Effective Date March 10, 2020
Joonto is a cloud communications platform that provides users with building blocks to add communications to web and mobile applications or manage conference call applications.
We understand that when you use Joonto’s platform you are placing your trust in us to handle your data appropriately, including the personal information of you and your end users. That is why we take a “No Shenanigans” approach to data protection.
Part of our “No Shenanigans” approach is to make sure that you, the developer, have information about how we process personal information in connection with your use of our products and services, including our website. We want to enable you to make informed decisions about your personal information when building your software applications on Joonto’s platform. We also want to provide you with relevant information to help your end users make informed decisions about their personal information when they use your software applications built on Joonto’s platform.
We’re realists here. And, as much as our Privacy Team wishes it were otherwise, we know that most developers don’t spend their time reading privacy notices…
But they do read API docs! So, we’ve added information to our Joonto API docs and Joonto Conference Documentation about personal information processing to give you information to help you build in a smarter, more privacy-aware way.
So, let’s say you’ve read everything here and you’ve checked out our product-specific API docs, but you still have more questions or concerns about how we’re processing personal information, or you would like to know more about how to exercise your rights. You can contact our Privacy Team in the Office of the Data Protection Officer by either emailing us at [email protected] or, by writing to us at:
Joonto processes two broad categories of personal information when you use our products and services:
- Your personal information as a customer (or potential customer) of Joonto’s services — information that we refer to as Customer Account Data, and
- The personal information of your end users who use or interact with your application that you’ve built on Joonto’s platform, like the people you communicate by way of that application — this category contains both your Customer Usage Data (e.g., communications metadata) and your Customer Content (e.g., the contents of communications).
- Joonto processes these categories of personal information differently because the direct relationship we have with you, our customer, is different than the indirect relationship we have with your end users.
How Joonto Processes Your Personal Information
Data protection laws and privacy laws in certain jurisdictions, like the European Economic Area (EEA), differentiate between “controllers” and “processors” of personal information. A controller decides why and how to process personal information.
A processor processes personal information on behalf of a controller based on the controller’s instructions. When Joonto processes your Customer Account Data, the Joonto entity with whom you are contracting is acting as a controller.
Broadly speaking, we use Customer Account Data to further our legitimate interests to:
- understand who our customers and potential customers are and their interests in Joonto’s product and services,
- manage our relationship with you and other customers,
- carry out core business operations such as accounting, filing taxes, and fulfilling regulatory obligations and
- help detect, prevent, or investigate security incidents, fraud and other abuse and/or misuse of our products and services.
What Personal Information Joonto collects
- While we’re on the subject of Customer Account Data and Customer Usage Data, we’d like to give you a brief summary of the categories of personal information that might be found in the Customer Account Data and Customer Usage Data that we collect from our customers and their end users, so you can know at a glance what we’re talking about.
- We collect and process your personal information:
- When you visit a Joonto public-facing website like Joonto.com, Joonto.org, authy.com, or Joonto Conference.com, sign up for a Joonto event, like SIGNAL, or make a request to receive information about Joonto or our products, like a Joonto whitepaper or a newsletter;
- When you contact our Sales Team or Customer Support Team; and
- When you sign up for a Joonto, Authy, or Joonto Conference account and use our products and services.
We call this personal information Customer Account Data. We also collect Customer Usage Data from you when you send or receive communications through your use of our services. This data might take different forms, and we might use it for different purposes — read on for more information.
When you visit our website, sign up for a Joonto event or request more information about Joonto, we collect information automatically using tracking technologies, like cookies, and through web forms where you type in your information. We collect this information to provide you with what you request through the web form, to learn more about who is interested in our products and services, and to improve navigation experience on our pages.
You may share personal information, like your contact information, with a member of our Sales or Customer Support Team when you communicate with them. We keep a record of this interaction.
When you sign up for an account with us, we ask for certain information like your contact details and billing information so we can communicate with you and so you can pay for our products and services. We also collect some information automatically, like your IP address, when you log in to your account or when your software application built on Joonto makes requests to our APIs. We use this to understand who is using our services and how, and to detect, prevent and investigate fraud, abuse, or security incidents.
We may collect information about you, as our customer, from publicly-available sources so we can understand our customer base better.
Joonto will store your Customer Account Data as long as needed to provide you with our services and to operate our business. If you ask Joonto to delete specific personal information from your Customer Account Data (see ‘How To Make Choices About Your Customer Account Data’ below), we will honor this request unless deleting that information prevents us from carrying out necessary business functions, like billing for our services, calculating taxes, or conducting required audits.
You can make various choices about your Customer Account Data through the account portal, such as accessing it, correcting it, deleting it, or updating your choices about how it is used, when you log into your Joonto account or through the marketing preferences center. Any other requests about your data you cannot make through these self-service tools, you can request by emailing [email protected] or contacting Customer Support.
For those customers that would like more information about our use of Customer Account Data or Customer Usage Data, you have the ability to request:
- that we provide details about the categories of personal information that we collect about you, including how we collect and share it;
- that we provide you access to the personal information we collect about you; and
- that we delete the personal information we have about you.
- Please be aware that when you ask us for these things, we will take steps to verify that you are authorized to make the request.
How Joonto Processes Your End Users’ Personal Information
Your end users’ personal information typically shows up on Joonto’s platform in a few different ways:
- Communications-related personal information about your end users, like your end users’ phone numbers for number-based communications, your end users’ email addresses for email communications, IP addresses for IP-based communications, or device tokens for push notifications, show up in our systems when you use or intend to use this information to contact your end user through use of our products and services.
- Your end users’ personal information may show up in “friendly names,” which are strings you provide, if you choose to include your end users’ personal information as part of a string.
- Your end users’ personal information may also be contained in the content of communications you (or your end users) send or receive using Joonto’s products and services.
We call the information in the first two bullets above Customer Usage Data. The information in the third bullet is what we refer to as Customer Content.
As noted above, data protection law (including privacy law) in certain jurisdictions, like the EEA, differentiate between “controllers” and “processors” of personal information. When Joonto processes Customer Content, we generally act as a processor. When we process Customer Usage Data, we act as a processor in many respects, but we may act as a controller in others. For example, we may need to use certain Customer Usage Data for the legitimate interests of billing, reconciling invoices with telecommunications carriers, and in the context of troubleshooting and detecting problems with the network.
We use Customer Usage Data and Customer Content to provide services to you and to carry out necessary functions of our business as a communications service provider. We do not sell your end users’ personal information and we do not share your end users’ information with third parties for those third parties’ own business interests.
Details regarding how long your end user personal information may be stored on Joonto systems and how to delete, access, or exercise other choices about end user data will depend on which Joonto products and services you are using and how you are using them. For that reason, our API docs for each of our products and services, along with Joonto Conference’s documentation, are the best place to find more detailed information about managing end user data collected and stored in connection with your use of our products and services.
We do not sell or allow your Customer Account Data to be used by third parties for their own marketing purposes, unless you ask us to do this or give us your consent to do this. Further, we do not sell your end users’ personal information. We also do not share it with third parties for their own marketing or other purposes, unless you instruct us to do so.
When you use our account portal, or our other products and services, personal information of you and your end users processed by Joonto may be transferred to the United States, where our primary processing facilities are located, and possibly to other countries where we or our service providers operate. These transfers will often be made in connection with routing your communications in the most efficient way.
Joonto employs appropriate safeguards for cross-border transfers of personal data, as required by applicable local law, including Binding Corporate Rules and the EU–U.S. Privacy Shield and Swiss–U.S. Privacy Shield Frameworks.
Joonto may use automated decision making using a variety of signals derived from account activity to help identify and suspend accounts sending spam or engaged in other abusive or fraudulent activity. Holders of accounts suspended under these circumstances are notified of the suspension and given an opportunity to request human review of the suspension decision.
We hope we can resolve any disputes relating to our data protection practices between us. You can raise your concern or dispute by emailing our Privacy Team at [email protected]
For individuals in the EEA, you have additional rights to make a complaint to a competent data protection authority or commence proceedings in a court of competent jurisdiction in accordance with applicable data protection laws.
How We Secure Personal Information
We use appropriate security measures to protect the security of your personal information both online and offline. These measures vary based on the sensitivity of the personal information we collect, process and store and the current state of technology. We also take measures to ensure service providers that process personal data on our behalf also have appropriate security controls in place.
Other Information You May Find Useful
Here’s some other information about our privacy practices, such as how we handle certain types of data like children’s data or protected health information, how we handle do-not-track signals, what to expect if we make changes to our notice, and the legal bases for processing personal information.