Ii. using your personal information for a purpose other than those for which it was originally collected or subsequently authorized by you.
You can provide your opt-in consent through our website settings or by contacting us directly at privacy@jiminny.com If you do not provide your consent, your data will not be shared with third parties or used for new purposes.
If you wish to exercise any of your other rights as detailed under section 8 above, please contact us at privacy@jiminny.com.
If you wish to object to our use of your email address for direct marketing purposes, please click on the ‘unsubscribe’ link at the bottom of any of our marketing emails.
We engage in service and promotional communications, through e-mail, phone, SMS and notifications.
We may contact you with important information regarding our Services. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Services, billing issues, service changes, log-in attempts or password reset notices, etc. Our Customers, and other Users on the same Customer Account, may also send you notifications, messages and other updates regarding their or your use of the Services. Such notifications and messages may also be sent by them to their own Customers (for example, invites, recordings or meeting summaries created through our Services). You can typically control your communications and notifications settings from your Jiminny User profile settings, or otherwise in accordance with the instructions included in the communications sent to you. Please note that you will not be able to opt-out of receiving certain service communications which are integral to your use (like billing notices).
When you consent to receiving marketing communications from Jiminny, we may notify you about new features, additional offerings, events, special opportunities or any other information we think you will find valuable, as our Customer, User or Prospect. We may provide such notices through any of the contact means made available by you to us (e.g. phone, mobile or e-mail), through the Services, Platform or Sites, or through our marketing campaigns on any other sites or platforms.
We may change our Privacy Notice from time to time. If we make changes we’ll revise the “Effective” date at the bottom of this document, and we will make our best efforts to provide prior notice on our Sites, Platform and/or Services. After such notice period, all amendments shall be deemed accepted by you. We will comply with applicable law with respect to any changes we make to this document and seek your consent to any material changes if this is required by applicable law.
Jiminny does not knowingly acquire or receive Personal Data from children under 16, and do not wish to do so. If we later learn that any User of our Services is under the age of 16, we will take appropriate steps to remove that User’s information from our account database and will restrict that individual from future access to the Service.
We do not collect or process Sensitive Personal Information of Users or Customers. If this changes, we will update our Privacy Notice accordingly and seek your consent before processing such information.
We hope we can resolve any concerns regarding Personal Data held with us. You can raise your concern or dispute by emailing our Data Protection Officer at dpo@jiminny.com or by writing to us at:
Jiminny Holdings Limited, Floor 2, 100 Fenchurch Street, London EC3M 5JD.
Jiminny Holdings Limited is registered as a Data Controller with the Information Commissioner’s Office (ICO) in the UK (0303 123 1113 https://ico.org.uk/) under the current UK GDPR (which is the equivalent of the General Data Protection Regulation((EU) 2016/679) ("GDPR")) and The Data Protection Act 2018 (DPA) legislation.
For those in the EEA or Switzerland, if you have a dispute with us relating to our data protection practices or are not satisfied with how we’ve addressed your concerns or questions, you may complain to an independent dispute resolution provider, at no cost to you. You also have the right to lodge a complaint with your local data protection authority.
If you have any comments or questions regarding our Privacy Notice please contact Jiminny’s DPO at dpo@jiminny.com.
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