This privacy policy (hereinafter “Privacy Policy”) governs the manner in which Jongla Oy (hereinafter “Jongla”) processes data collected from the users of this website and Jongla Mobile Messaging Service or other services of Jongla that post this Privacy Policy (hereinafter the “Service”). Use of the Service is also governed by Jongla Terms of Use which provide more specific terms regarding the use of the Service including the processing of your personal data and which are incorporated herein by reference.

1. Use of the Website

This website is provided “as is” without any representations or warranties.

By visiting this website your online device will automatically receive one or several cookies which are transferred from this website to your Internet browser. By using this website you consent Jongla to place cookies to your online device. Jongla uses cookies to provide you with the basic functionalities of this website. Jongla uses also third party services (such as Google Analytics and Localytics) to analyze the use of its website. More specifically, Jongla uses this information to measure user statistics, to improve the website and the Service, and to detect any technical or usability problems. Jongla may outsource the processing of cookies to third parties who may also be situated outside the European Union and the European Economic Area, such as for example in the United States, Singapore, and Brazil. Jongla will not identify you before your registration to the Service.

If you wish to avoid or delete a cookie, you may do this through the settings of your browser. However, if the browser’s cookie-function is disabled, some functions of this website may operate with reduced functionality or not at all.

2. Use of the Service

2.1 Registration

You may start using the Service by downloading the application from the applicable application store and installing it to your device or by accessing the Service via Jongla website. In order to register to the Service, you need to provide your phone number to which Jongla will send a SMS verification code. After entering the code you will need to create a username for the Service. You can then continue completing your profile by adding, for example, your avatar, cover image, gender, birthday, and other information as well as promoting your profile in social media services, such as on Facebook and Twitter.

2.2 Personal Data Collected

2.2.1 Phone Number and Contact Lists

When you sign up for the Service, you will be asked for your phone number and access to your phone’s contact list. Once you grant permission to this information, it is then stored in our servers. The purpose of storing this data is to check which one of your contacts are already registered with the Service. Also this information is used to notify you if any of your contacts registers with the Service. This data and your other personal data collected, as set forth in this Privacy Policy, is stored and processed in our servers which may be outsourced and which may also be situated outside the European Union and the European Economic Area, such as in the United States, Singapore, and Brazil. To provide high quality services, Jongla uses multiple servers that may be supported by external service providers, such as Amazon Web Services, Inc. and its affiliates (AWS), for storing and processing your data. For more information, for example, on the technical measures used by AWS, please visit AWS website.

2.2.2 Images, Videos, and Other Shared Content

The Service allows you to share digital content such as, for example, text, images, and videos with your friends or group of friends. When you, as a user, send such content to your friends, it (i.e., the content) first goes to the servers of the Service where it is temporarily stored. The purpose of storing this data in our servers is to provide you access to it later if requested by you (as the sender) or by your friend (as the receiver). Also this data is used to synchronize content across multiple platforms such as phone or a PC if you use more than one device. The content is then sent to other users of the Service to whom you, as the sending user, wanted to send it to.

Jongla does not use your content for any other purpose than to enable communication between you and your friends. Third parties do not have access to this data.

2.2.3 Location Information

You can choose to attach location information to messages sent to other users of the Service. If you choose to share your location information, Jongla retrieves the same from the device used by you (the user) and sends it to the servers of the Service where it stores it together with the message. The location information is then shared with other users of the Service selected by you when sending this information. The location information may also be processed by Jongla and third parties to display advertisements.

2.2.4 Analytics Collection

Jongla uses Localytics to track and report user behavior anonymously through user log information. This information helps us evaluate how our users use the Service in order to improve our services. This report does not include personally identifiable data. Localytics has access to this data to perform these tasks on behalf of Jongla. For more information on how Localytics uses your data for analytics purpose, please visit Localytics privacy policy.

2.2.5 Other Data

In order to provide you with the Service, ensure the security, safety, and quality of the Service, as well as for communicating with you and for other purposes described in more detail in the Jongla Terms of Use, Jongla may also process your other personal data such as your e-mail address, country of location, gender, data regarding your device you use for accessing the Service, as well as other data.

2.3 Children’s Privacy

The Service is not directed to, designed for, or intended to attract users under the age of 13.  Also we do not intentionally collect data from persons under the age of 13. For users aged 13 or older but under the age of majority, the use of the Service is subject to consent from a legal guardian.

3. Administrative Information and User’s Rights

3.1 Data Controller and Contact Information

Jongla Oy (business identity code: 1893981-7) having its registered address at Itämerenkatu 1, FI-00180 Helsinki, FINLAND is the data controller of the Service.

The file description (“rekisteriseloste” in Finnish) of the Jongla user data register is available both in Finnish and in English here.

3.2 User’s Rights of Access and Other Rights

You, as the user, have right of access to the data on you. You may check the data on you primarily by accessing the Service and your own profile. You may also request Jongla to provide the data by sending a written request to Jongla. If you note that some data is incorrect or incomplete, you must either immediately correct the data yourself or request Jongla to make the correction.

Date of last update: 19 December 2014