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Privacy Policy

We at Jugl Inc (“Jugl”, “us”, “we”, or “our”) recognize and respect the importance of maintaining the privacy of our Customers and their Personnel. This Privacy Notice describes the types of Personal Data (as defined below) we collect from you when you visit our website (“Site”) and/or use our Platform or App (collectively, the “Services”), and also how we collect, process, transfer, store and disclose such Personal Data. It also describes how you are able to control certain uses of the Personal Data. “You” means any adult user of the Site, App, Platform and/or Services.

“Personal Data” means any information that refers to, is related to, or is associated with an identified or identifiable individual or household.

Our Role:

Privacy Notice Key Points:

The key points listed below are presented in further detail throughout this Privacy Notice. You can click on any section to find out more information about any topic.

Personal Data We Collect, Uses and Legal Basis

1.1 Site Visitors

1.2 Account Owners, Administrators & Employees

1.1 Account Owners, Administrators & Employees – If you are a visitor to the Site, we collect the following types of Personal Data from you:

1.1.1 Contact Information

1.1.2 Automatically Collected Data

1.2 Site Visitors If you are an Account Owner, Administrator, or an Employee (which includes service providers or independent contractors of one of our Customers) (collectively, a “User”), using the Platform and/or an App in connection with a Customer account, we collect the following types of Personal Data from you:

1.2.1 Registration Data

1.2.2 Payment Data

1.2.3 Automatically Collected Data

1.2.4 Materials You Upload

1.2.5 Geo-location


Program Description:

2.1. Service Communications: We may send you service-related communications, including service announcements and administrative messages (such as log-in attempts or password reset attempts).

2.1.2. Promotional Communications We may contact you by email or through other communication channels approved by you. We may send promotional and transactional mobile messages in various formats through the Program. Promotional messages advertise and promote our products and services and may include [promotions, specials, other marketing offers, and abandoned checkout reminders]. Transactional messages relate to an existing or ongoing transaction and may include [order notifications and updates, appointment reminders, and other transaction-related information]. Mobile messages may be sent using an automated technology, including an autodialer, automated system, or automatic telephone dialing system. Message frequency will vary [but will not exceed 2 messages per day]. You agree that we, our affiliates, and any third-party service providers may send you messages regarding the foregoing topics or any topic and that such messages and/or calls may be made or placed using different telephone numbers or short codes, except in connection with marketing purposes. We do not charge for mobile messages sent through the Program but you are responsible for any message and data rates imposed by your mobile provider, as standard data and message rates may apply for short message service and multimedia message alerts.

2.1.3. User Opt-In: By providing your mobile phone number to us, you are voluntarily opting in to the Program and you agree to receive recurring mobile messages from us at the mobile phone number associated with your opt-in, even if such number is registered on any state or federal “Do Not Call” list. You agree that any mobile phone number you provide to us is a valid mobile phone number of which you are the owner or authorized user. If you change your mobile phone number or are no longer the owner or authorized user of the mobile phone number, you agree to promptly notify us at support@jugl.com. Your participation in the Program does not require that you make any purchase from us and your participation in the Program is completely voluntary.

2.1.4 User Opt-Out and Support: You may opt-out of the Program at any time. If you wish to opt-out of the Program and stop receiving mobile messages from us, or you no longer agree to these Mobile Messaging Terms, reply STOP, OPT-OUT and/or UNSUBSCRIBE to the mobile number the message is sent from. You may continue to receive text messages for a short period while we process your request and you may receive a one-time opt-out confirmation message. You understand and agree that the foregoing is the only reasonable method of opting out. If you want to join the Program again, just sign up as you did the first time, and we will start sending messages to you again. For support,email support@jugl.com to hear back from us. Our mobile messaging platform may not recognize requests that modify the foregoing commands, and you agree that we and our service providers will not be liable for failing to honor requests that do not comply with the requirements in these Mobile Messaging Terms. We may also change the telephone number or short code we use to operate the Program and we will notify you of any such change. You acknowledge that any requests sent to a telephone number or short code that has been changed may not be received by us and we will not be responsible for failing to honor a request sent to a telephone number or short code that has been changed.

2.2.1. We will take steps to limit direct marketing to a reasonable and appropriate level and only send you communications which we believe may be of interest or relevance to you.

2.2.2. You can ask us to stop sending email marketing by following the “unsubscribe” link you will find on all the email marketing messages we send you. Alternatively, you can contact us at support@jugl.com.

2.2.3. You can change the way your browser manages cookies, which may be used to deliver online advertising, by following the settings on your browser as explained in our Cookie Policy.

Sharing the Personal Data We Collect. We share your Personal Data with other entities as follows:

3.1. Customers. If you are an Employee, Account Owner or Administrator we may share your Personal Data with the Customer (or any individual acting on their behalf, for example an Account Owner or Administrator) with whom your account is associated. This includes where we are requested to share Personal Data regarding your usage of the Platform or App, your chats, IP address, or geo-location that we have collected. Other Employees within the account may have access to some of your Personal Data (for example Registration Data) depending on the settings within the account (set by you or your Account Owner/Administrator).

3.2. Affiliates. We may share information, including your Personal Data, with our affiliates and subsidiaries (whether existing now or those that may be incorporated in the future). Should Jugl 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, your Personal Data may be shared with or transferred to the parties involved in such an event. We may disclose Personal Data to a third-party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal Data may also be disclosed in the event of insolvency, bankruptcy or receivership.

3.3. Service Providers, and Subcontractors. We disclose information, including Personal Data we collect from and/or about you, to our trusted service providers and subcontractors, who have agreed to confidentiality restrictions and who use such information solely on our behalf in order to: (1) help us provide you with the Platform, Apps, and/or Services; (2) aid in our understanding of how you use our Platform, Apps, and/or Services; (3) for the purpose of improving, optimizing and sending promotional communications (see above for more details); and (4) provide us with IT and system administration services, data backup, security, and storage services, data analysis, data enrichment services, and payment processing.

3.4. Law Enforcement Related Disclosure. We may share your Personal Data with third parties: (i) if we believe in good faith that disclosure is appropriate to protect our or a third party’s rights, property or safety (including the enforcement of the Terms and this Privacy Notice); (ii) when required by law, regulation subpoena, court order or other law enforcement related issues, agencies and/or authorities; (iii) as is necessary to comply with any legal and/or regulatory obligation; or (iv) such disclosure is required to protect our legitimate business interests, including the security or integrity of our products and services.

3.5. Feedback or Recommendations. If you submit a public review or feedback, note that we may (at our discretion) store and present your review publicly, on our Sites and Services. If you wish to remove your public review, please contact us at support@jugl.com. If you choose to send others an email or message inviting them to use the Services, we may use the contact information you provide us to automatically send such invitation email or message on your behalf. Your name and email address may be included in the invitation email or message.

For the avoidance of doubt, Jugl may share your personal data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous.

International Transfer. We have an affiliate in the US, and we use subcontractors and service providers located in Poland, the US, and India, who process and store Personal Data. We conduct such international transfers for the purposes described above. We ensure that any third parties based in a third country and receiving Personal Data are subject to written agreements ensuring the same level of privacy and data protection as set forth in this Privacy Notice.

4.1. Jugl is headquartered in the USA, a jurisdiction which is considered by the USA, to be offering an adequate level of protection for the personal data of individuals residing in the USA, Central America, Europe, the Middle East, and Asia countries. We transfer data from the USA, Europe, and India on this basis.

4.2. Whenever we transfer your Personal Data to third parties based outside of USA, European Economic Area (“EEA“), the United Kingdom, and India to a third country that isn’t covered by an “adequacy decision” we ensure a similar degree of protection is afforded to it by signing specific contracts approved by the European Commission.

4.3. Please contact us at info@jugl.com if you would like further information on the specific mechanism used by us when transferring your Personal Data out of the USA, EEA, India, and the UK.

Security. We have implemented and maintained appropriate technical and organizational security measures, policies and procedures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to Personal Data appropriate to the nature of such data. The measures we take include:

5.1. Safeguards – The physical, electronic, and procedural safeguards we employ to protect your Personal Data include secure servers, firewalls, antivirus, and SSL encryption of data.

5.2. Access Control – We dedicate efforts for a proper management of system entries and limit access only to authorized personnel on a need-to-know basis of least privilege rules, review permissions quarterly, and revoke access immediately after the termination of our employees.

5.3. Internal Policies – We maintain and regularly review and update our privacy-related and information security policies.

5.4. Personnel – We require new employees of ours to sign non-disclosure agreements according to applicable law and industry customary practice.

5.5. Encryption – We encrypt the data in transit using secure TLS/ SSL protocols.

5.6. Database Backup – Our databases are backed up on a periodic basis for certain data and are verified regularly. Backups are encrypted and stored within the production environment to preserve their confidentiality and integrity, are tested regularly to ensure availability, and are accessible only by authorized personnel.

While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee that our Sites, Apps, Platform, and Service will be immune from any malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

As the security of information depends in part on the security of the computer you use to communicate with us and the security you use to protect user IDs and passwords, please take appropriate measures to protect this information.

Your Rights – How to Access and Limit Our Use of Certain Personal Data. Subject to applicable law, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to your Personal Data as detailed below.

6.1. Right of Access. You have a right to know what Personal Data we collect about you and, in some cases, to have such Personal Data communicated to you. Please note that we may not be able to provide you with all the information you request, and, in such case, we will endeavor to explain to you why.

6.2. Right to Data Portability. If the processing is based on your consent or performance of a contract with you and processing is being carried out by automated means, you may be entitled to (request that we) provide you or another party with a copy of the Personal Data you provided to us in a structured, commonly-used, and machine-readable format.

6.3. Right to Correct Personal Data. Subject to the limitations in applicable law, you may request that we update, complete, correct or delete inaccurate, incomplete, or outdated Personal Data.

6.4. Deletion of Personal Data (“Right to Be Forgotten”). Subject to applicable law,, you have a right to request that we delete your Personal Data if either: (i) it is no longer needed for the purpose for which it was collected, (ii) our processing was based on your consent and you have withdrawn your consent, (iii) you have successfully exercised your Right to Object (see below), (iv) processing was unlawful, or (iv) we are required to erase it in order to comply with a legal obligation. We cannot restore information once it has been deleted. Please note that to ensure that we do not collect any further Personal Data, you should also delete our App from your mobile devices, terminate your account with us, and clear our cookies from any device where you have used our Platform or an App. We may retain certain Personal Data (including following your request to delete) for audit and record-keeping purposes, or as otherwise permitted and/or required under applicable law.

6.5. Right to Restrict Processing. If you are an EU Individual, you can ask us to limit the processing of your Personal Data if either: (i) you have contested its accuracy and wish us to limit processing until this is verified; (ii) the processing is unlawful, but you do not wish us to erase the Personal Data; (iii) it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise, or defend of a legal claim; (iv) you have exercised your Right to Object (below) and we are in the process of verifying our legitimate grounds for processing. We may continue to use your Personal Data after a restriction request under certain circumstances.

6.6. Right to Object. If you are an EU Individual, you can object to any processing of your Personal Data which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.

6.7. Withdrawal of Consent. You may withdraw your consent in connection with any processing of your Personal Data based on previously granted consent. This will not affect the lawfulness of any processing prior to such withdrawal.

6.8. Right to Lodge a Complaint with Your Local Supervisory Authority. You may have the right to submit a complaint to the relevant supervisory data protection authority if you have any concerns about how we are processing your Personal Data, though we ask that as a courtesy you please attempt to resolve any issues with us first.

6.9. Right to equal services and prices. If you are a California resident, you have the right not to be discriminated against when you exercise your privacy rights.

We will investigate and attempt to resolve complaints and disputes and make every reasonable effort to honor your wish to exercise your rights as quickly as possible and, in any event, within

the timescales provided by applicable data protection laws. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information and/or comply with any of your requests, which may include asking you to sign into your account in the Services. If you are an Employee, for any requests to exercise such rights with respect to information we hold about you, please contact the applicable Customer directly.

Data Retention

7.1. Subject to applicable law, we retain Personal Data as necessary to maintain and expand our relationship and provide you with our Services and offerings; in order to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our data retention policy and at our reasonable discretion. We may delete information from our systems without notice to you once we deem it is no longer necessary for these purposes.

7.2. In some circumstances, we may store your Personal Data for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, audit, accounting requirements and so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data, and whether those purposes can be achieved through other means, as well as applicable legal requirements.

7.3. With respect to data within our Services for which we serve as data processors (see “Materials you Upload” in section 1.2.4 above), we will retain that data for as long as directed by the applicable Customer. For example, a Customer may choose to archive Personal Data within the Platform of Employees who have been terminated, in which case such archived data will be retained until deleted by the Customer. If you have any questions regarding such Personal Data, please contact the relevant Customer directly.

7.4. Please contact us at info@jugl.com if you have any questions regarding our data retention periods.

Cookies and Similar Technologies. We use cookies and similar technologies for a number of reasons, including to help personalize your experience, in order for us to provide and monitor our Services and Sites, to ensure that they perform properly and to analyze our performance and marketing activities. Third parties through which we provide the Services and/or our business partners may be placing and reading cookies on your browser, or using web beacons to collect information in the course of advertising being served on different websites.

8.1. What are Cookies? A cookie is a small piece of text that is sent to a user’s browser or device. The browser provides this piece of text to the device of the originating user when this user returns. Some cookies are removed when you close your browser session. These are the “Session Cookies”. Some last for longer periods and are called

“Persistent Cookies”. We use both types.

8.2. How We Use Cookies. We use cookies and similar technologies for a number of reasons, for example, we use persistent cookies to remember your log-in details and make it easier for you to log-in next time you access the Platform. To learn more about our practices concerning cookies and tracking, please see our Cookie Policy.

8.3. We and/or our service providers use analytics tools, including “Google Analytics” to collect and analyze information about the use of the Site and/or Services, such as how often users visit the Site, what pages they visit when they do so, and what other sites and mobile applications they used prior to visiting the Site. By analyzing the information we receive, we may compile statistical information across a variety of platforms and users, which helps us improve our Site and Services, understand trends and customer needs and consider new products and services, and tailor existing products and services to customer desires. The information we collect is anonymous and aggregated and we will not link it to any Personal Data. We may share such anonymous information with our partners, without restriction, on commercial terms that we can determine in our sole discretion. You can find more information about how Google collects information and how you can control such use at https://policies.google.com/technologies/partner-sites.


9.1. 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, “Services Provider”), who processes such data on behalf of the data controller (or business). Below we explain how these roles apply to our Services.

9.2. Jugl is the “data controller” of: (1) its Site Visitors’ and Customers’Personal Data, (2) Account Owners’ & Administrators’ Registration Data, Payment Data, and Automatically Collected Data, and (2) Employees’ Automatically Collected Data, as detailed in Section 1 above. Accordingly, we assume the responsibilities of a data controller (solely to the extent applicable under law), as set forth in this Privacy Policy.

9.3. Jugl is the “data processor” of: (1) Materials Uploaded by Users, (2) Employees’ Registration Data, and (3) Geo-Location Data, as submitted by our Customers and their Users to the Services, or automatically collected by our Services during the use of our Services by said Users. We process such data on behalf of our Customer (who is the “data controller” of such data) and in accordance with its reasonable instructions, subject to our Terms, our Data Processing Addendum (to the extent applicable) and other commercial agreements with such Customer.

9.4. Our Customers are solely responsible for determining whether and how they wish to use our Services, and for ensuring that all individuals using the Services on the Customer’s behalf or at their request, as well as all individuals whose Personal Data may be included in the Services, have been provided with adequate notice and given informed consent to the processing of their Personal Data, where such consent is necessary or advised, and that all legal requirements applicable to the collection, use or other processing of data through our Services are fully met by the Customer. Our Customers are also responsible for handling data subject requests under applicable law, by their Users and other individuals whose data they process through the Services.

9.5. If you would like to make any requests or queries regarding Personal Data we process as a data processor on our Customer’s behalf, including accessing, correcting or deleting your data, please contact the Customer’s Account Owner or Administrator directly.

Email address: info@jugl.com

Last updated: Mar 13, 2024

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