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Privacy Policy

JAVNA Privacy Policy

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At JAVNA, we care about your personal data. It is very important to us to be transparent about the data we collect about you, how we use such data and with whom we share it. Therefore, we advise you to read the following Privacy Policy to be informed about the processing of your personal data. 

Through our worldwide network of over 70 direct carrier connections, we reach more than 1 billion people. Our local presence across six continents enables us to react faster, support better, engage more, and offer tailor-made solutions creating communications solutions of the future with our clients. We believe that the responsible use of data supports business growth and builds strong relationships between partners, consumers, and brands. As a business, we are committed to respecting and protecting the privacy of all individuals with whom we interact. 

  1. DEFINITIONS

In the text, we use specific data protection terms, and their definitions are the following: 

The term “JAVNA” or “us” or “we” or “our” refers to the company JAVNA for software industry, with its registered office at the Hashemite kingdom of Jordan, Amman Adnan Halawa Center, Biader Wadi Al-Seer, Industrial Road and registration number 6733. 

The term “personal data” means any information about you by which you can be identified, directly or indirectly. 

The term “controller” means the natural or legal person which determines the purposes and means of the data processing and is responsible for processing such data. 

The term “processor“ means a natural or legal person who processes personal data on behalf of the controller. 

The term “Services” means JAVNA’s cloud-based communication products and services (CPaaS – Communications Platform as a Services). 

The term “you” refers to a natural person (an individual) whose personal data JAVNA collects and processes. 

 

  1. ABOUT JAVNA SERVICES

JAVNA is a Communications Platform as a Services (CPaaS) provider. While providing Services to our customers and processing personal data, we act either as the controller or the processor, depending on the situation. 

Our customers are mainly companies that integrate our Services into their business operations through their own software applications (via API) or using JAVNA Portal (“Customer User Portal” or “CUP”), our website interface. By using our cloud communications platform, our customers are able to send or exchange their communications with their end users using different communication channels (for example, SMS, email, Voice). We are not in direct relationship with our customers’ end users, so we will distribute these communications through telecom operators and other communications providers. 

We act as the processor when processing personal data of individuals on behalf of our customers, and for the sole purpose of providing our Services to them. We do that within limits and according to customers’ instructions and in line with the Service terms and conditions, agreement for Services and/or data processing agreement concluded with the customer. 

For example, when you, as an end user of our customer are the recipient of communication that our customer sent you by using our platform (such as an SMS message), we send that customer’s communications acting on behalf of our customer. That means that the customer is the controller, and JAVNA is the processor. 

Any request we may receive from customers’ end users regarding their rights related to our activities taken on behalf of our customers will be forwarded to customers, or the end users will be asked to contact them directly. 

In situations when we process personal data for our own purposes and do not act on behalf of someone else, we act as the controller and we are committed to processing that data as described in this Privacy Policy. 

 

  1. CONTROLLER’S CONTACT DETAILS

JAVNA for software industry, with its registered office at the Hashemite kingdom of Jordan, Amman Adnan Halawa Center, Biader Wadi Al-Seer, Industrial Road. 

If you have questions regarding this Privacy Policy or about JAVNA’s privacy practices, you may reach our Privacy team and Data Protection Officer via the email address info@javna.com . 

 

  1. HOW DO WE OBTAIN PERSONAL DATA?

Most of the personal data we process is provided to us directly by you for one of the following reasons: 

    • You created an account and started using our Services 
    • You visited our website, registered for more information on a specific Service, took steps to enter into a business relationship with us and/or you initiated communication with us 
    • You registered to attend or have attended an event organized by JAVNA 
    • You subscribed to our e-newsletter, blog or a webinar 
    • You accepted to participate in our market research activities 
    • You applied for a job or internship with us. 

We also receive personal information indirectly, such as in the situations where: 

    • Our customer or supplier provided us with the contact details of its representatives and personnel who will be our business contact points 
    • Our customer provided us with the contact details of individuals authorized to use its account to access our Services, 
    • Our customer provided us with the contact details of its personnel who will attend our event 
    • Our customer provided us with contact details of its end users (such as telephone number or email address) when using our Services 
    • An employee of ours gave us your contact details when naming you as a referee 
    • From providers of background check services when you apply for a job offer 
    • We have collected your information from LinkedIn or other publicly available sources or from data enrichment providers 
    • We automatically collect certain information, such as your Internet protocol (IP) address, user settings, cookie identifiers, and other unique identifiers, browser or device information, location information (including approximate location derived from IP address ), and when you use our Services 

 

  1. WHAT PERSONAL DATA DO WE COLLECT, WHY AND ON WHICH LEGAL BASIS, HOW DO WE USE IT AND FOR HOW LONG DO WE KEEP IT?

5.1. When we provide the Services to our customers 

5.1.1. To create the customer’s account and enable the customer to start using our Services: 

What personal data do we collect? 

We collect customer’s “account data”, which is data that relates to the customer’s relationship with JAVNA. 

If you sign up for our Services, in order to create a customer’s “account” we ask for your name, contact details (e.g., phone number, email address, country), and certain related information such as your company’s name, industry and your business role, as well as your login details (e.g., username and password, or API key). 

We also collect names, contact details and login details of customer’s personnel or any other individual authorized by the customer to log into and utilize our Services connected with the customer’s account (a “user” of the customer’s account). 

Within the customer’s account we also collect billing information (such as billing address, information on whether the customer is a legal entity or an individual, prepaid or postpaid subscriber, and further information if we are legally required to, and depending on each country’s legislation). 

When doing business with legal persons, we may collect personal data (such as name, business contact details, position in the company) related to their representatives and other personnel that will be our contact points. 

Collecting your name, contact details, login details, and billing information is necessary for us in order to enter into an agreement for Services with you. Therefore, we will not be able to provide you with our Services without collecting this basic information. If you sign up for a free trial account, you are not required to enter your billing information unless and until you decide to continue with a paid subscription to our Services.

How do we collect personal data? 

If you are our customer as an individual, we obtain this data directly from you. If your organization is our customer, we may obtain your personal data either directly from you or via your organization. 

Why do we collect personal data, under which legal basis, and how do we use it? 

We collect and use collected data for agreement signing and agreement administration purposes, to create your account and enable you to access and use our Services, to keep your account secure, to provide you with customer care and technical support, to share relevant information about our products and services and to exercise our rights and fulfil our obligations arising from the business relationship that we may have with you or with your organization. 

Conducting these activities is our legitimate interest in the sense of providing our Services to your organization. However, if you personally are our contractual counterpart, we process your data because it is necessary for the performance of an agreement for Services, or in order to take steps, at your request, prior to entering into the agreement.

 

5.1.2. To enable customers to exchange their communications by the use of our Services and to ensure the security of our network and Services: 

What data do we collect? 

We collect traffic data. Traffic data is data that is processed for the conveyance of a communication exchanged by using our Services or for billing related to that communication, and it includes data on the routing, type, duration, and time of the communication. So, this data encompasses data used to trace and identify the source and destination of a communication (including customer end user’s telephone number or email address, depending on the Service provided). 

We also collect the commands your application communicates to JAVNA (such as your IP addresses, information on your usage, routing information), as well as logs on your activities created during your use of our tools and Services and we connect this information with your account details. 

How do we collect this data? 

We receive the customer’s end user’s telephone number or email addresses from our customer, while other traffic data are automatically generated or unveiled during the process of conveyance of a communication. 

We collect data related to your activities on our platform directly from you when you use our Services. 

Why do we collect this data, under which legal basis, and how do we use it? 

We collect and process traffic data to provide customers with our Services, that is, to manage traffic with the purpose of transmitting customer’s communications toward or from telecom operators and other communication networks, in order to handle customer’s enquiries and to calculate charges. 

If you, as our customer, are an individual, the processing of your personal data is necessary for the performance of our agreement for Services. If our customer is a legal person, we rely on our legitimate interest to process personal data. 

We also process traffic data to prevent spam and fraud, for troubleshooting and detecting problems with the network, and to settle interconnection payments with telecom operators and other communications providers. Should we have a billing dispute with our customer or with telecoms or other communications providers, we may need to use traffic data related to routing (including the end user’s telephone number or email address, as well as the customer’s IP address) in order to resolve it. The carrying out of these activities is our legitimate interest. 

In order to comply with our legal obligations, we may be obliged to retain records containing communications related data as stipulated in the relevant national data retention provisions regulating the law enforcement matter, and to share them upon government request. 

We collect logs on your activities created during your use of our Services and connect this information with the customer’s account details in order to secure customer’s account, to prevent or detect fraudulent activities, and to ensure the security of the JAVNA network. This information is necessary to construct the timeframe of user’s activities in the case of security-related incidents, and to be able to take adequate steps for mitigation. IT security is crucial for us, so for these activities we rely on our legitimate interest and on the legitimate interest of our customers to maintain and improve the security of our network and Services. 

 

5.1.3. To improve our products and Services 

What data do we collect? 

We collect the data you generate during your activity on our platform (e.g. your behaviour records inside our web interface, such as time spent, pages visited, history of your visits and features used). 

How do we collect this data? 

We obtain this data directly from you. When you browse our website and use our Services, we automatically collect data by placing necessary cookies and trusted tracking technologies on your browser. 

Why do we collect this data, under which legal basis, and how do we use it? 

The information we collect helps us maintain and improve our website and business. It usually includes your IP address, browser type, the pages you have visited and the order you visited them in as well as whether you are a new or a returning visitor. 

If you are already our customer, we’ll use the data collected from your account to gain insight into the way you use our platform and Services, what your business needs are, past support issues, and so on. This information makes it possible for us to tailor our assistance and product offers and provide the best possible support. 

We analyze your activities on our platform and collect data that is useful for the improvement of our products and Services, relying on our legitimate interest. This may include using your personal information to create de-identified and / or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services or other de-identified analyses we create. We take partially automated measurements that include human intervention in order to analyze the way you use the features and tools available on our platform (e.g., by tracking and recording your behavior inside our web interface, including time spent, pages visited and features used) in order to give you recommendations to improve your performance (e.g. how to better access some feature). Also, we create statistics on the use of our tools to understand which tools have a user-friendly design and which should be enhanced. The general goal of such activities is to enhance your and your company’s messaging execution when communicating with your end users. 

How long do we keep your personal data? 

We will erase all information collected about our customers (basic identification data, contact details, business details and account details) within 7 years after the closure of the account. Moreover, information about reseller’s customers and account users (basic identification data, contact details, business details and account details) will be kept 12 months after the account closure. 

In order to maintain records of our business relationship and to comply with the applicable financial and tax regulations, we keep business agreements related to JAVNA Services for 10 years after the end of the year when the account was closed and invoices for 10 years after the end of the invoicing year. Longer periods may apply when required by the local legislation. 

Customers’ requests and other communication exchanged with our support team via our help desk (support ticketing) system may be kept for 7 years upon the ticket closure. 

Traffic data containing end users’ information (such as MSISD-number, telephone number, IMSI, IMEI) will be kept, in our communication detail records, for 12 months after the date of communication. Longer periods may apply if JAVNA needs to comply with applicable national legislation regulating retention of data in electronic communications for law enforcement purposes. In addition, as we may need to keep traffic data in order to calculate charges, we will keep them for billing and to settle our payments towards telecoms and other communications providers until payments are settled, the longest until the end of the period during which the bill may lawfully be challenged, or payment pursued. In case that a bill remains unpaid or has been challenged before being paid, we will keep data to establish, exercise or defend our legal rights, the longest until the court or other legal procedure is finally closed. 

Customers’ and reseller’s customers traffic data (such as sender name, sender ID, time, type, duration of communication, routing details) are kept for 10 years after the date of communication, since they can be checked by auditors and tax authorities, and they are necessary in order to demonstrate compliance with the relevant financial, audit, and tax legislation. 

Behavior analytics i.e. data generated during your activity on our platform are kept for twenty-five months. 

In case that legal matters such as litigation, law enforcement requests or government investigations acquire us to preserve records, including those containing personal information, we will delete the impacted records when no longer legally obligated to retain them. 

 

5.2. When you provide your products or services to us 

What personal data do we collect? 

If you as our supplier are an individual, we collect your name, contact details (such as address, phone number, email address), certain related information such as your company’s name, industry and your business role, and your billing information (e.g., billing address, information on whether you are a business or an individual, your VAT number, bank account details, and further information if we are legally required to and in accordance with applicable national legislation). 

Collecting this data is necessary for us in order to enter into an agreement with you. Therefore, we will not be able to purchase your products or services without collecting this personal data. 

When doing business with legal entities, we collect personal data related to their representatives and other personnel that will be our contact points (such as their name, business contact details, position in the company). 

How do we collect personal data? 

If you as an individual are our supplier, we obtain this data directly from you. If your organization is our supplier, we may obtain your personal data either directly from you or via your organization. 

Why do we collect personal data, under which legal basis, and how do we use it? 

We collect and will use this data for agreement signing and agreement administration purposes, to maintain and improve our business relationship, to get relevant information about our supplier’s product or services, or to share relevant information about our business and services with you, as well as to exercise our rights and fulfil our obligations arising from the business relationship that we may have with you or your organization. 

Conducting these activities is our legitimate interest in the sense of purchasing products or services from a supplier that is a legal person. However, if you personally are our contractual counterpart, we process your personal data because it is necessary for the performance of an agreement or in order to take steps, at your request, prior to entering into an agreement. 

How long do we keep your personal data? 

When you provide your products or services to us, we keep your business-related personal data (basic identification data, contact details and business details) for 7 years after the end of our business relationship. However, we keep business agreements for 10 years after the end of our business relationship and invoices for 10 years after the end of the invoicing year. Longer periods may apply when required by the local legislation. 

Customers’ requests and other communication exchanged with our support team via our help desk (support ticketing) system may be kept for 7 years upon the ticket closure. 

Personal data of the supplier’s personnel basic identification data, contact details, business details) that were our contact points during the business relationship we had obtained from our supplier will be deleted or made anonymous within 12 months after the end of the business relationship. 

If legal matters such as litigation, law enforcement requests or government investigations require us to preserve records, including those containing personal information, we will delete the records in question when we are no longer legally obligated to retain them. 

 

5.3. When you contact us with a question about our products and services and when we are looking for new business opportunities 

What personal data do we collect? 

We may collect your name, surname and basic contact and business information such as your email address, phone number, country, company, industry, and business role or job title. We will also collect any other information you choose to provide us, depending on the nature of our communication. 

How do we collect your personal data? 

We may collect this information directly from you through our “Contact Sales” or other forms available on our website. After submitting your details, we will send you an email to confirm that our sales team will contact you. 

We may also collect your information directly from you when you register on our website to learn more about our business and services, start chatting with us via our chat channel, take steps to enter into a business relationship with us, submit Startup or Shift Sponsor/Partner application form and when you provide us your contact information when requesting further information. 

We are constantly searching for new business opportunities. Therefore, we may collect your contact and business information indirectly, through business and professional networks and databases (such as LinkedIn) or we may employ third parties that supply us with information collected from publicly available sources and data enrichment providers. We only retain the information that will help us reach potential customers and suppliers that could benefit from our services and products, or if we are interested in their products and services. 

Why do we collect personal data, under which legal basis, and how do we use it? 

We collect this information to contact you, answer your questions, find out if you or your organization are interested in further cooperation with us. 

We use your personal data to provide you with the requested information about our products and services and to see if you are interested in using them, or if we can benefit from using your products and services, as well as to provide you with all the necessary information and support required to ensure the mutually beneficial and satisfying cooperation if you become our customer or supplier. Any further processing of your personal data will be based on the business relationship established with you or your organization and on the lawful processing ground. 

Such activities represent our legitimate interest. 

If there will be a mutual interest in entering into an agreement, we will process your personal data within the presales and purchasing process to ensure adequate technical and administrative support (tender procedures, negotiating, and concluding agreements), and it is our legitimate interest to conduct this process properly. If you personally are our contractual counterpart (as an individual), we process your data because it is necessary for the performance of a contract or in order to take steps, at your request, prior to entering into a contract. 

How long do we keep your personal data? 

If we do not enter into an agreement, we will delete your personal data collected for this purpose within six months after our last communication. 

 

5.4. When we send you our email marketing communications 

What personal data do we collect? 

We collect your name and email address. 

How do we collect personal data? 

We collect this information directly from you if you subscribe to receive our newsletters, blogs or our other email marketing communication by which we provide the information about our business and services. This data is collected through the webforms available on our website. 

For business to business (B2B) marketing, if we have an existing business relationship (our customers, suppliers and their staff), we may use data collected from you or your organization when entering into an agreement or during our business relationship. 

Why do we collect personal data, under which legal basis, and how do we use it? 

Our purpose for collecting the information is the provision of the services to you and informing you about news, webinars and upcoming events. 

We use your details only to provide these services. We also gather statistics around email opening and clicks using industry standard technologies, including clear gifs to help us improve our e-newsletter. 

If you subscribe to our email marketing communication, we rely on your consent provided to us when submitting such webforms. You will receive a confirmation email once you have submitted your details. 

For B2B (business to business) direct marketing, we may rely on our legitimate interest. For the purpose of maintaining and improving our business relationship, it is our legitimate interest to inform our existing business partners (customers and suppliers, including their staff) about our products and services, news, webinars, and upcoming events via email newsletters, blogs or other forms of email communication. 

In any case, you may proactively manage your preferences or opt-out of communications (unsubscribe) with JAVNA at any time using the unsubscribe link provided in all JAVNA’s email marketing communications. In case that you have unsubscribed from our marketing communications (i.e. withdraw your consent or object to the processing) we will stop sending you any marketing materials. 

However, we maintain a so-called “suppression list” that contains only your email address just to be sure that we will not contact you with unwanted content in the future. We retain this information relying on our legitimate interest. 

How long do we keep your personal data? 

If we send you marketing communications based on our legitimate interest (B2B) we will do so only during the business relationship with you or your organization (existing agreement for products or services is in place), or until you object to the processing of your personal data for this purpose. We will keep a suppression that contains email addresses of individuals that objected to receiving our marketing communications until the end of the business relationship with you or your organization. 

If you subscribed to receive our email marketing communications, we will provide you this service until you unsubscribe, i.e. withdraw your consent. In order to prevent you from receiving unwanted content after you had opted-out from marketing communications, your email in the suppression list is kept until you decide to subscribe again to our marketing communications. 

 

5.5. When you register to attend our webinar, business breakfast, or other events 

What personal data do we collect? 

When you register to attend a business breakfast, webinar  or any other event (hereinafter: event), you will be asked to provide your name and contact details (email, phone number, country), as well as your company’s name, industry, and your business role. 

We may also ask you information about the time and place of your arrival as well as accommodation details and dietary requirements you may have. 

If you require us to provide you with an invitation or support letter, or you need to get letter of guarantee to be able to get a visa, we will collect the necessary information required by applicable law (such as your name, address, date of birth, passport details). 

We may collect photos, audio, and video material from our events. 

How do we collect your personal data? 

We collect your personal data directly from you when you fill in our registration forms. 

Sometimes your organization will send us your contact details to attend our event on their behalf, and we will send you an invitation with the link for registration. 

Why do we collect personal data, under which legal basis, and how do we use it? 

If you register for a webinar, we will use your contact details to provide you with the webinar details in advance, to remind you of the webinar and email you the recording of the webinar subsequently. 

If you register to attend our event, we will use gathered information to ensure your place at the event, to be in touch with you, to provide you (via email or by SMS on the phone number you provided in the registration form) all relevant information before your arrival and during the event, to facilitate the event and ensure all organizational support that you may need. For example, help you with information about the location of our event, accommodation, travel or other logistic details related to the event. 

The legal basis we rely on for processing your personal data is your consent, provided when you submit your details through our registration forms. When we collect any information about dietary requirements, we also rely on your consent. 

If you will need an invitation or support letter or letter of guarantee to be able to get a visa, we have to collect the necessary information about you as defined by the applicable legislation. We collect this information just to respond to your request and support you with the necessary documentation and we rely on your consent provided when you submit us your personal data for this purpose. Such information will not be processed for any other purpose than issuing such a document upon your request. However, we may be legally obliged to share such a document with government authorities and to keep it for a certain period of time, as defined by applicable legislation. 

We also keep events’ participants lists containing only your name, contact details, your company’s name, industry and your business role. In this case, the processing purpose is to maintain a list of former participants in order to invite them to future events we consider they might be interested in. To be able to stay in touch with you, invite you to our other events, and inform you about our products and services, we rely on our legitimate interest. You may object to these communications at any by time using the unsubscribe link provided in all JAVNA’s emails and we will stop sending you event invitations. 

We also conduct promotion activities of the events we held. In this case, the processing purpose is to promote our events, and it consists of publishing photos, videos, audios, and texts in online and offline media. These activities represent our legitimate interest. 

How long do we keep your personal data? 

Personal data collected when you register for our webinar are kept for 18 months after the webinar. 

For off-line events, we keep events’ inviting lists for three years after the event day. 

All other personal data collected will be kept only for the duration of the event (accommodation and other logistic data) are erased within 60 days after the event day. Invitation, support letter or letter of guarantee will be kept for a period of time determined by the applicable legislation. 

 

5.6. When we perform research activities 

5.6.1. When we perform market research activities 

What personal data do we collect? 

We collect your name and contact information (email address). The idea of the researches we conduct is to gather anonymous information. Therefore, our intention is to collect only your personal data necessary to send you a questionnaire but not to link the anonymous answers with you in any way. 

How do we collect your personal data? 

We collect your name and contact data (email address) from business and professional networks (for example LinkedIn), or from our databases if you or your organization are our customers, suppliers or business contacts. 

Why do we collect your personal data, under which legal basis, and how do we use it? 

We conduct market research activities in order to receive anonymous information and feedback for improving our products and services and targeting potential. 

Firstly, we invite you to take a survey by sending a generic untraceable URL to a survey questionnaire. If you decide to participate and answer our questions, we will not ask you to unveil any personal data, and our intention is to keep the answers anonymous. 

When searching for your email address, we rely on our legitimate interest. Our intention is to collect anonymous information. However, if you disclose any information about you in your answers, we will rely on your consent. 

Keep in mind that we respect your privacy rights, so we do not carry out any activity to link the answers provided with you, and we do not inform other organizations (e.g. your employer) on the answers you provided in any way.

How long do we keep your personal data? 

We will process the answers you provided in order to have general feedback on our products and services. However, we will never ask you to reveal any personal data in your answers, our intention is not to collect personal data within this activity, and if you reveal any personal data in your answers, it will be promptly deleted. 

 

5.6.2. When we perform user experience research 

What personal data do we collect? 

We collect your personal data such as name, surname, email, and job title. We are committed to collecting and processing only personal data necessary to fulfill the aim of our research. The aim of the research we conduct is to collect feedback from users of our products to improve them based on users’ practical experience and needs. 

How do we collect your personal data? 

We collect your name and contact data (email address) from our databases if you or your organization are our customers, suppliers, or business contacts to invite you to be part of our research hub. 

If you apply to be part of our research hub and participate in our research, we will collect the personal data directly from you through a third-party provider who will process it on our behalf.

Why do we collect your personal data, under which legal basis, and how do we use it? 

We conduct user experience research activities to receive feedback for improving our products and services. 

Firstly, we invite you to be part of our research hub via email by sending you a link to apply. When inviting you to be part of our research hub, we rely on our legitimate interest. 

Your participation is completely voluntary, and if you decide to be part of our research hub and participate in our research, we will rely on your consent for personal data collected and further processed. We will contact you only about research related to the product you already use or have used. 

The research may be recorded, and we will take notes of your comments and actions. The research results, recordings, and notes are used only for improving our products and would be shared with the responsible teams, such as product design and development teams. 

How long do we keep your personal data? 

Data deletion deadlines are applied to ensure data is erased once no longer necessary for research purposes. 

 

5.7. When you visit our webpage 

We use third-party services such as Google Analytics when you visit www.javna.com in order to collect standard internet log information and details on visitor behavior patterns. We do this to find out information such as the number of visitors to various parts of the site. This information is only processed in a way that does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of visitors to our website. We also use LinkedIn Analytics.  

When you browse our website, we automatically place necessary cookies on your browser. You can opt in to accept advertising or analytical cookies. The information we collect helps us maintain and improve our website and business. It usually includes your IP address, browser type, the pages you’ve visited and the order you visited them, as well as whether you’re a new or returning visitor.  

 

5.8. When you apply for a job or internship with us or when you sign up to receive job posting updates 

What personal data do we collect? 

When you apply for a job or internship with us, we collect your first and last name, contact information (email address and telephone number) and place of residence as well as information about your education, previous work experience, and any other information you choose to share with us in your resume (CV) or application when expressing interest in joining our team. 

When permitted by applicable law, we may also collect professional information about you from the business networking sites you use (such as LinkedIn) and we may search their content in order to find out more professional information about you if your resume or application contains links to other sources (e.g. web pages). 

If we arrange an interview and you go through our selection process, we may collect further information gathered from you during the interviews, results of conducted evaluation tests, interview notes and reviews of our colleagues who interviewed you. We may also collect information about your professional experience from your referees, if you indicated them. If you are a successful candidate, we might also conduct a background check if permitted by the legislation. We will provide a separate privacy policy to you prior to conducting it. 

When you sign up to receive job posting updates, we collect your first and last name as well as your email address. 

How do we collect your personal data? 

We collect your personal data directly from you when you submit your resume or application directly into our recruitment software or when you create an account there to receive job posting updates. 

We may collect your personal data from recruitment agencies we have engaged in order to help us find potential candidates for open positions or from business networking sites you use such as LinkedIn. 

We may collect further information about you during the selection process. This information will be generated by you and by us. For example, you might complete an evaluation test or we might take interview notes or contact your referees. 

If you are a successful candidate, we might also collect your personal data from a background check agency if permitted by the legislation. 

Why do we collect personal data, under which legal basis, and how do we use it? 

As we are a young and growing company, we are in constant need of new, talented individuals who will become part of our global team. 

We rely on your consent to collect and process your personal data. We use your personal data for recruitment purposes, e.g. in order to let you know of new open positions or internships and check if you are interested, and if you are, to conduct the selection process and assess your suitability. 

If you do not submit your resume directly into our recruitment software (e.g. when we receive it from a recruitment agency or when we find your professional details on business networking sites you use), we will send you an email with a link to our recruitment software and you will be asked to provide us your consent to keep your personal data for recruitment purposes. In such cases, we collect your personal data and contact you with an email based on our legitimate interest, in order to find potential job candidates. However, we need your consent for any further processing of your personal data. If you do not provide us with the consent within thirty days following the receipt of the email, we will erase your personal data from our database. 

During the selection process we collect further information in order to review your professional qualifications and interests and be able to choose the best candidate. We also conduct the relevant background checks, to the extent permitted by applicable laws, which include identity verification, right of work verification, education, professional license and previous employment checks, verification of recommendations, checks of company registers and criminal checks. Moreover, for executive roles we will also carry out a reputational check from publicly available sources. For the processing of this information, we rely on our legitimate interest, your consent, or legal obligation depending on the circumstances. 

If you have been selected as the most suitable candidate for a job position or internship, you will be presented with an offer. If you accept it, we will collect further information so as to be able to conclude and execute an agreement with you. The further collection and processing of your personal data will be carried out to conclude an employment or internship agreement with you or in order to take certain steps, at your request, prior to entering into that agreement. You will be presented with an Javna privacy policy that applies to our staff where you can find relevant privacy information. 

We may share your personal data within Javna (subsidiaries and affiliates). Since we are a global company, we may engage our subsidiaries and affiliates in which we have employed members of our recruitment team in order to complete the recruitment process. 

How long do we keep your personal data? 

Your recruitment-related personal data will be deleted after the expiration of the period for which you have provided us with your consent (or earlier if you withdraw it). These periods might differ across countries due to local legislation.   

If legal matters such as litigation, law enforcement requests or government investigations require us to preserve records, including those containing personal information, for longer periods than you have consented to, then we will delete the records in question when we are no longer legally obligated to retain them. 

  1. HOW AND WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

We may engage processors to facilitate us in the processing of your personal data through CRM (Customer Relationship Management), marketing, recruitment and other tools necessary for conduct our business activities or to assist us in providing you with our Services. 

Before engaging a new processor, we perform security & privacy assessment of the processor, and we ensure that the processing of personal data is always regulated with written data processing agreements.  

We may share your personal data within JAVNA Group companies (subsidiaries and affiliates). Since we are a global company, we may share your personal data with our subsidiaries and affiliates to complete internal procedures within our offices, to perform certain processing activities on a global scale or to support you in the use of our products and services. JAVNA subsidiaries and affiliates can be engaged as processors or in certain situations can act as joint controllers. 

All JAVNA subsidiaries and affiliates will only use the personal data as described in this Privacy Policy. All intercompany processing of personal data is regulated by the JAVNA intercompany agreements on personal data processing and transfer and where applicable with standard contractual clauses of all relevant jurisdictions. 

Notwithstanding the foregoing, as a rule, we do not share personal data with third parties except when necessary, such as: 

    • With telecom operators and other communications service providers when necessary for the set-up of proper routing and connectivity. We are able to deliver messages that our customers send to their end users, independent of where they are located, through our connections with telecoms and other communications providers operating all over the world, especially OTT ones such as Whatsapp, Facebook. 
    • With third-party service and technology providers, to the extent strictly necessary for them to perform specific actions on our behalf. We may share personal information with our trusted and verified third-party service providers, for example, in order to enable them to process payments for us or to prevent fraud. 
    • Due to relevant legislation. If we are presented with the legal obligation, we will share the data with third parties that are legally entitled and authorized to request it, such as for criminal procedures or because of threats to public security. As a communications provider, we are required to retain certain communications-related data for law enforcement purposes and will be required to share that data with authorized law enforcement authorities upon their request. Also, if we are under an obligation to demonstrate compliance with relevant accounting, financial and tax legislation, your data can be shared with auditors and tax authorities for those purposes. 
    • Targeted Advertising. We do not and will not sell, rent, or share in any other shape or form any information to a third party for advertising or similar marketing purposes. We do, however, use direct marketing through Google Adwords for our own purposes. 
    • APIs/SDKs. We may use third-party Application Program Interfaces (“APIs”) and software development kits (“SDKs”) as part of the functionality of our Services.  
    • Disclosure in the event of merger, sale, or other asset transfer. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be transferred as part of such a transaction, as permitted by law and/or contract. 

 

  1. HOW DO WE CARRY OUT INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA?

We conduct our business operations globally, and sometimes we need to carry out international transfers of your personal data by providing your personal data to the parties specified in the section above. All international transfers are carried out ensuring the confidentiality and security of your personal data. 

In addition, the international transfers of your personal data are subject to contractual restrictions in accordance with this privacy policy, including, where necessary, the implementation of contractual mechanisms such as standard contractual clauses for data transfers. 

 

  1. HOW DO WE SECURE YOUR PERSONAL DATA?

JAVNA values your privacy. In order to protect personal data collected and processed by JAVNA we have invested in development, implementation, and constant improvement of a wide range of technical and organizational measures.  

We take care to train all our staff in the field of privacy and security, starting from their first day in JAVNA through the onboarding process and continuously throughout their stay at JAVNA. 

Before we engage any third-party vendor and service provider, we check their security practices and alignment with this privacy policy. 

 

  1. DO WE CONDUCT AUTOMATED DECISION-MAKING, INCLUDING PROFILING, THAT SIGNIFICANTLY AFFECTS YOU?

No. We do not conduct any operation under which you would be subject to a decision based solely on automated processing that has legal or similarly significant effects for you, including profiling. 

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