August 02, 2019

Privacy Policy

As the CEO of Jumbo, I made a commitment to make sure that each decision we make for our product and our company fundamentally respects your privacy. Over time, we want to honor your trust by consistently striving to ensure each of our decisions protects your privacy.

Pierre Valade

Our new privacy policy was released as of March 19, 2020.

It can be found here

This post dates November 21th 2019.

We never collect, store or process data you manage through Jumbo, therefore we cannot and will never sell any of your data. In fact, we don’t even know who you are.

We think it is the most fundamental decision we have made while building Jumbo: the application and its functionalities are phone-based: all the personal data processing happens from/in your mobile phone. This means that we do not collect nor access any of your personal information when you use Jumbo, not even to identify you for analytics purposes.

Processing your personal data through the Jumbo Privacy iOS and Android application

We do not collect any of your personal data

We do not collect nor store any personal data that you manage or store when you use the Jumbo Privacy App. We simply implement technical features in the Jumbo Privacy App that enable you to manage your personal data and privacy settings in other applications that you use. This is what can be called “processing”.

Opt-in to the processing of your personal data within the Jumbo Privacy App

When you open the Jumbo Privacy App for the first time, you will see a pop-up text with a link to this privacy policy. This privacy policy explains how the processing is done by us, in compliance with applicable laws protecting your privacy. Before using the Jumbo Privacy App, we kindly ask you to read this privacy policy carefully and tick the box to continue using the Jumbo Privacy App if you agree to it. If you do not agree with this privacy policy, please do not use the Jumbo Privacy App.

How does the Jumbo Privacy App work?

We offer you the possibility to scan some of your online accounts (i.e. Facebook, Google, Twitter, ….) through the Jumbo Privacy App. You can choose what online account you want to scan through the Jumbo Privacy App. To offer our services, we will ask you to log into your account through the Jumbo Privacy App, using your username and password. The authentication of your account will be made in your phone during the whole process: we don’t access, nor store your username and password.

Please note that when scanning your Alexa account, your password will be stored within your phone to avoid being disconnected all the time. If you do not wish for your password to be stored in your phone, please do not use this feature.

Once your account has been scanned, we might suggest some updates to your account, notably to your personal data and privacy settings. For example, we might suggest you to:

Every step of the way, you are the one controlling and deciding how to manage your personal data and privacy settings related to your accounts. The Jumbo Privacy App will never change anything in your accounts without your authorization. Consequently, we are only processing your data because you have consented to it and/or because we are performing a service you have requested from us.

Storing of Facebook publications and/or tweets

If you decide to transfer some of your personal data, such as your Facebook posts or tweets, the transfer of such personal data will be made directly from your account to the Jumbo Privacy App, the FTC registry and/or the third party storage space selected. If you decide to transfer your personal data directly to a third party, we suggest you verify the third party’s privacy policy before deciding to transfer your personal data to them. Indeed, we suggest them in our app, but we do not have a business relationship with them. Furthermore, we do not endorse them, nor are affiliated to them. We are not responsible for how your data is stored with them.

Saving of your Alexa password

If you chose to save your Alexa password, your password will only be stored within the Jumbo Privacy App in your phone. To delete your Alexa password, please delete the Jumbo Privacy App.

For more information about your use of the Jumbo Privacy App, please consult our TOS.

How to access, rectify, or delete your scanned accounts/stored personal data?

You can access, rectify, or delete the accounts you have managed through the Jumbo Privacy App and/or the data you have stored within the Jumbo Privacy App at any time.

As we do not collect nor store any of your personal data, you need to access and rectify directly in your account within the Jumbo Privacy App. If you want to delete any data stored in the Jumbo Privacy App, you need to delete the Jumbo Privacy App from your phone.

If you are not able to do any of this, you want help doing so or have any related questions, please send an email to [email protected]

Push Notifications

We may send you updates about Jumbo by sending you push notifications if you have given us your prior approval to do so.

To send you push notifications, we store and use a serial number which was generated by Apple, best known as a “token”, which is unique to your phone.

We cannot identify you nor localize you through this token but we can send you messages. This is why we have a strict security policy when collecting, storing and using your token.

Surveys

We sometimes conduct surveys within the Jumbo Privacy App to get feedback on our products and services. We only collect anonymous information such as country or age range to understand demographics of our userbase. On some rare occasion, we give you the possibility to provide us your email address on an opt-in basis if you want the opportunity to chat with a team member or if you want to receive updates regarding the Jumbo Privacy App. In such event, we only process your email address for the purpose provided for in the survey, and for as long as strictly necessary. We do not sell it or transfer it to any third party.

You can opt-out from any further communication, rectify, and/or erase your email address directly in any received communication, or by sending us an email to [email protected]

We use Typeform for conducting these surveys (more information about Typeform here).

Jumbo Privacy App Analytics

Our Jumbo Privacy App sends analytics data to our analytics providers: Segment and Amplitude. We do not track or store any personal information in our analytics. Instead, we ask Apple/Google to generate a unique deviceID which we use as a unique token for analytics purposes. Our analytics are 100% anonymous and only contains information about your usage of the Jumbo Privacy App, device and country.

Websites Analytics

When you navigate on our websites available at the following URL addresses: www.jumboprivacy.com and blog.jumboprivacy.com, they sends us anonymous statistics to allow us to track number of visitors and device screen size information. For such analytics, we use Simple Analytics, for more information see here.

Cookies on Our Websites

We have cookies on our websites available at the following URL addresses : www.jumboprivacy.com and blog.jumboprivacy.com only for strictly necessary purposes.

Our DNS provider, Cloudfare, uses cookies to allow you to navigate on our websites properly and to ensure their safety (notably against malicious visitors).

The way it works is that these cookies send your IP address to Cloudfare (which is stored for less than 24 hours according to their privacy policy). We never have access nor can use your IP address since it is only available to Cloudfare.

You can disable them by changing your browser preferences (for more information please visit : allaboutcookies.org). For more information about Cloudfare, please see here.

We do not have any other cookies on our websites (such as tracking or advertising cookies).

Services Jumbo relies on, and what data they might store about you

Help Scout

We have decided to use Help Scout as our helpdesk service provider. Therefore, if you email [email protected], Help Scout will receive and keep a copy of your IP address, and your name if it sent as part of the headers of the email protocol. We have setup Help Scout so that it deletes automatically all emails from their servers 30 days after they are received. For more information about how Help Scout processes your data, please visit https://www.helpscout.com/company/legal/privacy/

Microsoft Cloud, Azure

We choose the products we use very carefully, and our email servers (that we are using for [email protected] for example) are powered by Microsoft Cloud. Microsoft Cloud has a very strong reputation to respect privacy. If you email [email protected], Microsoft servers will receive and keep a copy of your IP address, and your name if your name is sent as part of the headers of the email protocol. Contrary to what we have set up for Help Scout, we will keep your emails for as long as it is necessary for replying to your request and then for as long as necessary, if required to, for evidence purposes. For more information about how Microsoft processes your data, please visit https://privacy.microsoft.com/

Apple

Apple hosts our Jumbo iOS app. Apple provides Jumbo with analytics: this feature is called App Analytics. Apple does not provides Jumbo with information that would personally identify you. You can turn off this feature completely, also. For more information about how Apple processes your data, please visit https://www.apple.com/legal/privacy/

Google Play Console

Android hosts our Android app. Google provides Jumbo Privacy with anonymous analytics with regards to your use of our app (country, device): this feature is called Google Play Console. Google does not provide Jumbo with information that would personally identify you. You can turn off this feature completely, also. For more information about how Google processes your data, please visit https://policies.google.com/privacy

Cloudflare

We use Cloudflare as our DNS provider for our app and our websites. Cloudflare has a solid privacy reputation. Cloudflare says they will log your IP address for less than 24 hours. To the best of my knowledge, I haven’t found a way to access, from the Cloudflare dashboard, these logs. For more information about how Cloudfare processes your data, please visit: www.cloudflare.com/privacypolicy/

Github Pages

The websites www.jumboprivacy.com and blog.jumboprivacy.com are hosted by Github, via their feature Github Pages. Jumbo has configured Cloudflare as a proxy between you and the Github servers, in order to avoid your IP address being sent to Github. Github never get any personal data. We do not use any cookies on our websites that will store any personal data.

Any changes we make to the Privacy Policy in the future will be posted on this page and, when mandatory, notified to you directly in the App.

Mailchimp

We may send you our newsletter if you have agreed to receive it. For that, we use Mailchimp as our newsletter service provider. Mailchimp provides that it will only process your personal data to provide us with their emailing tools. Your email address will be automatically deleted from Mailchimp if you decide to opt-out from any communication. We do not keep email addresses for marketing purposes for more than a year following the last sent communication. For more information about how Mailchimp processes your data, please visit https://mailchimp.com/legal/privacy/.

Simple Analytics

We use Simple Analytics to collect anonymous statistics on our websites. Simple Analytics does not use cookies nor collect personal data to provide us such statistics. Please see their privacy policy for more information. For more information about how Simple Analytics processes your data, please visit https://simpleanalytics.com/privacy

Typeform

We conduct surveys using Typeform. Typeform provides that it will only process your personal data to provide us with their survey tools. We transfer the answers of the survey to our cloud services and delete them from Typeform within a week following the end of such survey. For more information about how Typeform processes your data, please visit https://admin.typeform.com/to/dwk6gt

Other Information About Your Data

Personal Data transfers EU/Swiss - USA

Since 2121 Atelier Inc is located in the USA, we might transfer some of your personal information from the European Union to the USA. We comply with the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data transferred from the European Union, the European Economic Area, and Switzerland to the United States. Our certification is pending, but our name shall soon be added to the official certified company list available at www.privacyshield.gov/list. You can also learn more about Privacy Shield at www.privacyshield.gov.

Security of All Data

We take security very seriously and therefore have implemented appropriate technical and organizational measures to ensure a level of security appropriate to the risk linked to our processing of all data as described hereabove. To implement such measures, we have taken into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for your rights and freedoms as natural persons.

Access/Rectification/Deletion/Portability of Your Personal Data

On a general basis, you can access, rectify, or delete your personal data directly through the Jumbo Privacy App, or through the service providers we are relying on as described above. If you are unable to complete your requests through the Jumbo Privacy App or such services, you can send a detailed message explaining your request to us at : [email protected] or to 2121 Atelier Inc, 20 Jay Street, Brooklyn, New York, USA.

Changes to the Privacy Policy

Any changes we make to the Privacy Policy in the future will be posted on this page and, when mandatory, notified to you directly in the Jumbo Privacy App.

Liability and Disclaimers

Limits on liability and disclaimers applicable to our privacy policy are provided under our TOS.

Contact Us

If you have any questions or concerns regarding this Privacy Policy, please send a detailed message to : [email protected] or 2121 Atelier Inc, 20 Jay Street, Brooklyn, NYC, USA.

If you are a European citizen, in addition to 2121 Atelier Inc, you can contact our European Representative, 1862 Avocats, mandated for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union by sending a detailed message to [email protected] or 1862 Avocats, Zoé Vilain, 24 rue de Penthièvre, 75008 Paris, France.

We also want to inform you that you are entitled to lodge any complaint with regards to privacy matters in relation with our activity to your local data supervisory authority. As our EU representant is in France, any complaint will be transferred to the French supervisory authority which is the CNIL.

Thanks for reading!

Email [email protected] if you have more questions, thanks!

Pierre Valade

CEO