DIRECT MARKETING COMMUNICATION - PRIVACY NOTICE

 

INTRODUCTION

This Privacy Notice provides information regarding the processing of individuals’ Personal Data conducted by JAGGAER, for direct marketing communication purposes.

In terms of the EU General Data Protection Regulation 2016/679 (GDPR) or any other applicable Data Protection law, JAGGAER LLC, 3020 Carrington Mill Blvd. Suite 100 Morrisville, NC27650 US, is the Data Controller of individuals’ Personal Data. Term “Controller” shall have meanings ascribed to corresponding terms under other applicable Data Protection Law e.g., “Business” under California Consumer Privacy Act (CCPA) as amended by California Privacy Rights Act (CPRA).

JAGGAER has appointed a Data Protection Officer, who can be contacted via email at privacy@jaggaer.com.

What type and categories of Individuals’ Personal Data are processed, for direct marketing communication purposes:

  1. Identification, background and contact details
    1. name, surname
    2. business contact details including business address (headquarters and regional offices), business email address, business phone number
    3. job position
    4. company name
  2. Engagement measuring data through pixel technology Information whether user: dismissed, just opened, opened and clicked on the offered content in the email.
  3. Individuals’ Device related data when they engage with JAGGAER’s website through the email communication (e.g. using links in the email that lead to JAGGAER’s website)
    1. Details of Individuals’ IP address,
    2. Device and application/browser type
    3. Device operating system
  4. Records of communications sent to Individuals’ by JAGGAER or received from Individuals

How does JAGGAER obtain Individuals’ Personal Data?

  1. Directly from individuals through presales/sales and marketing activity generation
  2. Automatically generated data such as above listed Individuals’ Device related data.
  3. Indirectly from Third-Party Sources such as Partner organizations or so called “ Data brokers”, subject to JAGGAER’s privacy assessments and warranties that data is obtained and shared lawfully to JAGGAER by such Third Parties

What is the purpose and legal basis for Personal Data processing?:

  •  Processing is necessary for the purposes of the legitimate interests pursued by JAGGAER

What is purpose of Personal Data processing?

  • increase JAGGAER’s sales with current and former clients, by promoting JAGGAER’s Solutions , as well as prospecting for new potential clients with which JAGGAER has not had any previous engagements.
  • analyzing users’ engagement and other data to monitor the success of our outreach program and understand trends in participation o using digital tools to monitor the impact of our marketing communications (click open rate, etc.)
  • work on JAGGAER’s loyalty strategies through direct contact with existing clients which allows JAGGAER to customize promotions and email content to their needs.

Note that following data which are automatically collected are not further processed:

  • details of Individuals’ IP address,
  • device and application/browser type
  • device operating system

To whom does JAGGAER disclose and where applicable transfer the Individuals’ Personal Data?

JAGGAER may disclose the Personal Data processed for the above described purposes to:

  • Companies members of the JAGGAER Group:
    • Jaggaer, LLC (United States)
    • BravoSolution Italia S.p.A. (Italy)
    • Jaggaer Austria GmbH (Austria)
    • Jaggaer Deutschland GmbH (Germany)
    • Bravosolution France S.A.S. (France)
    • Bravosolution S.p.A. (Italy)
    • Pool4tool DOO Beograd (Serbia)
    • Jaggaer Asia Pacific Pte Ltd. (Singapore)
    • Bravosolution España S.A. (Spain)
    • JAGGAER FZ LLC (Abu Dhabi)
    • Tejari Solution FZ-LLC (Dubai, UAE)
    • Bravosolution Uk Limited (United Kingdom)
    • Bravosolution APAC Pty. Ltd. (Australia)
    • Bravosolution Nordics Oy (Nordics)
    • Bravosolution Benelux B.V. (The Netherlands)
    • Docskiff, Inc. (United States)
    • Docskiff India Private Limited (India)
    • Jaggaer Arabia For Information Technology (Saudi Arabia)
  • Below listed third-party service providers supporting JAGGAER with marketing campaign management, analysis and reporting activities, subject to contractually agreed conditions of privacy, confidentiality and security, and where applicable a valid Personal Data transfer mechanism:
    • Salesforce.com Salesforce.com, INC (415 Mission St 3rd Floor, San Francisco, US.) - Pardot is a stand-alone platform, within the Salesforce ecosystem that JAGGAER uses for scaled, personalized email outreach across multiple departments (mostly by, but not limited to marketing, global customer care, privacy departments) for the purpose of marketing campaign activities for potential prospects, cross-sell / upsell activities to existing customers, as well as for communication of necessary JAGGAER product updates, maintenance windows and major changes impacting existing customers.
    • Outreach Corporation, (33 Elliott Ave W, Suite 500, Seattle, WA 98119, US) - Outreach is used by JAGGAER’s sales teams for automated, sequenced email outreach to potential customers and existing customers.

International Data Transfers

JAGGAER will transfer Individuals’ Personal Data to locations where JAGGAER Affiliates are based as well as the third-party service providers as listed above, transfer will be conducted only subject to rules and valid transfer mechanism under the applicable Data Protection law and appropriate security measures.

How long will JAGGAER keep Individuals’ Personal Data?

JAGGAER will retain Personal Data we process about Users for as long as we have a legitimate business purpose to do so, or until individual opts-out from further processing. When JAGGAER no longer have an ongoing legitimate business need to process individuals Personal Data, JAGGAER will either delete or anonymize it or, if this is not technically feasible (for example, because Personal Data has been stored in backup archives), then JAGGAER will securely store such Personal Data and isolate it (via properly marking them as “Inactive” in a specific field created for that purpose) from any further processing until deletion is possible.

Individuals’ rights under the GDPR 

  • The right to be informed. Individuals are entitled to be informed of the use of Personal Data (as defined under GDPR). This Notice provides such information.
  • The right of access. Individuals have the right to request a copy of their Personal Data which JAGGAER holds.
  • The right of correction. Individuals have the right to request correction or changes of the Personal Data if it is found to be inaccurate or out of date. • The right to withdraw consent. Individuals have the right to withdraw a previously given consent for processing their Personal Data.
  • The right to be forgotten. Individuals have the right to request JAGGAER, at any time, to delete their Personal Data in its possession when it is no longer necessary for JAGGAER to retain such data for the purpose of processing, when the Individual withdraws consent on which the processing is based and where there is no other legal ground for the processing; • The right to object (opt-out). Individuals have the right to opt out of use of their Personal Data, for direct marketing purposes at any time.
  • The right to data portability. Individuals have the right to a “portable” copy of the Personal Data they have submitted to JAGGAER.
  • The right to refuse to be subjected to automated decision making, including profiling. Individuals have the right not to be subject to a decision and insist on human intervention if the decision is based on automated processing and produces a legal effect or a similarly significant effect.
  • The right to lodge a complaint with a supervisory authority. Individuals have the right to lodge complaints about our data processing activities by filing a complaint with JAGGAER or with the relevant Supervisory Authority. A list of Supervisory Authorities is available here: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

Individuals’ rights under the CCPA/CPRA

  • The right to know. individuals have a right to request that JAGGAER discloses to you the Personal Data JAGGAER has collected about them. Individuals also have a right to request additional information about JAGGAER’s collection, use, disclosure, or sale of such Personal Data in the past 12 months. Individuals may make such a “request to know” by contacting JAGGAER’s DPO at privacy@jaggaer.com.
  • The right to delete. Individuals have the right to request that JAGGAER deletes any of their Personal Data that JAGGAER collected from them and retained, subject to certain exceptions. Once JAGGAER receives and confirms their verifiable consumer request, JAGGAER will delete (and direct JAGGAER’s service providers to delete) individuals’ Personal Data from its records, unless an exception applies.
  • The right to correct inaccurate Personal Data maintained by the business
  • The right to data portability. Individuals have the right to request that Personal Data is transferred to another entity in a structured, commonly used, machine-readable format, to the extent possible.
  • The right to opt-out of the sale of Personal Data. Individuals have right to opt-out from sale of their Personal Data. Individuals may exercise that right writing to privacy@jaggaer.com.
  • The right to limit the use and disclosure of Sensitive Personal Data. Individuals have the right to limit the use and disclosure of their Sensitive Personal Data
  • The right to non-discrimination. JAGGAER will not discriminate against individuals for exercising any of their CCPA rights.

If individuals are located in California and have questions about their rights, they may also contact CCPA Toll Free Number: 1-866-467-8688, enter Service Code 987#. 

Contacting Us

Individuals may address any question about JAGGAER’s processing of their Personal Data to privacy@jaggaer.com.