Privacy Policy

Your privacy is our top priority

Version 1 (Dec 31 2024)

This document outlines how Jenny Forms, and affiliates (hereon referred to as “Jenny”), handles your data, be it personal or other information. As far as possible, we’ve used plain English to explain how we respect your privacy and why you should trust us with your data.

This Privacy Policy applies to all products, services and websites provided by Jenny (collectively referred to as the “Jenny Service”), except where otherwise noted. If any services have supplementary privacy statements, we’ll explain in more detail our specific privacy practices in relation to these services.

The Jenny Service is provided to two distinct groups. Firstly, our Service provides a platform and set of tools that enables people, companies and organisations (“app creators”) to create data-driven business apps for mobile and desktop devices. These apps are delivered to the second group, who interact with, and submit data through, the provided apps (“app users”). Jenny receives and handles information differently for app creators and app users, so we have split this Privacy Policy into two dedicated sections, one for each group.

SECTION 1: PRIVACY FOR APP CREATORS

Our approach to your data

• Your data is yours. Jenny regards all content that you create within your account on the Jenny Service (forms, data sources, tasks, user accounts, email addresses etc.) as being your private property, owned wholly by you. Jenny does not sell your content or data to anyone, and we only process and make your data available as needed to provide the Jenny Service, with the exception of a limited set of circumstances (e.g. Jenny is compelled by a subpoena, or if you’ve given us permission to do so).
• Your data hosting is based on your specified country at account signup. The Jenny Platform is hosted on Microsoft’s Azure cloud platform in 3 separate regions (“nodes”) across the world – specifically USA, West Europe and Australia. Customers that identify themselves as being located within Europe, Middle East and Africa are hosted within our West Europe (Amsterdam & Dublin) data centers. Similarly North and South American customers are hosted within our USA data centers, while East Asia and Oceania customers are hosted in our Australia East data centers. Once your account is provisioned on one of these nodes, there is no transfer or cross-population of your data to other nodes. So if, for example, your account is created on our West Europe node, then that is the only place your data will ever be hosted by us.
• Jenny is committed to processing and storing your data securely.

Information that Jenny collects

Jenny collects information relating to you and your use of the Jenny Service from a variety of sources which are listed below, along with details of how we use this information.

Information we collect directly from you

• Registration information. You need to create an Jenny account before you can build apps on the Jenny Service. Our account signup collects your name, email address, password, phone number, company name, country and time zone.
• Billing information. If you make a payment to Jenny, we require that you provide your billing details, including name, address, email address and financial information corresponding to your selected method of payment (e.g. a credit card number and expiration date). If you provide a billing address, we will regard that as the location of the account holder. Jenny does not store or log any sensitive cardholder data provided by you or your app users. We use a PCI Level 1 compliant credit card processor which securely stores all card details and processes card payments.
• Account settings. You can set various preferences and personal details within the Jenny Service. For example, your default language, time zone and other meta-data values can be specified within the Edit User and Organisation Setup pages of our backend web portal.
• App data. We store the data you and your app users upload, import and otherwise submit to us.
• Other data you intentionally share. We may store or collect your personal information or data if you explicitly send it to us for specified purposes. For example, if you give us a customer testimonial or participate in an Jenny sponsored marketing event.
• We don’t share, sell or use your app users’ information. Jenny will not contact your app users via email or other means unless you specifically request us to do so. We will not sell or make available your app users’ contact or other information to any third parties, aside from what is necessary to provide the Jenny Service (e.g. emails that you’ve configured are sent through our email delivery provider).

Information we collect indirectly or passively

• Usage data. Like most software services today, Jenny collects usage data about you whenever you interact with our services. This can include which Jenny areas/pages you visit, what you click on, when you performed those actions, and so on. Additionally our servers may keep short-term log files that record data each time a device accesses the Jenny Service. These log files contain data about the nature of each access, including originating IP addresses, internet service providers, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system versions, and timestamps.
• Device data. Jenny collects data from the device you use to access our services, such as your IP address, operating system version, device manufacturer and model, and browser type. We may also infer your geographic location based on your IP address.
• Referral data. If you arrive at an Jenny website from an external source (such as a link on another website or in an email), Jenny records information about the source that referred you to us.
• Information from third parties. Jenny may collect your personal information or data from third parties, if you have given permission to those third parties to share your information.
• Information from page tags. Jenny uses third-party tracking services that employ cookies and page tags to collect aggregated and anonymized data about visitors to our websites. This data includes usage and user statistics. Emails sent by Jenny may include page tags that allow us to collect information about who opened those emails and clicked on links in them. We do this to measure the performance of our email messaging and to learn how to improve email deliverability and open rates.

How Jenny uses collected information

To Jenny, your app data is private and owned by you. Jenny does not use your app data other than as described in this Privacy Policy unless we have your written consent. We do not sell or make available your app data to third parties, beyond what is necessary to provide the Jenny Service, without your permission.

The specific ways that Jenny uses collected information are listed below. See the next part of this Privacy Policy to understand how your information may be shared.

To provide the Jenny Service to you

• Customer support is the most common reason for us accessing your data, since often Jenny will need to view your account, data and app designs in order to provide training, advice and troubleshooting.
• A number of features of the Jenny Service require use of your app data and/or account information in order to function. The hints and documentation about these features will identify when this is the case. If you want to avoid the use of your data in this way, then simply do not use those specific features. For example, our Process Step feature allows you to send data captured in a Form entry onto another user as a Task for them to complete.
• Our various connectors and APIs give you the option to export and import data between the Jenny Service and other external applications. When using connectors, you may be disclosing your data to the individuals or organizations responsible for operating and maintaining such third party applications and sites. Jenny does not own or operate the external services that you choose to connect with, and you should review the privacy policies of such external services to ensure you are comfortable with the ways in which they may use the data you share with them.

To manage the Jenny Service

• To maintain, monitor and enhance the Jenny Service. We perform internal statistical and other analyses on data we collect, including usage data, device data, referral data, app data and information from page tags, to measure user behaviour and trends, to understand how people use the Jenny Service, and to monitor, troubleshoot and improve the Jenny Service, including to prioritise, plan and evaluate new features. Jenny may use your data for internal-only purposes designed to keep our services secure and operational, such as for troubleshooting and testing purposes, and for service improvement, marketing, research and development purposes.
• To enforce our Terms of Use. Occasionally Jenny may need to review data in your account in order to determine whether there is a breach to our contractual terms.
• To prevent potentially illegal activities.
• To screen for and prevent undesirable or abusive activity. For example, Jenny has automated systems that screen content for activities such as phishing, spam, and fraud.
• To create new functionality, services or content. Jenny may internally review your app designs and data for the purpose of creating new features, support content or services. Jenny may look at related statistics such as app usage, form entry counts, and average number of fields per screen in order to publish interesting observations about these for training or marketing purposes. When Jenny does so, neither individual app creators nor app users will be identified or identifiable unless we have obtained their permission.
• To contact you about your service or account. Jenny may occasionally send you communications of a transactional nature (e.g. service-related announcements, billing-related matters, changes to our services or policies, welcome emails when you first register). You are prevented from opting out of this type of communication since it is required to provide our services to you.
• To contact you for marketing purposes. Jenny will send you promotional emails only if you consent to us contacting you for this purpose. You can opt out of these communications at any time by clicking on the “unsubscribe” link in these emails.
• To respond to legal requests and prevent harm. If Jenny receives a subpoena or other legal request, we may need to inspect the data held to determine the appropriate response.

Who Jenny shares your data with

We recognize that you have entrusted Jenny with safeguarding the privacy of your information. Because that trust is extremely important to us, the only time Jenny will disclose or share your personal information or app data with a third party is when Jenny has done one of three things, in accordance with applicable law: (a) given you notice, such as in this Privacy Policy; (b) obtained your express consent, such as through an opt-in checkbox; or (c) anonymised or aggregated the information so that individual persons or other entities cannot reasonably be identified by it. Where required by law, Jenny will obtain your express consent prior to disclosing or sharing any personal information.

We may share:

• Your data with our sub-processors. We use third-party service providers (“sub-processors”) to help us provide you with the Jenny Service. Jenny gives these sub-processors access to your data, but only to the extent necessary for them to perform their services for us. Jenny also implements reasonable contractual and technical protections to ensure that your personal information and data remains confidential, is used only for the provision of their services to us, and is handled in accordance with this Privacy Policy. Examples of sub-processors include payment processors, hosting services, email providers, and analytics tools.
• Your email address with your organization. If the email address under which you’ve registered your account belongs to or is controlled by an organization, Jenny may disclose that email address to that organization to assist the organization with its Jenny account administration. Don’t use a work email address for the Jenny Service unless you are authorized to do so, and are therefore comfortable with this potential disclosure.
• Aggregated or anonymised data with third parties to improve or promote the Jenny Service. We ensure that no person can be reasonably identified or linked to any data we may share with third parties for the improvement or promotion of Jenny services.
• A cookie to advertise Jenny services. Jenny may ask advertising networks and exchanges to display ads promoting our services on other websites. Jenny may ask these networks to deliver those ads based on the presence of a cookie, but in doing so will not share any other personal information with the advertiser. Our advertising network partners may use cookies and page tags or web beacons to collect certain non-personal information about your activities on this and other websites to provide you with targeted advertising based upon your interests.
• Your data if required or permitted by law. Jenny may disclose your information as required or permitted by law, or when Jenny believes that disclosure is necessary to protect our rights, protect your safety or the safety of others, and/or to comply with a judicial proceeding, court order, subpoena, or other legal process served on us.
• Your information if there’s a change in our business ownership or structure. If ownership of all or substantially all of Jenny’s business changes, or if Jenny undertakes a corporate reorganisation, including a merger, acquisition or consolidation or any other action or transfer between Jenny entities, you expressly consent to Jenny transferring your information to the new owner or successor entity so that we can continue providing the Jenny Service. If required, Jenny will notify the applicable data protection agency in each jurisdiction of such a transfer in accordance with the notification procedures under applicable data protection laws.
• Information you explicitly consent to be shared. Jenny may occasionally explicitly ask for your permission to provide your contact details to third parties for various purposes, including to allow those third parties to contact you for marketing purposes. You may later revoke your permission, but if you wish to stop receiving communications from a third party to which we provided your information with your permission, you will need to contact that third party directly.

Your data rights

You can exercise the following rights over the data you store or process on the Jenny Service:

• Update your account details. You can immediately update your account information, and that of your app users, via the provided organisation and user editing pages.
• Access and correct personal information. As an account administrator, you may access and correct certain personal information that Jenny holds about you by visiting the provided user edit page. Some app users and other individuals may have certain legal rights to ascertain if we hold personal information about them, to access personal information we hold about them, and to pursue its correction, update, amendment or deletion in appropriate circumstances. Depending on the information involved, these rights may be exercised through the user or organisation edit pages previously mentioned. For all other cases, requests to exercise these rights may be directed to our support team. These rights are subject to some exceptions, such as where executing the request would have an unreasonable impact on the privacy of other individuals. Jenny will respond to requests to exercise these rights within a reasonable time and, where required by law or where we deem it otherwise appropriate and practicable to do so, we will honour your request.
• Download/backup your app data. Jenny provides functionality to export your app data in a variety of formats. This allows you to create your own backups or conduct offline data analysis.
• Delete your app data. Deleting app data may not permanently delete said data immediately. As long as you maintain an account with Jenny, we may retain your deleted data for a limited time, but no longer than 30 days, to cover cases where you accidentally delete data and need to restore it (which you can request by contacting our support team). To the extent permitted by law, Jenny will permanently delete your data if you request to cancel your account.
• Cancel your account. To cancel and delete your account, please contact our support team. Deleting your account will cause all the data in the account to be permanently deleted from our systems within a reasonable time period, as permitted by law, and will disable your access to the Jenny Service. Jenny will respond to any appropriate request to access, correct, update or delete your personal information within the time period specified by law, if applicable, or without excessive delay. Jenny will promptly fulfil requests to delete personal information unless the request is not technically feasible or such data is required to be retained by law, in which case Jenny will anonymise such data instead.

Jenny’s data retention timeframes

We retain your data for as long as you have an account on the Jenny Service, or to comply with our legal obligations, resolve disputes, or enforce our agreements. Copies of data deleted from our servers may remain on offsite backup media for up to 30 days thereafter. The following specific scenarios and timeframes apply:

• Data you delete within your account. You can delete app designs and data from within your account at any time. App data that you delete from your account will be rendered inaccessible but may not be immediately deleted, applicable laws permitting. We may retain your data for up to 30 days to allow restoration of data when deleted accidentally. Jenny generally does not use deleted form data for any purpose other than to give you the opportunity to restore it. Sometimes Jenny may retain deleted data to comply with legal obligations, resolve disputes, or enforce our agreements. In these cases, Jenny ensures that access to such data is blocked except for the purposes for which Jenny has been required to retain the information.
• Deletion of your Jenny Service account. You can request our support team to delete your account and all associated data at any time. After you initiate the deletion of your account, the account is disabled immediately, but the account and associated data may be held in our database for up to 30 days, until our next regularly scheduled deletion cycle, at which point it will be permanently deleted. You can contact our support team within that time frame to request the account be restored. After your account is permanently deleted, Jenny won’t be able to restore it or the associated data.
• App user account deleted by an account administrator. Your nominated administrator users can delete app user accounts at any time. This disables the target user account immediately, but the user and associated data may be retained by Jenny for up to 30 days prior to being deleted. Depending on when you request it, restoration of the user account may be possible by our support team.

Security and other important information

• Changes to this Privacy Policy. Jenny may modify this Privacy Policy at any time. Jenny will notify you by publishing the changes on this website. If Jenny determines the changes are material, you will be provided with additional, prominent notice as is appropriate under the circumstances, such as via email or in another conspicuous manner reasonably designed to notify you. If, after being informed of these changes, you do not cancel your subscription and continue to use Jenny services beyond the advance-notice period, you will be considered as having expressly consented to the changes in the Privacy Policy. If you disagree with the terms of this Privacy Policy or any updated Privacy Policy, you may close your account at any time.
• Security. Jenny takes security seriously and we’re committed to processing your personal information and data with respect and integrity. However, regardless of the protections and precautions undertaken, there is always a risk that your personal information may be viewed and used by unauthorized third parties as a result of collecting and transmitting your data through the Internet. If you have any questions about the security of your personal information, contact our support team.
• Data locations. We use Microsoft’s Azure cloud platform to host customer accounts in 3 separate regions (“nodes”) across the world – specifically USA, West Europe and Australia. Depending on your indicated country at account creation, your account will be provisioned and run exclusively within one of these nodes. For example, European country accounts are hosted only within our West Europe data centers. Your personal information may also be accessed from countries in which Jenny personnel or affiliates are located (generally for support and maintenance purposes), and may be processed in countries where our sub-processors’ services are located.
• Cookie Notification. Jenny and our partners use cookies and similar technologies on our websites. Cookies are small bits of data we store on the device you use to access our services so Jenny can recognize repeat users. Each cookie expires after a certain period of time, depending on what we use it for. Jenny uses cookies and similar technologies for several reasons:
  • For security reasons. We store your login details in an encrypted cookie to authenticate your identity and to keep you logged into the Jenny Service between usage sessions.
  • To provide you with personalized content. Jenny may store user preferences, such as your default language, in cookies to personalize the content you see.
  • To improve our services. Jenny uses cookies to measure your usage of our websites and track referral data, as well as to occasionally display different versions of content to you. This information helps Jenny develop and improve our services and optimize the content Jenny displays to users.
  • To advertise to you. Jenny, or our service providers and other third parties we work with, may place cookies when you visit our marketing website or when you open emails that are sent to you, in order to provide you with more tailored marketing content (about our services or other services), and to evaluate whether this content is useful or effective. For instance, Jenny may evaluate which advertisements are clicked on most often, and whether those clicks lead users to make better use of our tools, features and services. If you don’t want to receive advertisements that are tailored to you based on your anonymous online activity, you may “opt out” of many of the companies that are involved in such tailoring by going to http://optout.aboutads.info. Opting out in this way does not mean you will not receive any advertisements; it just means that you will not receive advertisements from such companies that have been tailored to you based on your activities and inferred preferences.
  • Google Analytics. In addition to the above, Jenny has implemented on our websites and other services certain Google Analytics features that support Display Advertising, including re-targeting. Visitors to our websites may opt out of certain types of Google Analytics tracking, customize the Google Display Network ads by using the Google Ad Preferences Manager and learn more about how Google serves advertisements by viewing its Customer Ads Help Center. If you do not wish to participate in Google Analytics, you may also download the Google Analytics opt-out browser add-on.
  • We don’t believe that cookies are bad, but you can still choose to remove or disable cookies via your browser. Note that if you choose to disable cookies received from our web backend, you will not be able to log in there, since we require cookies to be enabled for the security reasons above. By using our websites and agreeing to this Privacy Policy, you expressly consent to the use of cookies as described in this policy.
• Blogs and Forums. Jenny websites may offer publicly accessible blogs and community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. Jenny is not responsible for any personal information you choose to submit in these areas of our site. To request removal of your personal information from our blog or community forum, contact our support team. In some cases, Jenny may not be able to fulfil your request and an explanation will be provided. Commenting systems on our blogs may be managed by a third party application that may require you to register to post a comment. Please review that application’s privacy policy to learn how the third party uses your information.
• Online Tracking. Jenny currently does not process or comply with any web browser’s “do not track” signal or other similar mechanisms that indicates a request to disable online tracking of individual users who visit our websites or use our services, unless otherwise stated in a service-specific privacy statement.
• Social Media Features. Jenny websites may include social media features or widgets, such as the Facebook Like button. Use of these features may allow them to collect your IP address, detect which page you are visiting on our site, and set a cookie to enable the feature to function properly. Your interactions with these features are governed by the privacy policy of the third party providing it.
• Safety of Children and COPPA. Jenny services are not intended for and may not permissibly be used by individuals under the age of 16. Jenny does not knowingly collect personal information from persons under 16 or allow them to register. If it comes to our attention that Jenny has collected personal information from such a person, Jenny may delete this information without notice. If you have reason to believe that this has occurred, please contact our support team.
• English version only. The English language version of this Privacy Policy is authoritative. Any translations of this policy that we may provide are for convenience only.

Notices for European Union and United Kingdom users

• Personal data. For users located in the EU, references to “personal information” in this policy are equivalent to “personal data” as defined in prevailing EU data protection regulations.
• IP addresses. Our servers may record the incoming IP addresses of visitors to Jenny websites and services, whether or not the visitor has an Jenny account, and store the IP addresses in log files. Jenny uses these log files for purposes such as system administration and maintenance, record keeping, tracking referring web sites, inferring your location, and security purposes (e.g. controlling abuse, spam and DDOS attacks). Jenny may also store IP addresses along with certain actions you take on our system. By agreeing to this Privacy Policy, you expressly consent to Jenny using your IP address for the above purposes. If you wish to opt out from the above consent to use your IP address, you must cancel your account (if you have one) and/or not interact with apps created on the Jenny Service if requested to do so.
• Data controller. Jenny is the data controller for registration, billing and other account information that we collect from Jenny Service users in the EU. However, the data controller for all app data is the app creator. The app creator determines how their apps are designed, distributed and used. Jenny only processes app data in accordance with the instructions and permissions (including those given under this Privacy Policy) configured by the app creator when they create and administer their apps.
• Accessing and correcting your personal data. You have the right to access and correct the personal information that Jenny holds about you. This right may be exercised by visiting the provided “edit user” pages or by contacting our support team.
• Your responsibilities. By using the Jenny Service, you agree to comply with adequate data protection requirements when collecting and using your app data, such as requirements to inform respondents about the specific uses and disclosures of their data.
• Your data is hosted within the EU. Provided you have specified the United Kingdom or an EU country as your account’s location at signup for the Jenny Service, then your data will be hosted exclusively within our West Europe data centers. Some processing of data may still occur outside the EU by our sub-processors in order to provide aspects of the Jenny Service. Jenny personnel outside the EU may also access your data for support and maintenance purposes.

You are giving the following express consents

By clicking “I Agree” or any other button indicating your acceptance of this Privacy Policy, you expressly consent to the following:

• You consent to the collection, use, disclosure and processing of your personal data in the manner described in this Privacy Policy, including our procedures relating to cookies, IP addresses and log files.
• You consent and agree that Jenny and our various affiliates and sub-processors may process your data in countries which do not have data protection laws that provide the same level of protection as in European Economic Area countries. Jenny commits to having contracts in place with these affiliates and sub-processors that include similar requirements as prevailing EU data protection legislation. Your consent is voluntary, and you may revoke your consent by opting out at any time. If you opt-out, we will no longer be able to provide you with the Jenny Service.
• You consent to Jenny sharing your personal data with relevant persons working for sub-processors and affiliates when necessary to provide the Jenny Service.
• You consent to our use of cookies as described in this Privacy Policy.