February 05, 2021

Privacy Policy Update

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

This policy was last updated on March 18, 2021.

An Introduction from our founder and CEO

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.

Before you read our privacy policy, I’d first like to tell you how we think about privacy and security in our day-to-day decisions.

We only make money when our customers subscribe to Jumbo’s paid plans. To stay true to our values and mission, we are building a profitable, sustainable business that will protect your privacy and security in the long run, and remain independent from the same companies and practices from which we are fighting to protect you.

Thank you for trusting us with your privacy and security. If you have any questions or comments, you can always reach out to us at [email protected].

- Pierre Valade

The Privacy Policy

Thank you for using Jumbo! This privacy policy describes how 2121 Atelier, Inc. d.b.a. Jumbo Privacy (“Jumbo” or “we”) and our product (“Jumbo App”) might collect and process your personal data, in compliance with applicable laws protecting your privacy, when you use Jumbo’s privacy and security services.

Title 1 – Jumbo Features you may use

Section 1. Privacy & Security Services in the Jumbo App

Jumbo App is a mobile application available on iOS and Android that helps you protect your online privacy and security.

By using the Jumbo App, you are asking the Jumbo App to make changes to your privacy settings and/or personal data. This is what we call “processing of your personal data”. When you open the Jumbo App for the first time, you will see a pop-up displaying a link to this privacy policy.

Before using the Jumbo App, please read this privacy policy carefully and agree to its terms to continue using the Jumbo App. If you do not agree with this privacy policy, please do not use the Jumbo App.

A. Functionalities

The Jumbo App will never change anything in your accounts without your prior 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.

(i) Subscription to a Jumbo Plan

If you subscribe to a Jumbo Plan (i.e. Jumbo Plus or Jumbo Pro as described in our TOU), your payment may be handled by Google, Apple or Stripe, depending on factors such as your phone’s make or model, the plan you choose, the country in which you are located, and the features made available to you.

We provide these companies access to data required to process the payment for a Jumbo subscription. Your personal data may be stored by us and/or these payment providers as required by tax regulations and/or payment network requirements (e.g. visa, mastercard, etc.)

For more information on how Apple, Google or Stripe may use your data, please consult Title 2 on Sub-Processors.

(ii) Change of the privacy settings of your online accounts

The Jumbo App offers you the ability to scan the privacy settings on some of your online accounts and suggests changes to maximize your privacy. You can choose which of your online accounts you want Jumbo to scan.

To provide this service, you are asked to log into your account(s) through the Jumbo App. Your account authentication details, i.e., username and password, remains locally in your device during the whole process. We do not copy or store any of this personal data in the Jumbo Cloud.

In no event will your password be transmitted to Jumbo Privacy. If you do not wish for your password to be stored locally within the Jumbo App in your device, please do not use this feature. To delete your passwords, simply disconnect your account from the Jumbo App.

(iii) Transfer and storage of your personal content

If you decide to transfer some of your personal content (e.g. when archiving posts from Facebook), this transfer is made directly from your account to the storage space you have selected, which may be the Jumbo App or a third-party storage space that you select.

If you decide to store your personal content in the Jumbo App, your personal content will remain locally in your device and it is not copied or stored in the Jumbo Cloud. In no event will your personal content be transmitted to Jumbo Privacy.

If you want to delete your personal content, you can do so by deleting the Jumbo App.

If you decide to transfer your personal content directly to a third-party, please note that we do not own, operate, or control them, and they have their own controlling privacy policies that you should review. This means that we are not responsible for how your data is stored with them.

(iv) Data breach feature

The Data Breach feature requires Jumbo to process the email address(es) you want to protect and monitor and transmit it to our data breach service provider SpyCloud (see Title 2, Section 7 for more about this provider).

For security and privacy, the email address(es) you provide is transmitted as a “one-way-function” or hash, which looks like “642020b48e8f9706b14bc695f3b1f4ad719553df” instead of e.g. [email protected]

SpyCloud will use the hash of your email address only for the purpose of checking if your email address appeared in a data breach. You can, at any time, disconnect this feature. The hash of your email will be stored for security reasons by SpyCloud for 6 years.

(v) Family Plans or Referrals

The functionality of certain features such as the Family Pro Plan, or referrals, require contact information such as an email address of the person you are inviting or adding to your plan. Jumbo processes and stores this data to provide this functionality.

B. Your rights

How to access, rectify, or delete your personal data?

Except for Delete My Data and Secure Together, Jumbo Privacy does not access or store any of your personal data.Therefore, you can access rectify, or delete the accounts you have managed through the Jumbo App and/or the data you have stored within the Jumbo App at any time directly in the Jumbo App.

If you want to delete any data stored in the Jumbo App, you need to delete the Jumbo App from your phone.

You can access, rectify, or delete your data related to Delete My Data or Secure Together at any time, by sending an email to [email protected].

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].

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

Section 2. Jumbo App Analytics

The Jumbo App collects analytics information to ensure that our product works correctly on different devices and operating systems. This data also helps us improve the quality of our product and make your experience better. This includes data like the type of device you’re using, the operating system, event stamps and error logs.

You can opt-out from anonymous Jumbo App analytics at any time, directly from the Jumbo App, and we will no longer collect analytic data from your device.

We do not track or store any of your personal data with this analytic tool. Instead, to distinguish one user from another in an anonymous way, we use a unique identifier called “deviceID” that is linked to your device and your use of the Jumbo App.

The Jumbo App sends your analytics data to our analytics provider: Amplitude. For more information about Amplitude, please see here. We delete our analytics when they become obsolete. If you want to delete your anonymous analytics history of your use of the Jumbo App before there obsolescence, please contact support for help.

Section 3. Push Notifications

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

You may opt-out of receiving these notifications at any time by changing the appropriate settings within your Jumbo App. To send you push notifications, we store and use a serial number which was generated by Apple or Google, depending of the version of the Jumbo App you are using, best known as a “token”, which is unique to your use of the Jumbo App in your phone.

To send you such push notifications, we use MongoDB as service provider. For more information about MongoDB, please see here.

Your token is stored by MongoDB, and in the Jumbo Cloud. Your token is stored until you change your settings or request us to delete it.

We cannot identify you nor localize you through this token but we can know your time zone, the language chosen on your phone and send you messages. This is why we have a strict security policy when collecting, storing and using your token.

Section 4. Support

Jumbo Privacy is by your side to help you control your privacy. Therefore, if you have any questions or concerns regarding the Jumbo App, this Privacy Policy or your privacy rights, you can contact our support team directly in the Jumbo App, or by sending an email to: [email protected]oprivacy.com.

We use Help Scout, to receive and reply to your messages when sent by email, and Front when you chat with us directly in the Jumbo App. For more information about Help Scout, please see here.

Your request is stored in Help Scout or Front for 180 days.

Section 5. Surveys

We sometimes conduct surveys within the Jumbo App to get feedback on our products and services. When conducting such surveys, we might 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 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 or Survey Monkey for conducting these surveys (more information about Typeform here and Survey Monkey here).

Section 6. Newsletter

You can subscribe to our newsletter at any time by given us your email address in the Jumbo App or on our dedicated websites. We only send the newsletter to you for the informational purposes you have chosen when you subscribed. You can opt-out whenever you want by clicking the opt-out link directly in the newsletter or by sending us an email to: [email protected]. We will then stop sending you our newsletter, and will delete your email address from our emailing list. We use Mailchimp to send you our newsletter, for more information, please see here.

Section 7. Functioning cookies on our websites

We have installed cookies on our websites available at the following URL addresses: www.jumboprivacy.com and blog.jumboprivacy.com to collect your IP address only for strictly necessary purposes to enable our websites to work properly as described below.

Our DNS provider, Cloudflare, 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 Cloudflare (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 Cloudflare, and only Cloudflare may read or modify the information contained in such cookie. For more information about Cloudflare, please see here.

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

You can refuse the use of cookies at any time by adjusting the settings of your browser (Internet Explorer, Safari, Firefox, Chrome) by selecting the “cookies” option in the “Help” function to obtain information about the location of the cookie folder. Please note that disabling cookies may limit access to certain features or pages of the Jumbo Privacy websites.

Section 8. Jumbo Privacy’s ads

You might have noticed some ads for Jumbo Privacy on websites or apps you have been on. In order to understand if you have downloaded the Jumbo App by clicking on one of our ads, and if so, what exact ad, we collect your IDFA and IP address when you start using the Jumbo App together with certain events, for legitimate business purposes. Events consist of information on whether you have taken on a Jumbo subscription plan or not.

Once collected, Your IDFA/IP address and the collected events are immediately sent to our ad campaign partner, Singular, without Jumbo storing them. This information is shared with adnetworks Jumbo Privacy works with to display ads (such as Google Ads, Apple Ads, Twitter Ads and Facebook Ads) to confirm ad campaign attributions. Your IDFA/IP address and relevant events are stored for 45 days by Singular for that purpose. For more information about Singular, please see here.

Please note that you can opt-out from such data usage at anytime by sending us an email to [email protected].

TITLE 2: Sub-Processors

Third-party services Jumbo Privacy relies on, and what data they might store about you.

We only share your personal data with the services we rely on, if strictly necessary to provide you with our privacy and security services.

Where we need to share your personal data with our third-party services, we have chosen them with a lot of care, to make sure they take privacy as seriously as we do and that they only use your personal data for the purposes we have instructed them to do. We might also have executed data processing agreement with them to regulate how such service providers use your personal data. This data processing agreement was implemented thanks to the GDPR. In the event where such service providers are limiting their data processing agreements to European users, we are negotiating to extend such protection to all our users wherever located.

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Section 1. Help Scout

Helpdesk

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 180 days after they are received.

For more information about how Help Scout processes your data, please visit https://www.helpscout.com/company/legal/privacy/.

You can also consult the data processing agreement signed with Help Scout, available here: https://www.helpscout.com/company/legal/dpa/

Section 2. Jumbo Cloud: 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 (generally from two to five years, depending on your jurisdiction and the type of emails you have sent to Jumbo Privacy).

For example, emails containing details of your Privacy Requests and your signed mandate will be kept for two years for proof purposes. For more information about how Microsoft processes your data, pleasevisit https://privacy.microsoft.com/. You can also find more information about the data processing agreement signed with Microsoft here: https://docs.microsoft.com/en-us/legal/gdpr

Section 3. Apple

Apple hosts our Jumbo iOS app. This section applies to you if you use our iOS version of the Jumbo App.

Subscription information

Apple collects your account information and payment details when you subscribe to a Jumbo Plan. Your personal data is stored by Apple until you delete it, except for your payment data which is kept by Apple for duration imposed by tax regulations in your country. For more information, please visit https://support.apple.com/en-us/HT207233.

Face ID and Touch ID

You can use Face ID or Touch ID to unlock the Jumbo App if you use such version of the Jumbo App. Jumbo Privacy does not have access to this information, which is only managed by Apple. To learn more about this technology, please visit https://support.apple.com/en-us/HT208108 and https://support.apple.com/en-us/HT204587. You can disable this feature directly in the Jumbo App.

App Analytics

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

Section 4. Google Play Console

Android hosts our Android app. This section applies to you if you use our Android version of the Jumbo App.

Subscription information

Google collects your account information and payment details when you take an in-app subscription. Jumbo Privacy does not have access to this information, which is only managed by Google.

Your personal data is stored by Google until you delete it, except your payment details information that might be kept by Google for duration imposed by tax regulations in your country.

App analytics

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 Privacy 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.

Section 5. 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 our knowledge, we 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/.

Section 6. 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.

Section 7. SpyCloud

To verify if your email address was involved in a data breach, we transmit the hash of your email, with your consent, to a third-party provider: Spycloud. SpyCloud never has your email address, only the hash of it, which is an unrecognizable jumble of numbers and letters.

SpyCloud uses this unique hash to determine which unique code has been violated on a specific website SpyCloud will verify, without knowing who you are, if your email address (i.e. the hash email) has been compromised.

We have signed a specific data protection agreement with SpyCloud to supervise their use of your hash email. Please contact us for more information.

Section 8. Mailchimp

We may send you our newsletter if you have provided us with your email and agreed to receive it.

To send you our newsletter, 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/. You can consult the data processing agreement signed with Mailchimp here https://mailchimp.com/legal/data-processing-addendum/.

Section 9. 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.

Section 10. Typeform & Survey Monkey

We conduct surveys using Typeform or Survey Monkey. They provide that they will only process your personal data to provide us with their survey tools. To send you this survey, we will ask you for your email address or provide you access to our survey directly in the Jumbo App.

We transfer the answers of the survey to our cloud services and delete them from Typeform/Survey Monkey 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, how Survey Monkey processes your data, please visit: https://www.surveymonkey.com/mp/legal/privacy-policy/. You can also find more information about the data processing agreement signed with Typeform here: https://admin.typeform.com/to/dwk6gt and with Survey Monkey here: https://help.surveymonkey.com/articles/en_US/kb/SurveyMonkey-Data-Transfers-and-EU-Laws

Section 11. Freelancers

From time to time, we may use freelancers based in the USA or Europe to help us for specific tasks notably to our support team. These freelancers might process personal data belonging to you under our strict instructions. We chose very carefully the freelancers that work with us, and they all sign a data protection agreement containing security requirements to ensure the safety of your personal data before starting to work for Jumbo Privacy.

For more information, please contact us.

Section 12. MongoDB

To send you push notifications, we use a unique token which is stored by our service provider, MongoDB. MongoDB only stores your token on our behalf, and is not authorized to use it for any other purposes than sending you push notifications in the Jumbo App.

You may opt out of receiving these notifications at any time by changing the appropriate settings in the Jumbo app or on your smartphone.

For more information about how MongoDB processes your data, please visit : https://www.mongodb.com/legal/privacy-policy. You can consult the data processing agreement signed with MongoDB here : https://www.mongodb.com/cloud-terms-and-conditions.

Section 13. Amplitude

We use Amplitude to analyze analytic data of our users’ usage of the Jumbo App. Amplitude collects the Jumbo App analytics about your use of the Jumbo App with your DeviceID.

Amplitude only uses analytics of our users anonymously, and in accordance with our instructions. For more information about how Amplitude processes your data, please visit https://amplitude.com/privacy. We have signed a specific data protection agreement with Amplitude, including the processing of your data. Please contact us for more information.

Section 14. Singular

We use Singular to help us manage our ad campaign performance. We send Singular our users’ IDFA and IP address together with information regarding their Jumbo subscription plan.

Singular only stores and uses such information in accordance with our instructions, notably when sharing this information to adnetworks Jumbo works with. For more information about how Singular processes your data, please visit https://www.singular.net/privacy-policy/. We have signed a specific data protection agreement with Singular, including the processing of your data. Please contact us for more information.

Section 15. Stripe

Your subscription and payment may be handled by Stripe, depending on factors such as your phone’s make or model, the plan you choose, the country in which you are located, and the features made available to you.

Your personal data, such as your payment method and information required to complete your purchase (such as your billing address), will be secured and stored in Stripe as required by applicable regulations and laws, and payment network requirements (e.g. visa, mastercard, etc.). Note that regulations may require Stripe to retain transaction records for a prescribed period of time.

For Stripe’s data retention policy, please visit: https://support.stripe.com/questions/data-retention-policy. For information about how Stripe processes your date, please visit: https://stripe.com/privacy

Section 16. Front

We use front as our in-app chat provider. Front collects the content you send to Jumbo Privacy in your messages, your DeviceID, and your email if you indicate it. Your information is stored by Front for 45 days.

Front only collects such information to enable us to reply to your queries directly in the Jumbo App, for statistical purposes to build our customer care team, and under our instructions. For more information about how Front processes your data, please visit: https://frontapp.com/privacy-policy. We have signed a specific data protection agreement with Front, including the processing of your data. Please contact us for more information.

Section 17. TaxJar

In order to comply with regional and local tax obligations, we share transaction information from Stripe with our tax compliance provider TaxJar. This includes invoice information including the purchase date, plan, price and purchase location.

Your personal data included in invoices shared from Stripe will be secured and stored in TaxJar as required by applicable regulations and laws. TaxJar will process relevant personal data only as necessary to deliver the services Jumbo has entrusted them with, pursuant Jumbo’s service agreement with TaxJar. Note that regulations may require TaxJar to retain transaction records for a prescribed period of time.

For information on TaxJar’s security and privacy practices, please visit: https://www.taxjar.com/security/

TITLE 3 - Other information about your data

Section 1. Personal Data transfers EU/UK/Swiss-USA

PRIVACY SHIELD UPDATE: ON JULY 16th, 2020, THE EUROPEAN COURT OF JUSTICE HAS DEEMED THE PRIVACY SHIELD NO LONGER AN ADEQUACY DECISION TO MAKE TRANSFERS OF PERSONAL DATA FROM THE EU TO THE USA. WE ARE ACTIVELY WORKING ON THIS TOPIC TO CONTINUE ENSURING THE PROTECTION OF OUR EUROPEAN USERS’ PRIVACY.

Until then, please note that as provided under article 49 of the GDPR, we have the obligation to inform you of the possible risks of the transfer of your personal data to the USA due to the absence of an adequacy decision or other appropriate safeguards since such invalidation. By using the Jumbo App, you guarantee having been informed of such risks and understanding them.

Since 2121 Atelier Inc is located in the USA, we might transfer some of your personal information from the European Union, the United Kingdom or Switzerland, to the USA. We comply and have self-certified with the EU/UK-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, the United Kingdom and Switzerland to the United States. You can check our certification here: Privacy Shield Certification.

If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles will take precedence. You can also learn more about Privacy Shield at www.privacyshield.gov.

As described in the Privacy Shield Principles, Jumbo Privacy is responsible for personal data that it receives and subsequently transfers to third parties. If third parties that process personal data for us do so in a manner that does not comply with the Privacy Shield Principles, we are responsible for such failure, unless we prove that we are not responsible for the event giving rise to the damage.

In compliance with the Privacy Shield Principles, Jumbo Privacy commits to resolve complaints about our collection or use of your personal information. EU, British and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should contact Mary J. Hildebrand, CIPP/US, CIPP/E by email at [email protected].

Jumbo Privacy has further committed to refer unresolved Privacy Shield complaints to ICRD-AAA, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://go.adr.org/privacyshield.html for more information or to file a complaint. The services of ICRD-AAA are provided at no cost to you.

As further explained in the Privacy Shield Principles, binding arbitration before a Privacy Shield Panel will also be made available to you in order to address residual complaints not resolved by any other means. Jumbo Privacy is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission

Section 2. Extraordinary disclosures

We may be obligated to disclose your personal data if we determine that such disclosure is reasonably necessary and required:

(a) to comply with applicable laws or judicial orders;

(b) to protect the rights or property of Jumbo Privacy or other users of our services, including in investigating any violation or potential violation of the law, this Privacy Policy, or our TOS.

We will always keep in mind that your data should be protected therefore we will always fight unjustified requests and be transparent about them.

If Jumbo Privacy or its business or assets are acquired by, or merged into, another company, that company will possess any personal data in our possession at such time and will assume our rights and obligations under this Policy.

Section 3. Security of 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.

Section 4. CCPA

Even though the CCPA does not apply to Jumbo’s activity, we have provided you with all necessary information as provided under the CCPA:

TITLE 4 – Your Rights

As a matter of principle, you can exercise all your rights free of charge.

Section 1. 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 or by contacting the support team directly through the Jumbo App.

If you are unable to complete your requests through the Jumbo App or such services, you can send a detailed message explaining your request to us at : [email protected].

Jumbo Privacy will inform you if it can act on your request or if you need to do it directly in the Jumbo App, with our support.

Jumbo Privacy would also like to inform that the request you send for the exercise of your rights might be kept for follow-up purposes.

• Specification for deletion :

You may also ask us to delete your personal data where one of the following grounds applies:

Please note that the exercise of this right may not be possible when the retention of your personal data is necessary for compliance with statutory or regulatory provisions and in particular for example for the establishment, exercise or defence of legal claims.

Section 2. Restriction of processing

You may request restriction of processing of your personal data in the cases provided for by laws and regulations. You can exercise this right directly through the Jumbo App or by contacting the support team directly through the Jumbo App.

If you are unable to complete your requests through the Jumbo App or such services, you can send a detailed message explaining your request to us at : [email protected].

Section 3. Post-mortem Guidelines

You have the possibility to give guidelines in relation to the storage, deletion and communication of your personal data after your death to a certified trusted third party in charge of ensuring that the wishes of the deceased are respected in compliance with the conditions laid down in the applicable legislation.

You can exercise this right directly through the Jumbo Privacy App or by contacting the support team directly through the Jumbo App.

If you are unable to complete your requests through the Jumbo App or such services, you can send a detailed message explaining your request to us at : [email protected].

Section 4. 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.

Section 5. Liability and Disclaimers

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

Section 6. Information for European users

Pursuant to Article 27 of the General Data Protection Regulation of the European Union, we have appointed ePrivacy GmbH, as our European Representative, which office is located at:

ePrivacy GmbH
Große Bleichen 21
20354 Hamburg
Germany

https://www.eprivacy.eu

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.

Section 7. Contact Us

If you have any questions or concerns regarding this Privacy Policy, please send a detailed message to: [email protected].

Thanks for reading!

Pierre Valade

Chief Executive Officer