Privacy Policy

1. Preamble

This Master Privacy Policy (“Privacy Policy”) explains the collection, use, processing, transferring and disclosure of “personal information” by Jekko, Inc. (“Jekko”), a Delaware corporation, and also contains an Express Consent that applies to those who use our Websites and Services (as defined below). This Privacy Policy is incorporated into and made part of Jekko Master Terms of Use (“Master Terms”).

Unless otherwise noted on a particular website or service hosted by Jekko, this Privacy Policy applies to your use of all websites that Jekko operates. These includes but are not limited to http://jekko.com, http://jekko.net, together with all other subdomains thereof (the “Jekko Website”), (collectively, the “Websites”). This Privacy Policy also applies to all products, information, and services provided through the Websites, including without limitation the file uploader, web tools, and the Jekko Login Services (defined below)(together with the Websites, the “Services”). Furthermore, this Privacy Policy does not apply to any of the websites operated by affiliates or chapters of Jekko unless expressly provided on those websites or any subdomains of the Websites. For purposes of this Privacy Policy, “Jekko Login Services” refers to Jekko’s implementation of various accounts (such as WordPress, Email, etc) throughout the Website.

In addition, supplemental Privacy Policy terms (“Supplemental Privacy Policy Terms”) may apply to a particular Service. All such Supplemental Privacy Policy Terms will be accessible for you to read either within, or through your use of, that particular Service.

This Privacy Policy also explains our commitment to you with respect to our use, processing, transfer and disclosure of non personal browsing and site usage data that Jekko collects as the provider of the Services. “Non personal browsing and site usage data” refers to information that Jekko collects indirectly and automatically about your activities while visiting the Websites and using the Services through tools such as Google Analytics. The type of information that we collect focuses on general information such as general location such as country or city where you are located (not intentionally fine-grained location information), pages visited, heat-map of visitors’ activity on the site, information about the browser you are using, etc. In addition, whenever you use a Jekko Login Service to log into a Website or use the Services, our servers (which, again, may be hosted by a third party service provider) keep a plain text log of the websites you visit and when you visit them. Jekko does not deliberately track people over the Internet. See section 11, below for more information about this.

As used in this policy, “personal information” means information that would allow a party to identify you such as, for example, your name, address or location, telephone number, or email address or information from which a person could deduce your identity.

By accessing or using any of the Services, you are accepting and agreeing to the practices described in this Privacy Policy.

2. Our Principles

Jekko is committed to handling responsibly the personal information and data we collect and process about you through our Services, whether personal information or non personal browsing and site usage data. We have designed our Privacy Policy consistent with the following principles (the “Principles”):

  1. Privacy policies including provisions regarding data collection, processing and use, should be human readable, comprehensive, and easy to locate;
  2. Only the minimum amount of personal information reasonably necessary to provide you with services should be processed, collected and maintained, and only for so long as reasonably needed or required, consistent with the principles of proportionality; and
  3. Personal information you provide through our Services, or that we gather as a result of your use of our Services, should only be used in a tasteful manner which could include limited marketing, advertising purposes, and scholarly research;
  4. If Jekko is required to provide a third party with your personal information (whether by subpoena or otherwise), then provided we have collected and retained an email address for you, Jekko will use reasonable means to notify you promptly of that event, unless prohibited by law or Jekko is otherwise advised not to notify you on the advice of legal counsel.

3. Personal Information Jekko Collects

We may collect and process personal information through our Services, including without limitation:

  • when you provide us with your personal information such as by sending an email to us or signing up to receive updates from Jekko;
  • when you subscribe to one of our email discussion lists;
  • when you purchase merchandise;
  • when you apply for a contests or participation in one of our programs;
  • when you create a Jekko Login Service account.
  • when you join and use the Jekko network through our Website, and/or establish an account; and
  • when you provide personal information in connection with your participation in any of the forums we make available through our Services.

4. What Jekko Does with Personal Information

Emails and Newsletters . We use the personal information you provide to us when you send us emails or sign up to receive updates from Jekko in order to respond to your request – for example, to reply to your email or to send you communications about Jekko news and campaigns.

When you subscribe to updates from us, your email address is sent to and stored in a Customer Relationship Management (CRM) database (such as MailChimp, or CiviCRM) hosted on servers that can only be accessed by Jekko staff and contractors. Jekko may change CRM system(s) from time to time. When you subscribe to one of our email discussion lists, your name and email address is sent to and stored by (1) Jekko, and/or (2) another service with which Jekko has engaged to provide email support (such as a CRM system as mentioned above). Personal information submitted as part of our email discussion lists is used for the purpose of managing the discussion lists. Your name and email address typically will be visible to other list participants when you correspond on the list and to the general public in the discussion archives. All emails sent to the discussions lists are publicly archived.

Events: If you sign up for an event hosted or supported by Jekko, we may share your personal information with vendors and third party contractors solely for the purpose of organizing and running the event. Additionally, if you sign up to participate in a Jekko-sponsored event, including without limitation a Jekko Summit, you may be asked to enter your name, address, and account information in connection with your payment for attendance. Currently, Jekko uses Stripe for payment, but Jekko may use additional methods for payment. You affirmatively consent and agree that Jekko may use and process your information in connection with the use and processing of your attendance with any such third party payment processors for purposes of processing your payment. Your information is subject to the privacy policies of such third party websites, and you affirmatively consent to the transfer of your information to those websites and service providers. Jekko is not be responsible for their handling, processing and use of your information.

Contest opportunities or participation in our programs. When you apply for a contest or grant from Jekko, or when you apply to be selected to participate in one of our programs, Jekko will collect certain personal information from you in order to evaluate your application. We will share that information with the people who are designated to select participants in those programs, which may include people not employed by Jekko.

Merchandise. If you purchase merchandise from the Jekko, your personal information will be used for the purpose of sending you the items you purchased. If you sign up to receive updates from Jekko when you check out from the store, we will use your personal information to send you communications about Jekko news and campaigns.

5. Participating in Our Community

Registered Users. When you register to obtain a user account on any of the Services (any such person, a “Registered User”), including but not limited to a Jekko Login Service, you may be asked to provide personal information to create your account and establish a password and profile. We generally encourage you to use an alias or nickname if you are not comfortable providing your legal name. The name or nickname you provide in connection with your account may be used to attribute you in connection with any content you submit to any Service. We also use that personal information to establish and maintain your account, to provide you with the features we provide Registered Users, and to email you regarding changes to this policy or other applicable policies. If you sign up to receive updates from Jekko when you create your account, we will use your personal information to send you communications about Jekko news and campaigns.

Any other personal information that we may collect which is not described specifically in this Privacy Policy will only be collected, processed, transferred and used in accordance with the Principles and as stated herein.

6. Disclosures of Personal Information

In general, it is not Jekko’s practice to disclose personal information to third parties. We may share your personal information in two instances:

In general, it is not Jekko’s practice to disclose personal information to third parties other than as made available on the Services. Except as otherwise set forth herein or for providing you with attribution using your Jekko Login Service name or nickname (as you have elected) in connection with your cc-licensed works, we may share your personal information in the following instances:

  • First, Jekko may share personal information with our contractors and service providers in order to maintain, enhance, or add to the functionality of the Services, to organize and run an event you signed up to attend, to evaluate your application for contests and/or participation in a program run by Jekko, or to otherwise run any Jekko program or activity in which you have chosen to participate.
  • Second, we may disclose your personal information to third parties in a good faith belief that such disclosure is reasonably necessary to (a) take action regarding suspected illegal activities; (b) enforce or apply our Master Terms and this Privacy Policy; (c) enforce our Charter including the Code of Conduct and policies contained and incorporated therein, (d) comply with legal process, such as a search warrant, subpoena, statute, or court order; or (e) address legitimate interests pursued by Jekko or by a third party (except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child) and ensure our compliance with applicable laws.

For the purposes listed in section 3 above, Jekko may transfer your personal information to Jekko affiliates, members, chapters, and third parties that provide products or services to Jekko. The majority of consultants that Jekko is using as of the effective date of this Privacy Policy were located in the United States, but this may change from time to time. For example, Jekko has engaged a third-party Internet service to provide hosting services for some of our Websites based in Amsterdam.

When personal information is directly transferred to an affiliate, member, Chapter or a third party provider located in a country including those listed above, that may not provide a level of protection equivalent to the laws in your jurisdiction, Jekko will exercise appropriate due diligence in the selection of such recipients, and require that these recipients maintain adequate technical and organizational security measures to safeguard the personal information and process the personal information only as instructed by Jekko and for no other purposes.

7. Security of Personal Information Collected via the Services

Jekko has implemented reasonable physical, technical, and organizational security measures for personal information that Jekko processes, transfers, stores and controls against accidental or unlawful destruction, or accidental loss, alteration, unauthorized disclosure or access, in compliance with applicable law. However, no website can fully eliminate security risks. Third parties may circumvent our security measures to unlawfully intercept or access transmissions or private communications. If any data breach occurs, we will post a reasonably prominent notice to the Websites and comply with all other applicable data privacy requirements including, when required, personal notice to you if you have provided and we have maintained an email address for you.

The Jekko Login Services account systems have security risks in addition to those described above. Among other things, they are vulnerable to DNS attacks, and using any CC Login Service may increase the risk of phishing. See “More about Jekko Login Services” below and other information about those services throughout this Privacy Policy.

8. Information from Cookies and Similar Technologies

We and our service providers (for example, Google Analytics as described in section 1 above) may collect information using cookies or similar technologies for the purposes described above and below. Cookies are pieces of information that are stored by your browser on the hard drive or memory of your computer or other Internet access device.  Cookies may enable us to personalize your experience on the Services, maintain a persistent session, passively collect demographic information about your computer, and monitor advertisements and other activities.  The Websites may use different kinds of cookies and other types of local storage (such as browser-based or plugin-based local storage).

9. Data Usage Policy: Non Personal Browsing and Site Usage Information We Process and Collect

When you use the Services, our servers (which may be hosted by a third party service provider) may process and collect information indirectly and automatically (through, for example, the use of your “IP address”) about your activities while visiting the Websites and using our Services, and information about the country you are located in and the browser you are using. In addition, we use website and application analytics services provided by third parties that use cookies and other similar technologies to collect information about the use of the Websites and Services, and to report trends, without identifying individual visitors (this is all “non personal browsing and site usage information” for purposes of this Privacy Policy). The third parties that provide us with these services may also collect information about your use of third-party websites. You can learn about Google’s practices in connection with this information collection and how to opt out of it by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout. Whenever you use your Jekko website account or a Jekko Login Service, our servers (which, again, may be hosted by a third party service provider) keep a log of the websites you visit and when you visit them. We may share the non personal browsing information we collect with our third party service providers in connection with the services they provide.

10. No Linking

We do not intentionally link browsing information or information from our Jekko Login Services server logs to the personal information you submit to us. We use this information for internal purposes only, such as to help understand how the Services are being used, to improve our Services, and for systems administration purposes. Jekko may use a third party analytics provider (for example, Google Analytics as discussed in section 1 above) to help us collect and analyze non personal browsing and site usage information through operation of our Services for those same purposes.

In connection with your use of the Services you do things to personalize your experience. This information will be retained by Jekko in connection with the relevant Jekko Login Service.

11. No Selling or Sharing

Except in the unique situations identified in this Privacy Policy, Jekko does not sell or otherwise voluntarily provide the non personal browsing information we collect and process about you or your website usage to third parties.

12. No Access; More about CC Login Services

As a provider of Jekko Login Services, Jekko could access your web-based account tied to such services, and could log in on behalf of any of Registered Users to any of the accounts they have accessed using the Jekko Login Services. Jekko will never use this technical login ability for any purpose except for technical maintenance or as required by law.

13. Data Retention

Jekko generally discards non personal browsing information from our Jekko Login Services and Website once we have used the information for the limited purposes noted above under “No Linking” and described elsewhere in this Privacy Policy. Nevertheless, we may, but are not obligated to, retain certain data in connection with routine information technology backups and for archival purposes.

14. Notice

Any other non-personal information that we collect which is not described specifically in this Privacy Policy will only be collected, processed, transferred and used in accordance with the Principles.

15. Reorganization or Spin-Offs

Jekko may transfer some or all of your personal and/or non personal browsing information to a third party as a result of a reorganization, spin-off, or similar transaction. Upon such transfer, the acquirer’s privacy policy will apply. In such event, Jekko will use reasonable efforts to notify you and to ensure that at the time of the transaction the acquirer’s privacy policy complies with the Principles and with all applicable laws.

16. Children

The Services are not directed at children under the age of 13. Consistent with the U.S. federal Children’s Online Privacy Protection Act of 1998 (COPPA), we will never knowingly request personal information from anyone under the age of 13 without requiring parental consent. Our Master Terms specifically prohibit anyone using our Services from submitting any personally identifiable information about persons under 13 years of age. Any person who provides their personal information to CC through the Services represents that they are 13 years of age or older.

17. Third-Party Sites

The Services may include links to other websites. You should consult the respective privacy policies of these third-party sites. This Privacy Policy does not apply to, and we cannot control the activities of, such other websites.

18. Special Note to International Users

If you are accessing or using the Services in regions with laws governing data collection, processing, transfer and use, please note that we may transfer your information to recipients in countries other than the country in which the information was originally collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. The Services are hosted in the United States and the Amsterdam. Please note that your personal information may be located on servers in the United States and/or the Amsterdam. By providing your personal information or otherwise access and use our Services or Websites, you expressly consent to the use of your personal information for the uses identified above in accordance with the Privacy Policy.

19. Accuracy of Personal Information Collected

Jekko intends to keep personal information accurate and up-to-date. We also retain personal information no longer than is necessary to carry out the purposes described in section 3 above, or as required by law. If changes need to be made to your personal information, please notify us (as identified below, see the “Questions” section) right away. If you inform us of changes or we otherwise become aware of any factual inaccuracies in personal information, we will promptly make changes as appropriate. You also have the option to update some of your personal information yourself via your Jekko account or profile if you have one.

20. Access to Personal Information

Along with all other rights granted to you under applicable laws, you may at any time request to be informed of personal information that Jekko holds. If you wish to access such personal information, you should apply in writing to Jekko (as identified below, see the “Questions” section). You are generally entitled to access personal information that Jekko holds and to have inaccurate data corrected or removed to the extent Jekko still maintains it. In certain circumstances, you also may have the right to object for legitimate reasons to the processing or transfer of personal information.

21. Changes and Updates to this Privacy Policy

We may occasionally update this Privacy Policy. When we do, we will provide you with notice of such update through (at a minimum) a reasonably prominent notice on the Websites and Services, and will revise the Effective Date below. We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting, using, processing and transferring the personal information we collect.

Effective Date: 2018-1-1