Privacy policy

The purpose of this Privacy Policy is to inform you about how Jonna uses your personal data. We recommend you should read it carefully.

1.Definitions

Application: The Jonna application, available on the Apple App Store and the Google Play Store.

Account：The Member’s dedicated personal area within the Application, which he or she accesses when he or she registers and connects to the Application. It enables the Member to access the Services. A Member may only have one Account.

Geographical position：your location, recorded by Jonna and updated regularly when this option is enabled.

Chat：a function that sends a notification to the Member to whom you address it, and which also enables you to send him or her a private, personalized message to start a private conversation.

Member: A person registered with the Application.

Sharing experiences：Sharing your experiences, both work-related and personal, can lead to receiving help and answers in your professional life. By sharing your own firsthand experiences, you can gain resonance with more people and expand your network.

Profile Photos: photos on your profile enabling the easy identification of the Member. The Member accepts to, at the very least, provide a photo of his or her face in which he or she is clearly recognizable, and place it in first position. These two criteria combined are an essential condition for using the Services.

Jonna is extremely concerned about the protection of your personal data and respect for your privacy. The purpose of this privacy policy is to inform you on the way we process the personal data you share with us and that we collect when you use the Application and Services. Please read this document carefully to better understand how we process your personal data, and to know your rights.

This Privacy Policy applies to all Services published by Jonna that you use (with the exception of services supplied and operated by third parties, in which case, their privacy policy will apply).

Jonna collects and processes personal data on you when you use the Jonna application or when you communicate with Jonna. It may be information you share with us directly, or data we collect automatically.

To make sure our privacy policy is clear, we are providing below an overview of the personal data Jonna collects and processes. Information is given below for each type of data collected.

When you use our Services, you share information with us, some of which may be used to identify you. When you communicate this information, you accept that some of the data will be visible to the other Members of the Application, and therefore made public on the Application. In an effort to help you identify this information easily, it is signaled as‘public’below. Jonna cannot be held liable for data published on its platform and disclosed by a Member. However, information not marked as Public will not be visible or accessible by other Members; such information is signaled as ‘private’ below.

Jonna collects and processes data relating to your registration and data relating to your interactions with Jonna.

This data is collected by Jonna using different methods depending on the type of registration you choose.

If you choose to register using your Apple or Google account, your data will be collected from the relevant platform in an effort to reduce formalism. By selecting “Log in with Apple/Google,” you agree to having these platforms provide us with such data.

Depending on how you registered, some data must be collected in order to provide our Services. If such data is not obtained, Jonna will not be able to provide you with its Services via the Application, and you will not be able to create an Account. In all cases, your first name (public), age (public), birthdate (private), gender, and at least one Profile Photo (public) are required to register with the Application. Subsequently, you may add or remove Profile Photos at any time, providing you have added at least one Profile Photo containing a person’s face. As stated in paragraph 1, “Definitions,” the first Profile Photo should be a photo of a person’s face, otherwise one of your photos of your face will automatically be put in first position.

When you register via Apple or Google, we must collect your first name and email address. Said platforms may also provide Jonna with your last name.

You may add additional information to improve your profile. This information is optional, shared at your own discretion, and is your sole responsibility.

interests and habits (public): personal preferences, leisure activities, musical preferences, lifestyle, Member Characteristics;

profile description (public): if you would like to, you can share additional information about you in the space provided for this purpose.

Your description is a free text area, Jonna does not encourage Members to share data that can be perceived as sensitive with other Members, or with Jonna through the Application. Sensitive data refers to data that is legally qualified as “sensitive” by the General Data Protection Regulation (“GDPR”). More specifically, it includes information on race or ethnicity, political opinions, religious or philosophical beliefs or affiliation with a union, along with information on health, sexual life or sexual preferences (“Sensitive Data”). If a Member decides to share such information on his/her profile regardless, it is deemed to have been “clearly made public” by the Member who shared it, according to the GDPR.

When you contact our customer or support services, report an issue with our services, ask for help, exercise your personal data rights, or participate in promotional activities, games, competitions or surveys, when you share your experience of our services, give testimonies, or answer one of our questionnaires, Jonna will collect, depending on the case, the following personal data:

Data relating to reports and requests sent to the Jonna customer service (private): Date and time of the report, nature and reason for the report, data relating to the reported user. Furthermore, proof of identity may be requested as part of the exercise of your rights over your personal data, and for safety/confidentiality reasons.

This data will be collected by Jonna when you ask for help from our customer service, exercise your rights over your personal data, report a problem or another user. Such information is required to handle reports or answer your requests. This information will also be handled if a report is made about you. In fact, Jonna has a legal obligation to collect reports from its Members brought to its knowledge regarding contents or behavior likely to infringe our Terms of Service.

Such data is collected by Jonna when you take part in our games and competitions, answer our surveys and satisfaction questionnaires, share your experiences. This data is mandatory if you wish to take part in the games and competitions organized by Jonna. Without this data, Jonna may not register you for games or competitions. However, data on your experiences and satisfaction is optional.

When you use our services and features, we collect information on your activities on the Application:

Activity data (private) (registration date, login dates, on or offline status, interactions with Members and third-party accounts, number of transactions, notifications received, notification preferences, etc.)

When you access our Services and use the Application and its features, information on the way you use them is collected and processed. Most of the information collected by Jonna is necessary to the provision of its Services. Without this data Jonna cannot supply the Services linked to the Jonna application.

More specifically, this includes your registration date, login dates, on or offline status, the type and number of interactions with other Members with the third-party accounts connected to your Account (such as Spotify, Instagram), or the number of transactions made (subscriptions), notifications received and notification preferences.

The Application’s main value and purpose is to allow Members to find other Members they have or may have crossed paths. Your Geographical position is collected with your express consent only. In fact, you will be asked to authorize the collection and processing of your location data to allow Jonna to identify your crossing points with other Members who have agreed to be geolocated.

Unless you have chosen stricter settings on your device, Jonna will collect your Geographical position regularly.

When the Geographical positions of two Members are within a certain radius, Jonna pinpoints a Crossing point.

Your Crossing points will be displayed on your profile, but Members with whom you cross paths can never see your exact location. Each Member sees his/her location when the Crossing point was registered in a radius defined by Jonna. They cannot see the other Member’s location.

You may, at any time, withdraw your consent by disabling geolocation on your smartphone. If you choose to do so, your news feed will no longer be updated, and you will not be able to see who you have crossed paths with after disabling the geolocation option.

Messages are sent and stored on Jonna’s servers. Messages and voice messages are strictly private and only implicate the Members involved. Jonna’s authorized managers do not exercise any rights to view these conversations. These Messages are not transmitted or communicated to third parties except in cases of judicial requests, and/or in compliance with the applicable legislative or regulatory provisions. Moreover, Messages are strictly private and are not accessible to other Members who are not involved in the conversation, nor to any third party.

Search preferences - people whom you would like to cross paths with (age and gender) (private)

The Application lets you set preferences by age, gender, and the Member Characteristics they have provided. You can change these settings in the Application and specify the age range and Member Characteristics, and, after agreeing to Jonna collecting and processing your data, the gender of people you are looking for, so you can be matched exclusively with profiles you crossed paths with and who meet your search criteria. You will then only see the Members you have crossed paths with and who share your search preferences on your news feed.

Technical data of the cell phone or device (IP, mobile ID, application version, telephone version and model advertisement ID, etc.) (private)

We collect information from the devices and equipment you use to access our Services, including server logs, which may contain information such as IP addresses, version of the application, device version and model, language used, operating system, application crashes, and advertisement ID.

Transaction Data: Jonna does not collect or process any banking data. Apple’s App Store and Google’s Play Store have opted to refrain from sending certain types data to mobile applications, which includes any banking and financial information. This data is collected and processed solely by the above platforms, and Jonna does not have the option of changing this payment method. The only information exchanged between Jonna and Apple’s App Store or Google’s Play Store is technical data that does not allow us to identify you (for example, a transaction number), and is used to validate transactions. Jonna will therefore retain a history of your purchases and subscriptions but will not store any information relating to the payment methods you use.

Sending information messages relating to the Services or your interactions with other Members (notifications).

The data collected by Jonna is required to make sure the Application is running smoothly and to supply the Services, which it is contractually obliged to provide to Members under the service contract biding the two parties (Terms of Service).

Improvement and optimization of the services of Jonna, of the knowledge of its Members and the manner of using the Services:

This processing activity is based on Jonna’s legitimate interest in improving and optimizing its services, knowing its users and how its services are used.

Provide Members with advice on which Profile Photos to publish by analyzing all Members’ profiles, so Members can, if they wish to do so, optimize the way their profile is presented.

This processing activity is based on Jonna’s legitimate interest in improving the way profiles are presented in the Application. You may oppose this use at any time by contacting us.

Detecting or preventing breaches of the security of the Services by identifying and analyzing fraudulent behavior.

This processing is based on Jonna’s legitimate interest in guaranteeing the security of its application and the data it processes. You can object to this use at any time by contacting us . However, Jonna may continue to implement the processing if it justifies legitimate and compelling reasons.

4.4. Preventing and combating illegal or unauthorized activities (breaches of the terms of service), ensuring the trust of Members and complying with legal requirements

Managing undesirable behavior and warning, suspending, blocking or deleting the Member’s Account.

These processes are based on Jonna’s legal obligation, as a data host, to remove illegal content as soon as it becomes aware of it (Article 6 of the French Trust in the Digital Economy Act [Loi pour la Confiance dans l’Économie Numérique) of 21 June 2004]) and on its obligation to respond to requests to exercise Members’ rights over their personal data (Articles 12 to 22 of GDPR).

Detecting or preventing fraudulent activities or activities which breach our Terms of Service:

Automated analysis of profile data, application activity to detect fake profiles, fraudulent behavior or behavior that breaches the Terms of Service.

Automated analysis of Members’ Profile Photos in order to detect faces, and, as much as possible, exclude fake profiles from the Application, combat fraudulent behavior and guarantee Member identification. You will not be able to create an account if your face cannot be detected in one of your Profile Photos upon registering. If you are prevented from registering even though your Profile Photo does show your face, you may contact us at any time.

This processing is based on Jonna’s legitimate interest in preventing and stopping fraudulent activities that may be carried out on its Services or breach its Terms of Service, and in protecting users’ safety though profile identification. You can object to this use at any time by contacting us . However, Jonna may continue to implement the processing if it justifies legitimate and compelling reasons.

To reinforce the security of Members on the Application by automatically excluding the profiles of Members whose previous account had previously been suspended following fraudulent behaviour or behaviour that contravened our General Terms and Conditions of Use.

This processing allows us to provide you with the Services while preserving your peace of mind and security on the Application in accordance with our General Terms and Conditions of Use and to ensure compliance therewith.

Profile certification (as defined in paragraph 1): in order to certify the profile of a member, Jonna must, having obtained the Member’s consent, collect the his or her biometric data using a photo of his or her face, and compare this data with the Member’s Profile Photos. If the faces correspond, a “Certified Profile” badge will be granted. The biometric data are immediately deleted after the comparison. However, the video will be stored in order to reverify the Member’s profile should he or she add or delete other photos. In this case, the biometric data will be collected once again from the same video, then deleted again after comparison with the Member’s new photos.

Your consent for the use of your biometric data for Profile certification is requested when you start the certification process. You can withdraw this consent at any time by clicking on “My Data” then “Manage My Choices.” If you withdraw your consent, your video will be deleted and your biometric data will no longer be able to be collected. If you add new Profile Photos or delete your current Profile Photos, you may lose your “Certified Profile” badge as the comparison with your face will no longer be possible.

In compliance with the French Data Protection Act of January 6th, 1978 (Loi Informatique et Libertés, 78-17), and the GDPR, every Member has a right to access, rectify, and a right to data portability and removal of his/her personal data, along with a right to object to or limit processing of his/her personal data, and the right to decide on the way to handle the personal data after his/her death. In an effort to address its Members’ concerns, Jonna commits to respecting the protection of personal data and to process requests as soon as possible.

You can use the 'Contact Us' feature to send messages online, if there is a doubt on the requesting party’s identity, proof of identity may be requested.

For any other claim, the Member may lodge a request with the national authority responsible for data protection.

The right to access allows a Member to ask Jonna for data pertaining to him/her in an accessible format, based on the terms and conditions of Article 15 of the GDPR. Your right of access must not infringe on the privacy of third parties, which is why you will only have access to your personal data and not that of third parties (for example, only messages that you have sent will be communicated to you and not those that you have received).

The right to correct grants a Member the right to demand Jonna corrects, adds to, updates or removes any personal data on him/her that is inaccurate, incomplete, ambiguous, out-of-date, or whose use, communication or storage is prohibited based on the terms and conditions of Article 16 of the GDPR. You can modify or rectify some data directly on the Application. You just need to go on your profile and make changes directly in the sections “My photos”, “Work and Education (Job, Employer, School)”, and “About me”. When you have registered via Facebook Connect, to change your first name, age, or gender, go to your Facebook page and update the “About me – contact and basic info” section of your profile. When you have registered via a cell phone number, you must send a letter or contact customer support at the addresses listed above, to change your first name, age or gender. In case of error, your age can be rectified once, directly on the Application.

The right to data portability grants a Member the right to receive the personal data he/she gave to Jonna, in a structured, commonly used format, legible on a machine, and to forward them to another processing entity, in compliance with Article 20 of the GDPR.

The right to contest grants a Member the right to object, free of charge and at his/her own discretion, to the use of his/her data by Jonna for canvassing, especially commercial canvassing, and to the processing based on Jonna’s legitimate interest, in compliance with Article 38 of the French Data Protection Act and Article 21 of the GDPR. For processing based on legitimate interest, Jonna retains the option to justify legitimate and compelling reasons to continue processing.

The right to delete grants a Member the right to demand the removal, free of charge and at his/her own discretion, of data transmitted to Jonna, within the limits of the rights based on Article 17 of the GDPR. Also, you can delete your Account using the corresponding feature on the Application. We inform you that all your data will be deleted from the Jonna application. However, Jonna, as the host, has a legal obligation to retain your personal data for one year under Article 6-II) of the French Trust in the Digital Economy Act no. 2004-575 of 21 June 2004. Your data will be kept in an archive database kept separate from our production databases and only for the purpose of responding to a court order. Data will be permanently deleted after one year.

The right to limitation grants Members the right to request the temporary suspension of the processing of their data by Jonna under the conditions set out in Article 18 of GDPR.

The right for the Member to set the guidelines for the retention, deletion and communication of his/her personal data after his/her death, in compliance with Article 85 of the French Data Protection Act.

These rights may only be exercised within the limits of Jonna’s resources as it relates to its use of Google and Apple to log into the Application. Some data sent to Jonna by Google or Apple cannot be corrected without Google or Apple’s cooperation.

Jonna shall not collect data from minors. Should a Member lie about his/her date of birth, and particularly if he/she fraudulently claims to be an adult, the parents of the minor in question should inform Jonna of this fact by sending an e-mail to one of the contacts mentioned in Article 11 “Contact”, requesting the data to be deleted. Jonna commits to deleting all data on the minor in question as soon as possible.

If you have any questions regarding this privacy policy, or any other request concerning your personal data, you can contact Dating with friends company Limited by: