Privacy Policy

 PURPOSE 

The purpose of this Privacy Policy is to inform you about how your personal data is collected, processed, and secured by Keli Network Inc. d/b/a Jellysmack (hereinafter “Jellysmack,” “we,” “our,” and “us”) whose registered office is located at: 450 Park Ave South, 3rd Floor, New York, NY, 10016, USA. The present Privacy Policy extends to the affiliates of Jellysmack, including parent companies as well as any company controlled by Jellysmack that will be created or acquired.

This privacy policy covers: 

Jellysmack tools and services are directed to individual creators and digital professionals. By using our services and tools, you are accepting the policies and practices described in this Privacy Policy.

PURPOSE OF DATA PROCESSINGS 

  • Select our partners based on their business performance or expertise
  • Collect, re-edit, optimize, test, check, and publish content both for Owned and Operated
  • (ONO) Jellysmack creators and partners
  • Measure the performance of the content published
  • Define and use custom segments of the audiences managed by the platforms (Facebook,
  • Instagram, YouTube, TikTok, Snapchat, etc.) for targeted advertising
  • Community management including banning requests on the pages we manage both for
  • ONO Jellysmack creators and partners
  • Provide Users of our services with support when they write directly on our contact forms
  • on our Websites or via email
  • Execute service agreements related to the use of our services, tools, related offerings,
  • and associated payments
  • Brand safety and fraud prevention and detection
  • Improve our services and tools and measure usage

TYPE OF DATA COLLECTED 

Usage Data

We collect Usage Data relating to the use of our Website, traffic logs, user conduct, or the results of Site usage, or Jellysmack services for creators and content providers. Usage Data does not identify you via your IP address or device identifiers.

Contact information

If you provide contact information directly to Jellysmack through the completion of our contact data forms on our Sites (where you provide us with personal identifiers such as name, email, and phone number), we will only use this Personal Data to respond to your request and will only process it based on your consent, to execute the service agreement or if we have a legitimate legal interest.

We can also collect your contact information from publicly available sources such as your social network pages in order to contact you and offer to work together.

Aggregated Data from the platforms

We collect aggregated Usage Data from the platforms associated with the pages and content for both ONO Jellysmack creators and partners. The aggregated data is used to track content and page performance as well as to create metrics and custom segments of the audiences managed by the platforms (Facebook, Instagram, YouTube, TikTok, Snapchat etc.):

  • We receive aggregated statistical information about the performance of the posts and promoted content, such as numbers of views and types of viewers from the Social Media Platforms. This data is aggregated and anonymized by the Social Media Platforms before it is made available to us.
  • We also use the paid advertising and paid content tools provided by the Social Media Platforms to help us carry out advertising campaigns for our Ad partners and to promote the content on the Social Media Platforms. With your consent, the Social Media Channels display advertisements to you via targeted advertising methods and tailored to your individual interest. As a reminder, we only receive aggregated statistical information about interactions with our ads and paid content (such as number of views, number of times shared, etc.) from the Social Media Platforms. We process information provided to us by the Social Media Platforms on the basis of our legitimate interest in interacting with our audience on social media and using social media to promote our content.

The products of Aggregated Data are anonymized, and no Personal Data identifying you or any Data Subject is used.

We do not have access to the list of Data Subjects included in the audiences provided by the platforms Aggregated Data from Jellysmack sites and pages.

We collect and aggregate Usage Data that contains Personal Data via our Corporate Social Media Channels and Pages from your comments on our Social Media Channels and Pages solely in order to create metrics and statistical audience segments (“Aggregated Data”). Aggregated Data consists of information that is aggregated, or combined, with information of other Data Subjects (identifiable physical persons, who potentially may be identified, directly or indirectly, by identifiers such as name, online profile, IP number, etc.).

We recommend that you also review the Privacy Policies and your personal privacy settings for the social media platforms (such as Facebook, Instagram, YouTube Snapchat, TikTok, etc.) where our Channels and Pages appear (the “Social Media Platforms”) and where your comments are posted and shared, to ensure that those Privacy Policies and your personal privacy settings accurately reflect your consent for the use of any Personal Data.

Special Category Data 

From time to time, we may perform a targeted audience survey (“Audience Survey”) on our Social Media Channels for our United States audience only in order to collect statistical data. Such an Audience Survey may include demographic Personal Data (such as information about age, gender, ethnic origin, marital status or household income) (“Special Category Data”). We will not collect Special Category Data in any Audience Survey without your consent. If we collect Special Category Data, we will not share it with or sell it to any Third Party for business or any other reasons.

Google Analytics Cookies 

We are using Google Analytics to collect and process Usage Data on our Site and improve the performance of our Services. On our behalf, Google will use this information to evaluate your use of the Site, to compile reports on Site activity, and to provide us with other services relating to the Site and internet use. The IP address transmitted by your browser in the context of Google Analytics is not merged with other Google data.

To learn more about Google Analytics and how to opt out, please visit https://policies.google.com/technologies/partner-sites. You may be able to change browser settings to block and delete Cookies when you access the Services through a web browser. However, if you do that, the Services may not work properly.

THIRD-PARTY 

Third party used 

We collect and share your data with Jellysmack partners who are contributing to deliver the service. The third parties are the following:

  • Social network platforms such as Facebook, Instagram, YouTube, Snapchat, TikTok, etc.) for content collection, delivery and as audience providers
  • Hosting service: AWS
  • For operating the services:
    • Tools: Pipedrive, Deels, Bodyguard, Monday, Slack, FreshService, Jira, Looker, Dropbox, Adobe, AudioNetwork, Crowdtangle, Figma, Frame, Getty Images, Iconosquare, Rev, and Tubular
    • Contractors for content editing, testing, and checking

Purpose of third party transfer 

We process personal data within Jellysmack own legal entities but can also use external tools and third parties in order to operate our business and provide you the best Services, and in accordance with applicable data protection laws. Any Personal Data provided to Jellysmack will not under any circumstances be sold to any third parties. Your Personal Data can be shared with third parties in the following situations:

  • For l business operations reasons. Your information and Personal Data may, if necessary, be transmitted to third-party subcontractors involved in the provision of our Services, such as technical and hosting service providers, content editors, customer follow-up and satisfaction surveys (such as Nielsen proprietary measurement software), and data security incident management. Jellysmack will only communicate your information and Personal Data to authorized and trusted service providers, who process them on our behalf, according to our instructions, and in compliance with this Privacy Policy and any other applicable data security and data privacy laws and regulations.
  • For legal and statutory reasons. Your information and Personal Data may be disclosed to a third party if Jellysmack is required to do so by law, regulation, or court order, or if such disclosure is compelled or necessary for the purposes of an investigation, injunction or judicial proceeding, within or outside the United States.
  • Merger and company sale. In the event of any merger, company sale or other company asset transfers, or acquisition of all or a portion of Jellysmack by another third-party Company, your information may be disclosed in connection with the negotiations of such transaction, solely as permitted by law and/or contract.

Third Party Site 

Our Site may also include links to external Third-Party websites and Social Media Platforms (“Third-Party Sites”). These sites have their own privacy policy and by clicking on those links, your data will be processed according to these.

Jellysmack is not responsible for Third-Party Sites, which may collect information about you through the use of their own Cookies and other informatic tools (Third-Party Widgets, Web Beacons, etc.). We advise you to read their Privacy Policies carefully to check that your Personal Data is well protected. Jellysmack will not be responsible for any liability or damages resulting from your use of any Third-Party Sites.

DATA LOCATION 

Jellysmack is an international group with its offices across the globe, including Europe, United States, LATAM, and Asia. To this end, the services and tools can be performed worldwide. However, Jellysmack ensures compliance with relevant regulation and takes appropriate measures to keep your personal data protected, especially, to comply with GDPR requirements regarding lawful transfer mechanisms.

Personal Data related to Jellysmack services and tools is hosted in the United States, in Oregon, for the services of Amazon as a third-party hosting partner for data storage. We can also use third party solutions and tools (SaaS) that can be hosted in various countries.

By using the Services, you authorize Jellysmack to transfer, store, and use your information in the United States and where we operate.

In the event your data is transferred to any contracted third-party data processors, it will be subject to at least the same level of data protection as provided by Jellysmack itself, as detailed in this Privacy Policy.

SAFETY MEASURES 

We secure any Personal Data collected and shared, and have taken all precautions and technical and physical safeguards necessary to comply with this Privacy Policy and any other applicable data security and data privacy laws and regulations such as GDPR and CCPA. We have also taken all precautions and implemented safeguards necessary to preserve the security and confidentiality of Personal Data by our third parties, and in particular to prevent any Personal Data from being lost, distorted, damaged, or disclosed to unauthorized persons. We limit access to your Personal Data only to employees or technical service providers who reasonably need to come into contact with that Personal Data to provide Services to you or Jellysmack.

Jellysmack also uses encryption (HTTPS/TLS) to protect data transmitted to and from our Sites and tools. However, no data transmission over the Internet is fully secure, so Jellysmack cannot guarantee the total and complete security of Personal Data transmitted in this way.

RETENTION PERIOD 

Personal Data is retained for a period of time depending on the purposes of processing your Personal Data and Jellysmack will securely destroy your Personal Data once there is no longer a need to keep it, in accordance with applicable laws and regulations.

CHILDREN’S PRIVACY 

Jellysmack is highly sensitive to the privacy of children. Therefore, Jellysmack will not collect Personal Data from children, except those displayed in the content from our creators. If Jellysmack or its employees become aware that Personal Data from a child has been collected or received, we will promptly delete all such Personal Data collected or provided to us.

DATA SUBJECT RIGHTS 

EU and UK data subjects 

You can exercise the following rights by contacting Jellysmack at this email: privacy@jellysmack.com 

  • The right to be informed 
  • The right of access 
  • The right to rectification 
  • The right to erasure 
  • The right to restrict processing 
  • The right to object 

Before processing the request, Jellysmack should ensure the identity of the person making the request to avoid sharing data with an unauthorized person and might request additional information from you.

As a European or United Kingdom Citizen, you dispose of the right to file a complaint with a European Union supervisory authority, (or the Information Commissioner’s Office (ICO) if you are a resident of the United Kingdom), in the event you have reasonable doubt that we are not processing your Personal Data in compliance with applicable law and GDPR, or UK-GDPR.

In such a case, we are asking you to contact us first by sending an email at privacy@jellysmack.com and we will make our best efforts to reply promptly.

California residents 

You are entitled to the following specific rights under the CCPA in relation to personal information related to you:

  • You have a right to request that we will disclose certain information to you about our collection and use of personal information related to you over the past 12 months, including:
    • (i) The categories of personal information that we collect about you
    • (ii)The categories of sources from which the personal information is collected
    • (iii) The purposes for collecting, using, or selling that personal information
    • (iv) The categories of personal information that we disclosed for a business purpose or sold, and the categories of third-parties to whom we disclosed or sold that particular category of personal information
    • (v) The specific pieces of personal information that we have collected about you
  • You have a right to request that we delete personal information related to you that we collected from you under certain circumstances and exceptions.
  • You have a right not to be discriminated against for exercising your rights under the CCPA.

To make such requests, contact Jellysmack at this email: privacy@jellysmack.com 

Before processing the request, Jellysmack should ensure the identity of the person making the request to avoid sharing data with an unauthorized person and might request additional information from you.

You also have a right to submit your request via an authorized agent. If you use an authorized agent to submit a request to access or delete your personal information on your behalf, the authorized agent must: (1) be a person or business entity registered with the California Secretary of State to conduct business in California; (2) provide proof of such registration; and (3) provide documentation or other proof indicating that they are authorized to act on your behalf. We may also require you to verify your identity directly with us, and directly confirm with us that you provided the authorized agent permission to submit the request.

CONTACT INFORMATION 

Jellysmack can be reached for requests related to personal data by: 

  • Sending us a letter at: Jellysmack, 450 Park Ave South, 3rd Floor, New York, NY, 10016, USA.
  • Emailing us at: privacy@jellysmack.com.
  • Using the contact form available on our website (Jellysmack’s website accessible at the URL: www.jellysmack.com, hereinafter the “Site”).

CHANGES TO THIS PRIVACY POLICY 

We’re likely to update this Privacy Policy in the future. When we make changes, we will revise the date at the top of the Privacy Policy and, in some cases, will notify you through our Site such as on our homepage. Please come back and check from time to time for the latest information on our privacy practices.

For the Data Subject we have emails, we would also send an email notification to inform on the policy change.

Last Updated: 24 Jan, 2022