Ji Tap Privacy Policy | Jewish Interactive UK

Jewish Interactive Privacy Policy
Effective Date: 1st May 2018

When you use Jewish Interactive and its services, you trust us with your information. This Privacy Policy is meant to help you understand what data we collect, why we collect it, and what we do with it. This is important; we hope you will take time to read it carefully.

This Policy explains when and why we collect personal information, how we use it, the conditions under which we may disclose it to others and how we keep it secure.

We may change this Policy from time to time so please check this page occasionally on our website to ensure that you’re happy with any changes.

Any questions regarding this Policy and our privacy practices should be sent to our Data Protection Officer. You can do this:

By email, to: [email protected]

By telephone: +44 7966 414 417

By writing to: Data Protection Officer, Jewish Interactive, 44B Albert Road, London NW4 2SB, UK.

Who are we?

Established in 2012, Jewish Interactive is a global non-profit organization that creates interactive Jewish programs, utilizing modern technology and innovation, to make Judaism more relevant, accessible and alive to educators, children and parents.

Jewish Interactive (“Ji” “we,” “us” or “our”) currently has offices in South Africa, US and the UK.

Jewish Interactive Inc. (“Ji US”) was established in 2013 as a Section 501(c3) charity in the US and primarily funds the development of apps and digital programs for international Jewish educational use.

Jewish Interactive Ltd (“Ji UK”) was established in 2013 in the UK as a separate entity, affiliated to Ji US. Registered Charity number 1151408

Jewish Interactive Education Trust (“Ji SA”) was formed in 2012 with an office in Johannesburg.

All three entities are totally separate, but work as affiliates.

Please see About Us page for more information.

How do we keep your data safe?

When you give us personal information, we take steps to ensure that there are appropriate technical measures in place to protect it. For example, access is restricted only to those who are entitled to see the data, our online forms are protected and routinely monitored.

Sensitive personal data, as well as credit or debit card details is given additional protection and encrypted.

Non-sensitive details (your email address etc.) are transmitted normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems.

All data is stored within the EU or ‘safe’ territories that have privacy legislation that is satisfactory to EU standards. It can only be accessed by named data processors and data controllers based in ‘safe’ territories that have privacy legislation that is satisfactory to EU standards. The US office and staff have restricted access to data and do not have access to data specific to EU countries.

We make various services available, including an educational platform that enables users to access, create, and share Jewish-themed educational, interactive content and applications (“Ji Tap,” or the “Service”). Ji has engaged the services of developer TinyTap to help bring you Ji Tap, one of our main products. The terms by which users may use our Service are set forth in our Terms of Use (the “Terms”). This Privacy Policy is part of the Terms and describes the treatment of information provided to or collected by us and third parties in connection with the Service. This Privacy Policy applies to all schools and school districts, including trained institutional staff members who are authorized to access the Service on behalf of a school or school district (each, a “School”), as well as individuals who are non-School users of the Service (Schools and individuals, referred to here as “user,” “you,” or “your”). This Privacy Policy applies to our information collection, disclosure, and consent practices for all users, including with respect to information provided by or on behalf of children under the age of 16 (“child” or “children”). We value our users’ privacy and are mindful of the fact that many of our users are children. We seek to be transparent about our privacy practices and to educate our users about privacy. While non-profit entities such as Ji are generally not subject to the US Children’s Online Privacy Protection Act (“COPPA”), the US Federal Trade Commission (“FTC”) encourages such entities to post privacy policies online and to provide COPPA protections to children. We are not fully COPPA compliant at this time. However, Ji is in the process of working with a COPPA safe harbor program that is approved by the FTC to help us implement privacy best practices and online safety guidelines for kid’s safety. We aim to comply with COPPA in the near future.

This Privacy Policy may change from time to time. We will notify you by updating the “Effective Date” found at the top of this page. Your continued use of the Service after any changes constitutes your acceptance of any new terms.

You may access some of Ji’s Services by registering for an account (each, a “User Account”) and logging in to the Service (Ji Tap site and app) with your user name/email and password. Only Schools, authorized individuals acting on behalf of organizations other than Schools if not accessing the Service on behalf of children, and individuals who are not children (including parents or guardians of children) may register for the Service. Children under the age of 16 may not register for the Service with an email address. Adults over the age of 16 can create sub accounts for children under the age of 16 as explained above.

1. Information We Collect and How We Use It

We collect two basic categories of information, aggregate information and personal information. Aggregate information is information that does not identify and cannot reasonably be used to identify an individual. Personal information is information that can be used to identify an individual, including any information that can identify a child under the age of 16. By using the Service you consent to use of your aggregate and personal information by Ji and TinyTap for the purposes described in the Terms and this Privacy Policy (including, without limitation, providing your information to third parties in the limited circumstances set forth).

We collect the following types of information:

Registration information that you provide when you create a User Account in the Ji site and apps, including your school name, first name and last name, country of residence, gender, date of birth, email address, username and password.
Transaction information you provide when you request information or purchase a product or service from us, including your postal address, telephone number and the last four digits of your credit card information.
Information sent one-on-one or within a limited group using our message, chat, post or similar functionality, where we are permitted by law to collect this information.
Location information when you use the Service, including location information either provided by a mobile device interacting with the Service, or by your IP address, where we are permitted by law to process this information.
Usage, viewing and technical data, including your device identifier or IP address, when you use the Service or open emails that we send.
Information you voluntarily share with us to help you resolve your problem. We may also collect technical information regarding your browser or mobile device, so that we may help you troubleshoot your problem.
Information based on third party built-in and external analytics tools that is sent by your device or our Service, including the pages you visit, add-ons, and other information that helps us improve the Service.
Additional examples where we collect personal or combined personal and aggregate information are : where you can create on one of our apps or sites, use the Contact Us form, or register for a Ji Tap Contest, Newsletter or any other service, register at an event, give your details to a Ji staff member or download an application.

How we collect information:

We collect information from you when you register for the Service (Ji Tap app, Ji apps and/or site), when you upload content through our Service, and when we contact you or you contact us. We also collect information through sign up sheets for trainings, through landing pages and forms when you sign up for our newsletter, blog or to our marketing email list.
We also collect information through technology, such as cookies, Flash cookies, and Web beacons.

When you give it to us DIRECTLY

We obtain information about you when you:

Receive support from one of our services
Take part in one of our training sessions
Attend one of our events
Donate money
Use any of our programmes (sites, apps)
Volunteer
Apply to work for us
Use our website
Enquire about any of the above
Give us your details.

How we use information:

To Verify Your Identity. We use your information to prevent fraud, or other unauthorized or illegal activity on your account.
To Facilitate Transactions. We do not process financial information directly. We use a third party payment vendor, Stripe World Pay Zinc, or such other vendor as we may designate from time to time to process transactions when you purchase a product or service/ make a donation from us. When using a third party vendor, it is your responsibility to ensure that the financial information that you submit to our third party payment vendor is accurate.
To Improve Customer Service. Information you provide helps us respond to your customer service requests and support needs more efficiently.
To Personalize Your Experience. We use the information we collect to send you notifications based on your account settings (such as an email to notify you that your game has been uploaded to Ji Tap), updates (such as when certain activity happens on Ji Tap) , newsletters, push notifications, and other information that may be of interest to you. For example, depending on your email settings, we may send you updates that include games you may like. You can decide to stop receiving these updates by updating your notification settings (or by opting out of our mailing lists.).
To Improve Our Service. We may use your information in a way that does not identify you as an individual to understand how our users as a group use the Service and resources provided on the Service. We may also use feedback you provide to improve our Service.
To Send You Email. We may use your email address to send you communication relating to your account including account verification, changes to our Service, Privacy Policy or Terms, and technical and security notices, as well as newsletters, invitations to our training sessions and events. We may also use your email address to respond to your inquiries, questions, or other requests. You are given the choice to opt-out of certain optional communications from us. You may not unsubscribe from service-related emails such as account verification, changes and updates to our Service, or technical and security notices without deleting your User Account. It is your responsibility to ensure that email information that you submit to Ji is accurate.

Additional Info for EU citizens:

GDPR legislation mean that we need your explicit permission to contact you for the following optional communications:

Latest news about Ji and free Jewish educational resources. This includes emails of Ji’s newsletters and blogs, top picks of Ji Tap games, new apps we are developing, what we are doing as a non-profit.
Invitations to events and promotional offers. This includes emails regarding training events, and fundraising events.
Promotional offers. This includes emails about discounts we are offering for Ji Tap or our other apps.

If you opt-in to any of the above mailing lists, you will receive the emails with relevant content.

We reserve the right to contact you via email or in other ways where you have opted in.

Third parties to Ji US that process data of data subjects are Ji UK and Ji SA. There are employees in these affiliates of Ji US that process data of data subjects. We limit the data processing of data subjects that are citizens of the EU as much as possible. Only Ji employees and select data processors (listed below) that need access of personal information of data subjects in the EU process that data. Employees of Ji US do not process the data of EU subjects wherever possible. We try to limit their access to personal information of data subjects only in the US.

Third parties and data processors we work with:

Salesforce
Hubspot
Stripe
Flurry
Google Analytics
TinyTap Inc.
Monday.com
Slack
Mixpanel

US companies including Google Analytics, Hubspot, Salesforce, Stripe, Monday, Slack and Mixpanel are in the Privacy Shield Framework and commit to data storage and processing safeguards satisfactory to EU. We have checked that the other third parties we work with also commit to this.

Updating your information:

You may review, correct, update or change your User Account and profile information at any time. Simply change your email settings in Ji Tap or contact us at: [email protected].

Once opted in, you can unsubscribe to any email sent at any time and we will update your data accordingly

If you would like all data we have on you to be deleted, please email us at [email protected]. You have the right to request to receive a copy of all of the data we have about you. We will get back to you and fulfill your request within 30 days from the date of your request, unless the requests we receive are complex or too numerous – in which case we will request a 1-2 month extension. To request a copy of all your data we are storing, please email us at [email protected]

We are developing our retention and destruction policy to delete data that is no longer relevant. If you have been inactive on Ji for more than 2 years, we may delete your account and all data.

Sharing your information:

We will not sell, share or otherwise distribute your personal information to third parties except as expressly provided in this Privacy Policy. Your personal information may be transferred to a third party in the event that the Service or a part of it and the customer data connected with it is sold, assigned or transferred.
We may share your information in response to a request from law enforcement officials. if we have a good faith belief that the law requires us to do so. We may share your information in response to civil or criminal subpoenas, or other requests by law enforcement personnel, to establish or exercise our legal rights, and to defend against legal claims if, in our sole judgment, disclosure is required or appropriate. We may also share your information if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms, or as otherwise required by law.

2. How We Protect Your Information

No method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot ensure or warrant absolute security. We require that you use a password to protect your information when using the Service, and it is up to you to do your part to keep that login information secure. When you register, your information is protected through the use of encryption, which makes it difficult for your information to be intercepted or stolen while being transmitted.

You are solely responsible for any data, text, files, information, usernames, games, graphics, audio recordings, voice recordings profiles, links and other content or materials (collectively, “User Content”) that you submit, post, record, upload or display on or via the Service or otherwise transmit to us. If you choose to submit User Content, then all parties with access to our Services may have access to your User Content. Users who sign up for a Ji Tap Pro Plan subscription have the ability to make their own User Content private so that other users may not engage with or edit their User Content without permission.

If Ji learns of a data security breach, we will notify you as required in accordance with applicable law. If you become aware of data security breach or have any questions about the security of the Service, please contact us at: [email protected].

3. Where Information is Processed

The Internet is a global environment. Your information may be transferred to and maintained on computers located outside of your area, province, state, country or other governmental jurisdiction for the purposes described in this Privacy Policy where the privacy laws may not be as protective as those where you are located. Ji is based in the US, the UK, Israel and SA. When you use our Service you consent to the processing and transfer of information in and to the US and other countries. Please note EU citizens’ data will be kept within the EU and within other safe territories when it comes to privacy legislation, such as Israel. The US office will not have access to EU data.

Keep in mind, even if the laws in your country are more protective than US law, US law governs your use of our Service, unless you live in the EU in which case we are GDPR compliant.
If you are a user based in the US and you use the Service while you are abroad, your information may be available to law enforcement or to the government of that country.
We are fully committed to complying with GDPR regulations, however please note that by registering for and using the Service, you consent to the transfer of information to the US for such use and disclosure as is described in this Privacy Policy.

4. Children’s Privacy

Ji Tap empowers parents/guardians and Schools to create User Accounts that have sub-accounts on behalf of children. Such a sub-account, created on a child’s behalf, allows the child to access the Service through a sub-account username and password. We recognize a special obligation to protect personal information obtained from children.

Parents and Guardians:

Ji believes that it is important for parents and guardians to supervise children on the Internet. We have adopted the following policies to help keep children safe:

We will not knowingly collect, use or distribute personal information from children except where: (a) we have obtained prior consent from a parent or guardian; or (b) a School is acting on behalf of a parent or guardian to provide consent for the collection of a child’s personal information as described below.
In order for us to seek parental consent, we will request the online contact information of a parent or guardian. This contact information will be used to send the parent or guardian a message about our privacy practices, to send the parent or guardian communications about the family’s User Account, and for such other purposes as described in this Privacy Policy.
We will not sell personal information we collect from children to third parties.
We do not recommend that children under the age of 16 use free form chat, message boards, email accounts, or other services within Ji Tap that would allow them to publicly post or otherwise distribute personal information. We have removed the ability of sub-accounts to rate or comment on games, and are working on removing their ability to put in an email address in their account settings on Ji Tap. We are working on removing the ability of sub-accounts (children) to comment and rate on courses.
Please note that children’s subaccount information and User Content is searchable by other users or third parties unless the account holder has made that subaccount and its User Content private.
We will not knowingly ask a child to divulge more information than is needed to participate in the Service.
We will not knowingly provide any direct link to websites that are unsuitable for children or teens.
If we have collected and stored personal information from a child, we will give the child’s parent or guardian the ability to review the personal information of the child, request that we discontinue further collection or use of the child’s personal information by Ji, and request that we delete the child’s personal information.

Schools:

Under our Terms of Use, Schools are permitted when authorized by parents/guardians to act on behalf of parents/guardians and provide consent for the collection of children’s personal information. Children’s personal information may be collected by or on behalf of Ji and its agents for use in a manner that is consistent with the School’s educational purpose only. Schools should always notify parents/guardians about their use of the Ji site, and Ji apps and sites and obtain prior consent for their records. While Ji does not use or authorize any agent or third party to use children’s personal information for any commercial purpose, children’s personal information may be publicly viewable on Ji sites and apps.

With regard to School-based activities, we adhere to the following tenets:

We will not require a child to disclose more information than is reasonably necessary to participate in an activity.
Schools can contact us directly to review the child’s personal information, direct us to delete it, and refuse to allow any further collection or use of the child’s information by Ji.
Schools can agree to the collection and use of the child’s personal information, but still not allow disclosure to third parties unless such disclosure is part of the Service.
We will notify Schools directly before collecting personal information from children. This includes what specific information we will collect and how it might be disclosed, a link to our online Privacy Policy, and how the Schools should provide notice to parents of consent. Also, if a School notifies us that a parent does not consent within a reasonable time, we will delete the parent and child’s contact information from our records.

Limited features for children:

Ji Tap is a platform that Users (including children) may use to create and play games and inspire others in the process. Certain activities on Ji Tap allow children to create or manipulate User Content and save it with Ji Tap. Our age verification gate is available on the Ji Tap mobile app and is intended to prevent children from sharing their User Content outside of the Ji Tap mobile app and make some features of our Service unavailable to children such as the ability to complete in-app purchases. Password recovery on a child’s account may only be requested and received directly through the main account holder.

Push notifications:

Push notifications are notifications on mobile and other devices that are typically associated with downloaded applications, and which can communicate to the device holder even when the application is not in use.

Geolocation data:

We do not knowingly collect geolocation information that is specific enough to equate to the collection of a street address for sub-accounts associated with children.

Persistent identifiers:

We do not knowingly enable third party analytics for sub-accounts associated with children except to support our internal operations.

5. Notice to California Residents: Your California Privacy Rights

If you are a California resident, you have the right to receive: a) information identifying all third party companies to which we may have disclosed, within the past year, personal information pertaining to you for those companies’ direct marketing purposes; and b) a description of the categories of personal information disclosed. To obtain such information, please email your request to [email protected].

We do not respond to Do Not Track signals at this time.

6. Contact Us

Please contact us at the mailing address, email, or phone number below with questions about our privacy policy and collection and use practices:

For US:
57 West 57th Street, New York 10019, USA
+1 (703) 517 5182

Or for any country outside US:
44B Albert Road, London NW4 2SB, UK
+44 7966 414 417

Email: [email protected]