Privacy Policy

At Jumbea (“we” or “us”) we are committed to protecting and respecting your privacy. This Privacy Policy explains how we look after your personal information when you visit and use our community engagement platform at https://jumbea.com, our mobile sites or applications and where you access and use any of the tools and features that we provide through the Site (collectively, the “Services”). This Privacy Policy also tells you about your privacy rights with respect to your information. USE OF THE SITE AND THE SERVICES Authorized Users If a profile which you did not create yourself exists on this Site it is because the school or university identified on the Site (the “School”) or other club, group or organisation (together with the School, an “Organisation”) has shared certain information with us due to your affiliation with the Organisation (whether as a registered student, member of staff, alumni, parent, partner, employee, club member or other third party connected with the Organisation and authorized to access the Services). If we have received such information from your Organisation, your Organisation has authorized your access to, and use of the Site and Services and for purposes of this Privacy Policy, you will be referred to as an “Authorized User”. As an Authorized User, your Organisation is responsible for and administers your Jumbea account and is also responsible for the collection and use of any data that you submit or provide through the Services (including any messages, files or other content submitted through the Services) (collectively, “User Contributions”). We have a separate agreement with your Organisation which governs delivery, access and use of the Services (the “Organisation Agreement”). In addition to this Privacy Policy, your Organisation may have additional policies which apply in relation to your use of the Service. Authorized Users shall be referred to as “Users”. Your use of the Site and Services is governed by the Terms of Service and this Privacy Policy. If you have any questions about your use of the Services, including privacy settings and practices, please contact us at [email protected] Where appropriate, we will forward your message to your Organisation. WHO ARE WE AND HOW CAN YOU REACH US? We’re Jumbea Pty Ltd (“Jumbea”) and we operate the Site and provide the Services. If you would like to contact us for any reason, including (i) to obtain more information about how we have received your information from your Organisation or how we share your information with your Organisation; (ii) how we process your information; or (iii) if you have any questions about the Site or the Services generally, please contact us at: [email protected] INFORMATION WE COLLECT AND RECEIVE Personal data, or personal information, means any information about an individual from which that person can be identified. We may collect, use, store, transfer and receive different kinds of personal information about you when you access and use the Site or Services, which we have grouped together as follows (collectively “Data”): Identity Data includes name, Organisation identifiers (student ID, etc.), depending on what the Organisation decided to share with us. Contact Data includes email address(es) and phone numbers. Technical Data includes internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices used by the user to access the Site and/or the Services. Include logs of all requests made by the user to the site Profile Data includes username and password, memberships in a group which is part of an Organisation (a “Group”), membership end date, school program, degree, year of entry, year of graduation, work details (LinkedIn resume, company, work title), interests, preferences, feedback, surveys/forms/poll responses, platform join date, group officer status, validation status, opt-in subscriptions (sub-groups), member tags, posts on feeds. User Contributions includes any messages, photos, news, files or other content submitted through the Services by individual Users. Usage Data includes information about how Users use the Site and/or the Services – includes web analytics relating to usage of the Site and the platform in general and logs of all requests made by users to the Site, as well as usage of specific features of the Services such as events registration and attendance, tickets selected/purchased/cancelled, email engagement, member tags, likes and comments on feeds. Marketing and Communications Data includes any preferences in receiving marketing from us, Groups, the Organisation, other relevant third parties, plus any communication preferences – e.g. ways in which the user may be contacted. Support Data includes any information that users of the Site or the Services provide when they contact or engage platform support regarding the Services. We also collect, use and share Aggregated Data such as statistical and demographic data for any purpose. Aggregated Data may be derived from your personal information, but it does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature of the Service. However, if we combine or connect Aggregated Data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this Privacy Policy. Your university login credentials are not stored unless you accepted the automatic synchronisation. We only collect schedule information (course code, time, dates, instructor, location) and no other information is collected. We do not sell or distribute any data to third parties. HOW IS YOUR INFORMATION COLLECTED? We use different methods to collect information from and about you, including through: Direct Interactions You may submit certain Data when you use the Site and the Services. This includes (but is not limited to) personal information you share when you: Register or log on in your individual capacity or as an Organisation administrator (“Organisation Administrator”) or as a leader or an officer of your Group (“Group Officer”); Post material (including resumes, biographical information, and photos); Request further services, purchase tickets to an event, when you wish to join a Group, or when you report a problem with the Site or the Services. Please note that in some cases, recording your membership of a particular Group may involve the processing of Special Categories of Personal Data; Records and copies of your correspondence (including e-mail addresses), if you contact us; Respond to surveys that we, your Organisation or your Group might ask you to complete for research purposes; Contact us with feedback or queries; Post User Contributions on public areas of the Site or transmit to other users of the Site or third parties. Automated technologies or interactions As you interact with or navigate through the Site and the Services, we may automatically collect Data about your equipment, browsing actions and patterns. We may collect this information by using cookies and other similar technologies. Please note: you can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, some parts of the Site and the Services may then be inaccessible or not function properly. Please see our Cookie Policy for further details. You are not under a statutory or contractual obligation to provide us with any personal information. However, certain information is collected automatically and if you don’t provide some information, such as account set-up details, we may be unable to provide the Services to you. PURPOSES FOR WHICH YOUR INFORMATION IS USED All Users We process personal information, as applicable, for our legitimate business interests as follows: Contacting Organisation Administrators for invoicing, account management or other administrative reasons; Notifying you about changes to our Terms of Service or Privacy Policy or contacting you with other important Service-related messages, such as security and fraud notices; Carrying out data analytics, identifying usage patterns, customizing the Site and the Services to individual preferences, improving and enhancing user experiences, modifying the Site and the Services, developing new products and our business, auditing use and functionality of the Site and the Services, informing our marketing strategy, investigating and preventing service errors, security or technical issues, helping enforce compliance with our Terms of Service, protecting the Site and the Services, protecting our business; Asking you to complete a survey or feedback form to collect your views or comments on the services we provide, helping us study how Users use our products and services to develop and grow our business; Responding to your requests, comments or queries relating to your use of the Site and the Services; Subject to your marketing preferences, making suggestions and recommendations to you about goods or services that may be of interest to you or your Organisation. This may include emails about new product features, promotional communications or other Jumbea news. We may also process personal information as necessary to comply with a legal obligation. Where your Organisation has requested that we make the Services available to its Authorized Users under the applicable Organisation Agreement, your personal information may be used for the purpose of providing the Services to you. Some examples of how your information may be used include (but are not limited to): Publishing your Data to maintain an open directory of individuals affiliated with your Organisation and your Groups (the membership of which may reveal particularly sensitive information, such as religious or philosophical beliefs, political opinions, sexual orientation, or racial or ethnic origin); Sharing your Data with affiliates of your Organisation or Group; Sharing your Contact Data to enable you to receive communications from your Organisation, your Groups and other individuals affiliated with your Organisation; Enabling you to communicate with other individuals associated with your Organisation or your Groups; Enabling you to register for events. Groups and Membership Management; Group Page Administration; Creating, Promoting and Managing Events; Messaging; Creating and Managing Surveys, Forms & Polls; Facilitating Online Payments; Platform Analytics; Directory services; File Sharing; Discussion Feeds. FOR HOW LONG DO WE KEEP YOUR INFORMATION? Where we process your personal information on behalf of your Organisation, we will retain your information in accordance with your Organisation’s instructions and in accordance with any legal obligations. For all other personal information, we will only keep it for as long as necessary to fulfil the purposes we collected it for as set out in this Privacy Policy. When you connect your account with third party apps & platforms, such as Google Calendar or Zoom, we also store the data required for the integration you selected. When you disconnect the integration, the tokens used to access your data on the third party platform are deleted. Data which was retrieved through the integration prior to it being disabled may still be available on the platform if it is still in use, such as the Zoom meeting link for an event, unless specifically deleted. You may find additional details on how to disconnect an existing integration or how to delete your data on our help center. HOW IS YOUR INFORMATION SHARED AND DISCLOSED? This section describes how we may share and disclose your information. Please note that Organisations determine their own policies and practices for the sharing and disclosure of information. Organisation’s Instructions Where we collect or receive personal information from Authorized Users and Independent Users through their use of the Site and the Services, we will only share and disclose information in accordance with the Organisation’s instructions, including any applicable terms in the Organisation Agreement and in compliance with applicable law. Directory Services Unless you (or your Organisation, if relevant) have updated your privacy settings to “private”, we may disclose personal information that we collect, or you submit, as described in this Privacy Policy to provide an active and open directory of individuals affiliated with your Organisation, to your Organisation, your Groups, and to individuals who access your Organisation’s or your Group’s pages. For Trial Users of Directory Services, your personal information will only be available to those individuals authorized to access the trial platform. Aggregated Information We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. Organisation Access Organisation Administrators, Group Officers, and other Organisation representatives and personnel may be able to access, modify or restrict access to your personal information. This may include, for example, your Organisation using features of the Services to export activity logs or modifying access to other Service features. Organisation Administrators may also have access to your personal information where you create an account to access certain Services as an Independent User. If you have any questions about your Organisation’s account settings, please contact us at [email protected] Where appropriate, we will forward your message to your Organisation. Third Party Service Providers working on our behalf. We may pass your information to our third-party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf or on behalf of your Organisation or your Groups. Sale of Our Business/Legal Requirements We may transfer your personal information to a third party as part of a sale of some or all of our business and assets or as part of any business restructuring or reorganisation, or if we’re under a duty to disclose or share your personal information in order to comply with any legal obligation or to enforce or apply our Terms of Service or to protect the rights, property or safety of our supporters and customers. Additional Sharing of Your Information We may also share your information with other companies and organisations for the purposes of fraud protection and credit risk reduction. As a data processor we may use your Data in accordance with the written instructions of your Organisation (as data controller), including any applicable terms in the Organisation Agreement, and as required to comply with a legal or regulatory obligation. As a data controller, we will use your Data: Where we have your explicit consent (for example, to collect and store Special Categories of Personal Data). Where we need to perform the contract we are about to enter into or have entered into with you. Where it is necessary for our legitimate business interests in operating the Site and providing the Services (including carrying data analytics on the Site and the Services or the purposes set out in this Privacy Policy). Where we need to comply with a legal or regulatory obligation. SECURITY We have implemented appropriate security measures designed to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. All data we collect is stored securely on our servers. Firewalls are in place exposing only the necessary services to the Internet as well as between our servers. All information transmitted between your browser and our servers is encrypted using industry standard security protocols. We have put in place procedures to deal with any suspected personal data breach and will notify you or your Organisation (if applicable) and any relevant data protection regulator of a breach where we are legally required to do so. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site and the Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Site. The information you share in public areas may be viewed by any user of the Site. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site. LINKS TO OTHER WEBSITES Our Site may contain links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy notice of every website you visit. 16 OR UNDER Our Site is not intended for children under 16 years of age. If you are under 16, do not use or provide any information on the Site. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at [email protected] YOUR LEGAL RIGHTS You have the right to: Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: • if you want us to establish the data’s accuracy; • where our use of the data is unlawful but you do not want us to erase it; • where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims;or • you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. You can exercise any of these rights at any time by contacting us at [email protected] CHANGES TO THIS PRIVACY POLICY We may change this Privacy Policy from time to time so please check this page occasionally to ensure that you are comfortable with any changes. By using the Site and the Services, you’re agreeing to be bound by this Privacy Policy. This version was last updated on 15/07/2020.