Joyn Joyn Data Privacy Policy

2nd of September 2018

Joyn Joyn SCRL  (“Joyn Joyn”, “we”, “our” or “us”) respects the privacy of its users (“User(s)” or “you”). This Privacy Policy is to inform you what information we collect when you visit our website(s) at http://joynjoyn.com and any additional websites owned and operated by Joyn Joyn (the “Site”) or when you use our downloadable mobile application available on Google Play Store or Apple App Store (the “App”) or use our chatbot interface available at  https://www.messenger.com/t/joynjoynbot (the “bot”) or when you use our API (the “API”) documented at http://developper.joynjoyn.com , all these usages collectively referred to as the “Service”.

You may access and/or use the service only if you fully agree to this privacy policy and by accepting this privacy policy, accessing and/or using the service , you signify and affirm your informed consent to the collection and processing of your personal information as defined and explained here below.

If you disagree to any term provided herein, you may not use the service.

Please note: you are not obligated by law to provide us with any information. You hereby acknowledge, warrant and agree that any information you do provide us is provided of your own free will and consent, for the purposes and uses described herein.

  1. Information we may collect

We may collect two types of data and information from our Users when using the Service.

The first type of information is nonidentifiable and anonymous information (“Non-Personal Information”). We are not aware of the identity of the User from which we have collected only the Non-Personal Information. Non-Personal Information which is being gathered consists of technical information and behavioural data regarding the activity of the User on the Service, operation system and browser, type of mobile device, and operating system version and settings, User’s screen resolution, duration of usage of the Service, User’s ‘clickstream’ on the Site, keyboard language, etc.

The second type of information is individually identifiable information (“Personal Information”). This information may, in itself or taken together with additional information available to Joyn Joyn, identify an individual, or may be of a private and/or sensitive nature.

Personal Information we collect includes: username, email address, phone number, your geo-location, your travel habits (such as routes, preferred transportation services, times of travel from one destination to another), your home address, office address or other favorite destinations, User’s search history on the Service, User’s most-used routes and stations, all User-generated data, User’s reports and reviews regarding the Service, your in-app settings, your rank and user profile including your nickname and avatar, in-app usage scores (“points”) you receive for using the Services, Facebook Access Token, User IP address, and any additional information which the User actively chooses to provided.

The geo-location information we collect includes detailed location and route information, including GPS signals and other information sent by your mobile device for which the Service is installed and currently activated. We collect such information via your use of the Service and through information which you voluntarily provide and/or upload to the Service as further described in this Privacy Policy below, for purposes of providing the Service, enhancing the User’s experience and personalizing the Service and security purposes as further detailed below and.

If you choose to use the Services via a User Account you may create such User Account via Facebook Connect or personal Email address. If you choose to use your Facebook accounts then Joyn Joyn may also have access to your public profile, which includes your name, gender, profile picture, age group and residency. For avoidance of doubt, any Non-Personal Information connected or linked to any Personal Information is deemed as Personal Information as long as such connection or linkage exists.

  1. How we collect information on our users

We are using two main methods:

(1) Use of the Service. We collect Non-Personal and Personal Information when you access or use the Service. In other words, we are aware of your usage of the Service and may gather, collect and record the information relating to such usage. We also collect Non-Personal and Personal Information derived from information we receive from third party services and providers we work with (described here after).

(2) Voluntarily Provided. We may collect Personal Information which you voluntarily provide when you use the Service. We may also collect information provided via your social network account in the event that you voluntarily choose to create a User Account via such third party social networks (like Facebook ).

  1. How we use your information

Your information is collected for the following purposes: (i) to provide you with and to operate the Service, including for statistical and research purposes and creation of aggregated anonymous data; (ii) to personalize the Service and content provided to you, to customize your experience with the Services, to suggest you with transport recommendations based on your preferences and to enable you to retrieve your information; (iii) to develop, improve and customize the Service, the experience of other users and the offering available through the Service; (iv) to be able to contact Users for the purpose of providing them with technical assistance, support, handle requests and complaints and collect feedback in connection with performance of the Services; (v) to send you updates, notices, announcements, and additional information related to the Service ; (vi) to be able to reply to User online queries in connection with performance of the Services; (vii) for customization and improvement of the Service’s accuracy and interface; (viii) to use such information for Joyn Joyn’s commercial purposes; (ix) to display or send to you marketing and advertising material when you are using the Service, including in accordance with the section titled ‘Direct Marketing’ herein and (x) to comply with any governmental agencies’ legal requests or court orders, and/or with any applicable law, rule or regulation. Any statistical, aggregated or anonymous data may be used by us at our discretion for any purpose.

  1. Sharing information with Third Parties

Joyn Joyn will not share any Personal Information it collects with any third party, except in the following cases: (i) to satisfy any applicable law, regulation, legal process, subpoena or governmental request; (ii) to enforce this Privacy Policy and/or the Terms of Use, including investigation of potential violations thereof; (iii) to communicate with its Users regarding ours service; (iv) to detect, prevent, or otherwise address fraud, security or technical issues; (v) to respond to User’s support requests; (vi) respond to claims that any content available on Joyn Joyn’s Service violates the rights of third parties; (vii) to respond to claims that contact information (e.g. name, e-mail address, etc.) of a third-party has been posted or transmitted without their consent or as a form of harassment; (viii) to protect the rights, property, or personal safety of Joyn Joyn, its Users, or the general public; (ix) when Joyn Joyn is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of its assets; or (x) to collect, hold and/or manage your Personal Information through Joyn Joyn’s authorized third party service providers, as reasonable for business purposes, which may be located in a country other than the country of your residency or location, that may not have the same data protection laws as your jurisdiction, as listed below; (xi) pursuant to your explicit approval prior to the disclosure; (xii) cooperate with third parties for the purposes of adding operational features to the Service, enhancing and personalizing the User’s experience, monetization and commercialization; or (xiii) to authorized third party service providers solely for the purpose of providing you with the Service.

For avoidance of doubt, Joyn Joyn may transfer and disclose or otherwise use Non-Personal Information or information which is linked to anonymous random identifiers or information that is aggregated in a nonidentifiable way, at its own discretion.  

  1. Deletion or Modification of personal information

Joyn Joyn retains Personal Information for such a period of time as is necessary in order for Joyn Joyn to be able to use the Personal Information for the sole purposes described in this Privacy Policy and for the purpose of providing its Services under the Terms of Use.

If for any reason you wish to modify or delete your Personal Information please contact us at: support@joynjoyn.com  and we will make reasonable efforts to modify anonymize or delete any such Personal Information pursuant to any applicable privacy laws.

  1. Third Party Software/Services  

While using the Service we may be using third party software and/or service for various needs, inter alia, in order to collect and/or process the information detailed herein (the “Third Party Service Provider”).

Note that these are independent software and/or service providers and Joyn Joyn does not take any liability about the information collection policies of these providers, or about any kind of issue, legal or otherwise, relating thereto.

Third Party Service Provider’s includes the following:

Joyn Joyn may also provide additional transit-related services, including on-demand transit services, provided by its third party operational service partners (as they may evolve from time to time at Joyn Joyn’s discretion). Such third party providers’ services include (non exhaustive list)

  • Uber
  • Drive Now
  • Taxi Vert
  • PickmeApp
  • Cambio
  • Zen Car
  • Ubeequo
  • Billy Bike
  • oBike
  • Villo
  • Google
  • SNCB
  • STIB

, all of which are subject to a respective terms of use and privacy policies.  

  1. Creating an account using Facebook

By signing onto Joyn Joyn using your Facebook account, you agree to provide Joyn Joyn with information (including personal information) obtained from Facebook, for the purposes provided under this Privacy Policy.

In the event that you create a User Account via your Facebook account, Joyn Joyn may have access to your public profile namely your name, gender, email address, photo, age group and residency. Your use of Facebook to create your account is subject to the privacy policies and term of use of such third party social networks.

  1. Use of cookies

To make the Site work properly, when you visit or access our Site we use industry-wide technologies such as “cookies” (or similar technologies) in order to improve your user experience by enabling us to ‘remember’ you, either for the duration of your visit (using a ‘session cookie’) or for repeat visits (using a ‘persistent cookie’).

In addition, we may use cookies in order to deliver ads relevant to you. By using or accessing our Site, you agree to our use of cookies. Most browsers will allow you to erase cookies from your computer’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored.

Please note that by deleting or disabling future cookies, your user experience may be affected and you might not be able to take advantage of certain functions of our Site, therefore, your online experience may be limited.  

  1. Direct Marketing

You hereby agree that we may use your contact details for the purpose of informing you regarding our products and Service, which may interest you, and to send to you other marketing material, transmitted to the email address or to the mobile device.

You may withdraw your consent contacting us at: support@joynjoyn.com. We may also permit, solicit or contract certain authorized partners of Joyn Joyn to conduct advertising campaigns on the Services. In addition, Joyn Joyn may display advertisements via the Service.

Such advertisements that you see when accessing the Service may be targeted on the basis of your geographic location and language. It is clarified that Joyn Joyn is not responsible for the content of said advertisements and the products delivered or services rendered thereby by third parties and you irrevocably and unconditionally agree that we shall not be held responsible or liable in connection thereof.

  1. Security

Joyn Joyn takes a great care in implementing and maintaining the security of our Service and our User’s Personal Information. Joyn Joyn employs industry standard procedures and policies to ensure the safety of its Users’ Personal Information, and prevent unauthorized use of any such information. We cannot, however, guarantee that unauthorized access will never occur.

  1. Data Storage Location

The Information that we collect from you is stored in the European Economic Area (“EEA”)

Information submitted by you may be transferred by us to our other offices and/or to the third parties mentioned in the circumstances described above, which may be situated outside the European Economic Area (for instance in the United States) and may be processed by staff operating outside the European Economic Area. By submitting information via the App, you agree to this storing, processing and/or transfer.

  1. Under 12 year olds

We do not knowingly collect personal information from children under the age of 12. If you are under the age of 12, please do not submit any personal information through the App or email. We encourage parents and legal guardians to monitor their children’s internet use and to help enforce our privacy policy by instructing their children never to provide personal information on our website without their permission. If you have reason to believe that a child under the age of 12 has provided personal information to us, please contact us as specified below, and we will work to delete that information from our databases.

  1. Notifications

We may send you information we think you may find useful or which you have requested from us by push notification and/or by email (if provided), and we or the operating system will always give you the option to opt-out of receiving further notifications or emails.

  1. Changes to our privacy policy

We reserve the right to change this privacy policy from time to time. Any changes and additions to this privacy policy will be posted on our web site and are effective from the date on which they are posted. Please review this privacy notice from time to time to check whether we have made any changes to the way in which we use your personal data. This privacy policy was last updated on 2nd September 2018.

  1. Contacting us

Please submit any questions, concerns or comments you have about this privacy and cookies policy or any requests concerning your personal data by email to support@joynjoyn.com. By contacting Joyn Joyn you warrant and agree that you are free to do so, and that you do not provide Joyn Joyn with information which violate any third party intellectual rights . Without degrading from the aforesaid, all rights, including intellectual property, arising from your communication with us will be owned by Joyn Joyn and will be considered as Joyn Joyn’s confidential material. It is clarified that any use of the information you are providing us will be done in Joyn Joyn’s sole discretion, and Joyn Joyn is not obligated to use all or part of such information.