This is the Jokers Privacy Policy (the “Privacy Policy” or the “Policy”) that, together with the Jokers Terms and Conditions of Use, applies to the use the Jokers mobile application.
At Jokers, we care about the personal information we collect through the operation of our services. We aim for complete transparency on how we gather, use, and share personal information. Hence, this Policy describes our privacy practices to make sure you understand the information we collect, why we collect it, how it is used and your choices regarding your information. We appreciate the trust you have placed in Jokers with your information.
This Privacy Policy applies from 02/05/2024.
1. Who We Are
The Jokers mobile application (the “App”) offers a platform for couples to facilitate and/or improve their communication, relationship, and life together.
The App is operated by Suikernonkels VOF (also referred to in this Policy as “we”, “us” or “Jokers”).
If you live in the European Union, the company that is responsible for your information under this Policy (the data controller) is Jokers.
If you live outside the European Union, the company responsible for your information is: Suikernonkels VOF
2. Where The Privacy Policy Applies
The present Policy applies to the App operated by Jokers.
3. Information We Collect
Information you provide us:
- Information you directly enter into our App, such as: wish lists, shopping lists, bucket lists, “to do” lists, and any other data.
- Information you provide us when you create a Jokers account, such as your: name, username, preferred language, email address, phone number, gender, date of birth and password.
- Information you provide us when you report a problem with our App, such as crash logs and screenshots.
- Information you provide us when you contact us, such as information that can be found in your correspondence.
- Information you provide us when you participate in surveys about our services, such as responses to our questions and testimonials.
Information we receive from others:
- Other users: other users may provide information about you when they use our services. For instance, your Partner (i.e., the person you identify as your partner or the person who identifies you as their partner) can give us your name and email address.
- Other partners: we may receive information about you from our partners. For instance, we may obtain information about your visits to an advertiser's site which we might use to serve you relevant advertisements in the App.
Information we collect automatically:
- Usage information: we collect information about your activity on our App. For instance, date and time you log in, pages and advertising you click on, how you interact with other users (e.g., date and time of your exchanges with your Partner, how many Jokers you send and receive).
- Device information: information collected about the device you use to access our App, such as: IP address, device ID, the type of device, advertising IDs (such as Google’s AAID and Apple's IDFA), browser type, settings, operating system, service provider.
- Cookies and other similar data collection technologies: we use Cookies or similar technologies (e.g., Pixel tags) to obtain data. For example, Cookies help us remembering your preferences and settings, so you don’t have to set them up every time you visit the App. You may read our Cookie Policy for more information.
- Location information: we might use your IP address to determine your approximate location.
- Other information with your consent: with your consent, we can collect your exact geolocation through several means, for instance, Bluetooth or Wi-Fi connections. With your explicit consent, your geolocation may also be collected even when you aren’t actively using the App.
4. Purpose and Legal Basis For Processing Information We Collect
To process your information as described in Section 3 of the Policy, we rely on the following legal bases for the following purposes:
This is the Jokers Privacy Policy (the “Privacy Policy” or the “Policy”) that, together with the Jokers Terms and Conditions of Use, applies to the use the Jokers mobile application.
At Jokers, we care about the personal information we collect through the operation of our services. We aim for complete transparency on how we gather, use, and share personal information. Hence, this Policy describes our privacy practices to make sure you understand the information we collect, why we collect it, how it is used and your choices regarding your information. We appreciate the trust you have placed in Jokers with your information.
This Privacy Policy applies from 02/05/2024.
- Who We Are
The Jokers mobile application (the “App”) offers a platform for couples to facilitate and/or improve their communication, relationship, and life together.
The App is operated by Suikernonkels VOF (also referred to in this Policy as “we”, “us” or “Jokers”).
If you live in the European Union, the company that is responsible for your information under this Policy (the data controller) is Jokers.
If you live outside the European Union, the company responsible for your information is: Suikernonkels VOF
- Where The Privacy Policy Applies
The present Policy applies to the App operated by Jokers.
- Information We Collect
Information you provide us:
- Information you directly enter into our App, such as: wish lists, shopping lists, bucket lists, “to do” lists, and any other data.
- Information you provide us when you create a Jokers account, such as your: name, username, preferred language, email address, phone number, gender, date of birth and password.
- Information you provide us when you report a problem with our App, such as crash logs and screenshots.
- Information you provide us when you contact us, such as information that can be found in your correspondence.
- Information you provide us when you participate in surveys about our services, such as responses to our questions and testimonials.
Information we receive from others:
- Other users: other users may provide information about you when they use our services. For instance, your Partner (i.e., the person you identify as your partner or the person who identifies you as their partner) can give us your name and email address.
- Third-party account information: to create and log into your Jokers account, you may be able to use one of your third-party account login (such as Facebook Login). The information we may usually access is user data such as your name, user ID, email, etc.
- Other partners: we may receive information about you from our partners. For instance, we may obtain information about your visits to an advertiser's site which we might use to serve you relevant advertisements in the App.
Information we collect automatically:
- Usage information: we collect information about your activity on our App. For instance, date and time you log in, pages and advertising you click on, how you interact with other users (e.g., date and time of your exchanges with your Partner, how many Jokers you send and receive).
- Device information: information collected about the device you use to access our App, such as: IP address, device ID, the type of device, advertising IDs (such as Google’s AAID and Apple's IDFA), browser type, settings, operating system, service provider.
- Cookies and other similar data collection technologies: we use Cookies or similar technologies (e.g., Pixel tags) to obtain data. For example, Cookies help us remembering your preferences and settings, so you don’t have to set them up every time you visit the App. You may read our Cookie Policy for more information.
- Location information: we might use your IP address to determine your approximate location.
- Other information with your consent: with your consent, we can collect your exact geolocation through several means, for instance, Bluetooth or Wi-Fi connections. With your explicit consent, your geolocation may also be collected even when you aren’t actively using the App.
- Purpose and Legal Basis For Processing Information We Collect
To process your information as described in Section 3 of the Policy, we rely on the following legal bases for the following purposes:
Legal basis:
Contractual necessity
Purpose:
Administer your account and provide you with our services:
- create your user profile;
- register your wish lists, bucket lists, shopping lists, “to do” lists and give your Partner access to it;
- manage the Jokers system;
- enable you to connect with your Partner.
Data:
Name, email address, date of birth, information you choose to provide in wish lists, shopping lists, bucket lists and “to do” lists, the email of your partner.
Legal basis:
Legitimate interest
Purpose:
Legitimate interests pursued by Jokers:
- Present you with relevant advertisements and generate income from advertising revenue;
- Improve our App and develop new services.
- Detect, investigate, and prevent security incidents and other, fraudulent, or illegal activity (e.g. by verifying your identity);
- Facilitate access to our services via third party accounts;
- Provide you with customer support to ensure good services;
- Protect our legal rights in legal claims;
- Offer you a consistent experience across your devices.
Data:
Email address, date of birth, gender, approximative geolocation, your answers in surveys about our services, crash logs, date and time you logged, pages and advertising you click on, date and time of your exchanges with your Partner, how many Jokers you send and receive, Cookies or similar technologies, IP address, device ID, the type of device, advertising IDs, browser type, settings, operating system, service provider, data proving your consent, data necessary for us to establish, commence or defend civil or criminal proceedings, including to protect the Jokers services, our property or other legal rights.
Legal basis: Compliance with legal obligation
Purpose: Comply with regulations requiring us to take additional measures to protect children.
Data: Date of birth.
Legal basis: Consent
Purpose:
- Send you marketing information about the App;
- Serve you with relevant advertising based on your geolocation.
Data: Email address, exact geolocation.
- How We Share Some Of The Information We Collect
- Service providers and partners: we may use service providers and partners to help us operate and ameliorate our services. For instance, third parties may help us with data hosting, maintenance, analytics, customer support, marketing, advertising and security operations. We make sure all of our service providers and partners agree to strict confidentiality and privacy obligations.
- Subsidiaries: we may share personal information we collected about you to a current or future company under a common control. All subsidiaries having access to your personal information will be required to respect this Policy.
- Business transfers: the Policy will continue to apply to your information in case of a merger, acquisition, sale of company assets, or bankruptcy, resulting in the transfer of user information to third party.
- Legal, regulatory and other obligations: we may disclose information with law enforcement agencies, courts, government agencies, or other parties in accordance with legal, regulatory and other obligation. For example, we might be required to reveal information by a court order. We only share information in response to such requests if we consider in good faith that disclosure is required to comply with the law; safeguard the rights, property, or safety of a user, other persons, or Jokers.
- Advertisers: we may share data with advertisers about the categories of people seeing their advertisements (e.g. categories by age, gender, approximative geolocation), and about the performance of their ads, but we don't divulge personal identifiers with them.
- With your consent or at your request information may be disclosed and shared with your permission or at your request.
- With other users: we share your wish lists, shopping lists, bucket lists and “to do” lists with your Partner.
- Cross Border Data Transfers
Some of the third parties listed in Section 5 of the Policy may be located in countries outside European Union (EU), that provide a sufficient degree of data protection, according to adequacy decisions of the European Commission.
To countries that have not been found to provide adequate levels of protection according to the European Union, your data will only be transferred following the implementation of Standard Contractual Clauses and any additional safeguards that may be required on an individual basis. Standard contractual clauses bind companies transferring personal data to preserve the security and privacy of your information.
- Your Rights
Under the General Data Protection Regulation (GDPR), you have the right to:
- Be informed and access your information: you have the right to know if information about you is being processed by Jokers and why (see Section 4). You also have the right obtain a copy of the personal data undergoing processing;
- Verify and seek rectification: you have the right to verify the accuracy of your personal data collected by Jokers and ask for it to be updated or corrected;
- Withdraw your consent: you may withdraw your consent at any time to let us process your data;
- Object to the processing of your information: you have the right to object to the processing of your information if the processing is carried out on a legal basis other than consent by providing us grounds in relation with your particular situation to justify the objection. You can object to the processing of your data for direct marketing purposes at any time and without providing any justification;
- Restrict the processing of your information: you have the right to restrict the processing of your information in certain circumstances set out by law;
- Delete or erasure: you have the right to obtain the erasure of information about you in certain circumstances set out by law;
- Data portability: you have the right to receive your data in a structured and machine-readable format and transmit it to another controller;
- Lodge a complaint: if you consider that we have our processing of your personal data have infringed the law, you have the right to bring a claim before the Supervisory Authority in the European Union Member State of your habitual residence, place of work or place of the alleged infringement. In Belgium, this is the Autorité de la protection des données - Gegevensbeschermingsautoriteit (APD-GBA) (contact@apd-gba.be).
How to exercise your rights?
Any requests to exercise your rights described in the present Section, can be directed to Jokers, through the contact details provided in section 11. Requests are free of charge and Jokers will provide you with the information required by law as soon as possible — always within a month.
- Further Information For Residents of California
This section supplements Jokers’s privacy Policy and applies to Californian consumers.
The table below describes the categories of personal information we collect and process, third parties we share your personal data with as well as our processing purposes, in the preceding twelve months since this Policy was last updated. The table below is based on definitions laid out in the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act.
Categories of Personal Information:
Identifiers such as name, username, cookies, pixel tags, email address
Categories of Third Parties for Operational Business Purposes to which Personal Information is or may be Disclosed (see Section 5)
Current or potential affiliate businesses, service providers, public authorities, other users of the App (e.g. your Partner)
Processing Purposes (See also Section 4 of the Policy)
- Create your user profile;
- Protect our legal rights in legal claims;
- Provide our services;
- Detect, investigate, and prevent security incidents and other, fraudulent, or illegal activity;
- Send you marketing information about the App;
- Serve you with relevant advertising;
- Provide you with customer support.
Categories of Personal Information:
Personal information as defined in the California customer records law, such as contact information: name and email address
Categories of Third Parties for Operational Business Purposes to which Personal Information is or may be Disclosed (see Section 5)
Current or potential affiliate businesses, service providers, public authorities
Processing Purposes (See also Section 4 of the Policy)
- Create your user profile;
- Protect our legal rights in legal claims;
- Provide our services;
- Detect, investigate, and prevent security incidents and other, fraudulent, or illegal activity;
- Send you marketing information about the App;
- Serve you with relevant advertising;
- Provide you with customer support.
Categories of Personal Information:
Characteristics of protected classifications under California or federal law such as age and gender
Categories of Third Parties for Operational Business Purposes to which Personal Information is or may be Disclosed (see Section 5):
Current or potential affiliate businesses, service providers, public authorities, advertising networks
Processing Purposes (See also Section 4 of the Policy):
- Protect our legal rights in legal claims;
- Comply with regulations and legal rules;
- Detect, investigate, and prevent security incidents and other, fraudulent, or illegal activity;
- Serve you with relevant advertising.
Categories of Personal Information:
Commercial information, including wish lists and shopping lists data
Categories of Third Parties for Operational Business Purposes to which Personal Information is or may be Disclosed (see Section 5):
Current or potential affiliate businesses, service providers, public authorities, advertising networks
Processing Purposes (See also Section 4 of the Policy):
- Improve our App and develop new services;
- Serve you with relevant advertising;
- Provide you with our services.
Categories of Personal Information:
Internet or network activity information such as search history, interactions with our online properties, and information regarding your interaction with advertisements on our App
Categories of Third Parties for Operational Business Purposes to which Personal Information is or may be Disclosed (see Section 5):
Current or potential affiliate businesses, service providers, public authorities, advertising networks
Processing Purposes (See also Section 4 of the Policy):
- Offer you a consistent experience across your devices;
- Serve you with relevant advertising;
- Detect, investigate, and prevent security incidents and other, fraudulent, or illegal activity.
Categories of Personal Information:
Geolocation data at a city-level only, derived from your IP address
Categories of Third Parties for Operational Business Purposes to which Personal Information is or may be Disclosed (see Section 5):
Current or potential affiliate businesses, service providers, public authorities, advertising networks
Processing Purposes (See also Section 4 of the Policy):
- Comply with regulations and legal rules;
- Serve you with relevant advertising;
- Detect, investigate, and prevent security incidents and other, fraudulent, or illegal activity.
Categories of Personal Information:
Information you choose to put in our App.
Categories of Third Parties for Operational Business Purposes to which Personal Information is or may be Disclosed (see Section 5):
Current or potential affiliate businesses, service providers, public authorities, advertising networks, other users of the App (e.g. your Partner)
Processing Purposes (See also Section 4 of the Policy):
- Serve you with relevant advertising;
- Improve our App and develop new services;
- Provide our services.
Your Rights and Request
If you are a California resident, you may exercise the following rights:
- Right to correct inaccurate personal information: residents of California have the right to request that we correct inaccurate information we hold about you;
- Right to know what personal information is being collected and access personal information: residents of California have the right to know what categories of personal information we collect, use, sell and disclose, including the right to request specific pieces of information we have collected about them;
- Right to opt-out of sale or sharing of personal information: residents of California have the right to opt out of the sale or the sharing of their personal information. Residents of California also have the right to request that we limit our use or disclosure of their sensitive personal data. Click on the "Opt-out" link to opt out of the sale or sharing of your personal information.
- Right to non-discrimination: we do not discriminate against Californian residents for exercising their rights under the CCPA. For instance, we will not discriminate against Residents of California by denying services or providing a different quality of goods or services just because they exercised their consumer privacy rights. However, if you refuse to provide us specific personal information, like your e-mail address, or ask us to delete or stop sharing specific personal information, and that personal information is necessary for us to provide you with our services, we may not be able to provide you with certain functions of the App.
- Deletion: residents of California have the right to request that we delete the personal information we have collected from you.
How to Submit a Request:
To request information, access, correction, deletion or opt-out as a California resident, contact us using the information available in section 11 of this Policy.
- Security
We employ several technical, organizational and physical measures to protect your personal information against unauthorised access and erasure and unlawful processing.
In order to ensure the confidentiality, availability and integrity of your data, we use security methods that involve encryption or pseudonymization.
In addition, we regularly review and update our security measures.
Unfortunately, no mobile application can ever be 100% secure against data loss, hacking, unauthorized access, or other security lapses. If we suspect or find evidence of a security breach, we reserve the right to immediately cease your usage of all or some of the services of the App. Please contact us right away using the contact details listed in section 11 if you believe that your account or information is no longer secure.
- How Long We Retain Your Information
We keep your personal information only as long as we need it for the purposes for which the personal data are processed (as set out in Section 4) and as permitted by applicable law.
When your account is deleted, we make sure your information is no longer viewable in the App. It is still possible to reactivate your account for a maximum of 28 days, in case it was inadvertently erased. We start the process of removing your personal data from our systems after 28 days, unless we must keep it:
- to enable us to provide evidence of our compliance with applicable law (for instance, records of your consents for processing data for a period of five years to demonstrate our compliance with the applicable law);
- on the basis of our legitimate interests, in the event of a claim or dispute requiring us to keep the relevant information or for safety and security reasons (for instance, data might have to be preserved to stop a banned user from creating a new account due to risky behaviour or security incidents).
Note: should you remove information from your profile or deactivate your account, copies of such information might still be accessible and/or viewable to the extent that it was copied or saved by other users in the past (e.g. your Partner). We unfortunately cannot control such situation and do not take responsibility for it.
- Children's Privacy
The App is not intended for children under the age of 13. We do not retain personal information from anyone we know to be under 13 years of age. Should we later discover that a user is younger than 13, we will take the necessary action to delete the user's personal information from our database and prevent them from using the App.
- Privacy Policy Changes
We periodically evaluate the Policy to ensure that it reflects any changes to the services we offer and to privacy laws. Any change in this Policy will be communicated to you in advance in order for you to have opportunity to consider them.
- How To Contact Us
If you have questions about this policy, you can contact us as described below.
The data controller responsible for your information is Jokers, which you can contact online support@jokersapp.com or by writing to: Frankrijkstraat 25x 1755 Gooik Belgium