Privacy Policy
Last updated : 8th July 2024
Changes to this Privacy Notice
Joraleka reserves the right to update or modify this Privacy Notice at any time. All updates and modifications to these documents will be effective from the day they are posted on the Site at https://www.joraleka.com/pages/privacy (except as stated below). If we make any material changes to this Privacy Notice, we will notify you of these changes by sending a notification to the email address we have on file for you, and may also post a prominent notice of any such changes on the Site and/or through the user interface of the Platform. It is your responsibility to regularly visit and review this Privacy Notice. If you do not agree to any updates or modifications to the Privacy Notice, terminate your Account and cease all use of the Services. Your continued use of the Services after we have posted the updated Privacy Notice, or, in the event of material changes, ten (10) days following the date we first notified you of such material changes via email or the date we posted the notice of such changes on the Site and/or through the Platform, as applicable, signifies to us that you acknowledge and agree to be bound by the revised Privacy Notice.
Information We Collect
How and what personal information we collect in connection with the use of the Services depends on how and why you use the Services.
The term “personal information” or “personal data” means any information about an individual from which that person may be identified. For example, it may include a person’s name, telephone number, email address, or payment information, and in some jurisdictions, IP address. It does not include data from which the identity of an individual has been definitively removed along with any identifiers connected to such individual (also known as anonymous or anonymized data).
Generally, Joraleka collects personal information when you:
- Visit and/or browse the Site,
- Access and/or use the Platform,
- Register an account to access and use the Services (“Account”),
- Interact with and/or use support and other services provided by us as part of or in connection with the Services,
- Sign up for our marketing communications and/or newsletters, and/or
- Communicate with us directly.
In some instances, we collect information directly from you as explained here, and in others, you will not provide any information to us directly, in which case we automatically collect certain information as explained here. In addition, we may receive information from third parties as explained here.
Important Note Regarding Client Users
Please note that if you access and/or use the Services as an employee, contractor and/or agent of a user that is a Client, you are deemed a “Client User” of that Client, and certain information collected by us in connection with your use of the Services is controlled by the Client. When we collect and/or process such information, we do so on behalf of the Client. In such cases, the Client is the “data controller” and Joraleka is the “data processor” (as those terms are defined under applicable data protection laws).
Whether that Client is your employer, another organization, or an individual, that Client determines its own policies regarding storage, access, modification, deletion, sharing, and retention of such information which may apply to your use of the Services. If applicable, please check with the Client about the policies and settings it has in place with respect to information you submit in connection with your use of the Services.
A) Information Provided by You Directly to Joraleka
The personal information we collect directly from you depends on how and why you use the Services. For instance, the information that you provide when you visit and/or browse the Site or sign up for our marketing communications is more limited than the information you provide when you register an Account. We have divided this section into the following categories to better explain the circumstances the types of personal information that may be collected when you engage in the following activities:
- Account and Profile Information
- User Content
- Payment and Transaction Information
- Identity Verification Information
Please be advised that we may ask you to update your information from time to time in order to keep it accurate.
Additionally, if you provide personal information to us about someone else, you must ensure that you are entitled to disclose that information to us and, without us having to take any further steps required by data protection laws, that we may collect, use and disclose such information for the purposes described in this Privacy Notice. For example, you should ensure the individual concerned is aware of the terms detailed in this Privacy Notice and that they have not objected or do not object to you sharing their information with us.
Account and Profile Information
When you register an Account, Joraleka may collect the following personal information directly from you:
- Your identity (including your first name and last name);
- The name of your employer;
- The name of the Client if you are invited to use the Services as Client User;
- Your occupation, if you register as an Account as an Expert;
- Your email address;
- Your postal address;
- Your phone and/or mobile number; and/or
- Your photo, biographical information, and any other information you decide to share and/or add to your user profile (“Profile”).
User Content
If you post, submit, transmit, upload and/or otherwise provide us any messages, photos, video, audio, images, data, information, text and/or any other content or materials in connection with the use of the Joraleka Service (collectively, “User Content”). Examples of when we collect User Content include:
- When you post a listing for Project on or through the Services;
- When you provide reviews and/or feedback relating to an Expert who has provided you Expert Services “Reviews”);
- When you use any communication, phone, text and/or chat features of the Services, including, without limitation, through the phone number and/or email Joraleka has provided to an Expert (“Communication Features”);
- When you fill out forms, answer surveys, or contact us (such as your feedback, requests for support, or other communications with us; and/or
- When you comment and/or post on any of our blogs or forums available through the Services.
Payment and Transaction Information
When you make purchases and/or receive payments through the Services, Joraleka may collect limited payment information, such as your credit card, bank account information, billing address, taxpayer identification information, as well as information regarding the payments paid and/or received by you in connection with the use of the Services.
Note that payment transaction information is processed and stored exclusively by our third-party payment processors and/or by the third party payment provider you have linked to your Account, and the information provided to Joraleka only includes partial payment or credit card information, as described here.
Identity Verification Information
In some circumstances, we may need to verify your identity and/or qualifications for our internal purposes or as required by law, for example, for tax filing purposes, or, with your consent, to conduct a background check, in which case, we may collect certain personal information, such as your date of birth and your taxpayer identification number or social security number, and any other information necessary for us to verify your identity and/or qualifications and/or to conduct background checks.
B) Information Collected Indirectly
Usage Information
When you use or interact with the Services, we, or our authorized third-party service providers, automatically collect information about how you use them (collectively, “Usage Information”).
Usage Information that we collect consists of information about your interactions with the Services, including information about the device and/or platform (e.g., iOS or Android) used by you to interact with and/or access the Services, including, without limitation, IP address, access dates and times, information about your approximate location (as determined through your IP address), device information, device event information, crash data, and log data when you access and use the Services.
Usage Information allows Joraleka to understand how you’ve used the Services (which may include administrative and support communications with us), and other actions you have taken in connection with your use of the Services. We use this information for our internal purposes, specifically to operate, maintain, secure and improve the Services.
Typically, all technical, analytics, and usage information is gathered by Joraleka in anonymous form and does not identify you personally. To the extent any Usage Information is linked or tied to personally identifiable information, such information is deemed “personal data” and we will use it and protect it in accordance with this Privacy Notice.
We may also use this information to provide you with notifications, recommendations, and information about specific features of the Services and/or additional products, services, or features we believe may be of interest to you.
Cookies and Similar Technologies
We or authorized third parties may collect certain information by automated means using technologies such as cookies, web beacons, embedded scripts, pixels, browser analysis tools, server logs, and mobile identifiers; however, even though we use these technologies to track the use of the Services, Joraleka does not directly track users across third party websites; however, certain third partner advertising partners may track you across third party websites as described below. In many cases, the information we collect using cookies and other tools is only used in a non-identifiable manner without reference to personal information. For example, we may use information we collect to better understand website traffic patterns and to optimize user experience. In other cases, we associate the information we collect using cookies and other technology with your personal information. For more information on our use of these technologies, see our Cookie Policy.
Targeting & Advertising
We may use third party advertising partners (e.g., Facebook, Inc. and Google, Inc.) who use targeting/advertising cookies and similar technologies to deliver advertisements that are more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaigns. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organizations such as advertisers. For more information on our and/or third party advertising partners’ use of these targeting & advertising cookies and similar technologies, please see our Cookie Policy.
C) Information Collected from Third Parties
In some instances, we process personal information from third parties, which consists of:
- Data from our partners, such as transactional data from providers of payment services and/or from payment platforms that you have linked to your Account.
- Information from other Users that you engage with in connection with a Project, for example, if you are an Expert, we may receive information about you from a Client you are working with or if you are Client User, we may receive information about from the Client that authorized you as a Client User.
- Information from third party providers of certain third party products, goods, services and/or Sites that we have identified and/or linked on or in connection with the Services (all of the foregoing, “Third Party Products and/or Sites”), if you have clicked on and/or engaged with such Third Party Products and/or Sites.
D) Aggregated Data
With the personal information and other data (including, Usage Information) collected by us, we process “Aggregated Data”, such as statistical or demographic data. Aggregated Data may be derived from personal information, but is not considered personal information under the law if it does not directly or indirectly reveal your identity. If we combine or connect Aggregated Data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information, which will be processed in accordance with this Privacy Notice.
Children’s Privacy
Joraleka does not target the Services to persons under the age of 18 and does not knowingly collect personal information from minors. Therefore, we ask you not to provide us with personal information of persons under the age of 18. If we learn that personal information of persons under 18 years of age has been collected on or through the Services, then we may deactivate the account or otherwise terminate access to the Services and/or make the user content inaccessible.
Sensitive Data
Joraleka does not require you to provide any sensitive data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health and genetics, or biometric data to use the Services.
Payment Processing
We do not directly collect or store any payment information. We use third-party, PCI-compliant, payment processors (currently, we use Shopify Payments and PayPal), and enable you to connect your Account with our third payment processors, which collect payment information on our behalf in order to collect fees payable by you, complete transactions, and/or payout any fees that may be payable by us to you in connection with your use of the Services. Our administrators are only able to view limited transaction information via our payment processors’ portals. Please review the following Privacy Policies of our current payment providers to learn more about how they collect, process and protect your personal information:
- Shopify Payments : https://www.shopify.com/legal/privacy
- PayPal : www.paypal.com/myaccount/privacy/privacyhub
Using Personal Information
Our mission is to provide a safe, efficient and high-quality services, and we, or our authorized third party service providers who assist us in providing the Services, process your personal information for this purpose. We process your personal data for the reasons and on the legal basis as follows:
- In order to perform the Services under the contract we are about to enter into or have entered into with you. For example, when you register to use our Services, that’s a contract. This may also include disclosure to the third parties who help us perform our obligations to you in connection with your use of the Services, such as hosting providers, and payment processors.
- Where it is necessary for our legitimate interests (or those of a third party), and your interests and fundamental rights do not override those interests. For example, for security purposes and protection against fraud.
- Where we need to comply with a legal or regulatory obligation. For example, keeping records of our sales for tax compliance.
- If we have obtained your prior consent (for example, when you subscribe to our newsletter or participate in our surveys or marketing campaigns). Please note that for this specific legal basis, you have the right to withdraw your consent at any time.
Depending on how you use the Services, we use your personal information in the following instances:
- To host and provide the Site (performance of a contract);
- To perform and provide the Services to you (performance of a contract);
- To perform our payment and disbursement obligations arising from our collection, receipt and payment of fees due and payable by Clients to Experts in connection with the performance of a Project (performance of a contract);
- Conduct checks to verify identity or, in some circumstances, background checks (performance of a contract or sometimes necessary for our legitimate interests, and with your prior consent with respect to background checks);
- Deliver direct marketing communications to you regarding our products and services that we may think are of interest to you (for our legitimate business purposes and with your prior consent where required by law when you are not an existing customer);
- Respond to your queries and requests, or otherwise communicate directly with you (including, without limitation, via telephone and SMS text messages) (performance of a contract or sometimes necessary for our legitimate interests);
- Detect any fraudulent or illegal activity against you, our other customers and users, and/or Joraleka (necessary for our legitimate interests);
- Perform system maintenance and upgrades, and enable new features (performance of a contract or sometimes necessary for our legitimate interests);
- Provide information to regulatory bodies when legally required, and only as outlined below in Legal Obligations and Security (necessary for compliance with a legal obligation).
Sharing Personal Information
Aside from disclosing your information to those of our personnel who are authorized to process the information in order to provide the Services and who are committed to confidentiality, we disclose your personal information only to the third parties as described below.
A) Third-Party Service Providers
We share personal information with third parties that provide services to us that help us in the operation, provision, administration and management of the Services (“Service Providers”), and to otherwise operate our business. Depending on how you use the Services, the following categories of third parties collect data on our behalf or receive personal information:
- Hosting services providers,
- Analytics providers,
- Advertising and marketing partners,
- Providers of business operations and communication tools,
- Other third-party service providers that help us provide features and functions for the Services (e.g., customer support providers, phone and email providers to enable certain Communication Features), and
- Professional service providers, such as auditors, lawyers, consultants, accountants and insurers.
For a list of all Service Providers we use, please contact us. We require all Service Providers to respect the security of your personal information and to treat it in accordance with the law.
B) To other Users of the Services
Depending on how you use the Services, we may share your information with other users of the Services. Examples of when we may share your information with other users includes:
- We may share your Profile information with other users, unless you have marked your Profile (or certain information therein) as private.
- If you use any Communication Features, for example, when you communicate with a Client and/or Expert using the email and/or phone number provide by Joraleka to the applicable Expert and/or engage in chat groups and/or message through the Services, any personal information submitted or transmitted in connection with such Communication Features will be available to anyone who has access to the Communication Features.
- If you comment and/or post on any of our blogs, your comments and/or posts will be publicly available.
- If you are a Client User, we will share and disclose your personal information with the Client and otherwise in accordance with the Client’s instructions, including any applicable terms in the Joraleka Terms of Service Agreement, and in compliance with applicable law and legal process. If you are a Client User, please consult with the Client to learn more about how your information may be used, shared and/or disclosed by us on behalf of the Client.
- If you request to designate a Client User to access and use the Services, the Client User may have access to your data and information depending on the permissions you grant to such Client User.
- If you engage and/or enter into any Project with another user, we will share your information and data, including any related Project details and information, with the other users that are also engaged in that Project (which may include, the Expert and/or the Client, and the Client’s Client Users).
Please be aware that other users with whom you choose to share your information may use your personal information differently than we do, and we do not control their use of your information. Joraleka will not be able to contain or retrieve personal information once it has been shared or disclosed with other users, and Joraleka will have no responsibility or liability for any consequences that may result because you have released or shared personal information with others.
Please make your choice to share your information carefully.
C) Third Party Products and/or Sites
When you choose to click on any links we have placed on the Site and/or interact with and/or engage with any Third Party Product and/or Sites, certain data and information may be exchanged between us and the provider of the applicable Third Party Products and/or Sites. Note that the third party providers of Third Party Products and/or Sites with whom you choose to share your information with are not our service providers. The applicable providers of Third Party Products and/or Sites may use your personal information differently than we do and we do not control their use of your information. Please review the privacy policies of any Third Party Products and/or Sites you decide to visit and/or interact or engage with.
D) Business Transfers
We may also share data with third parties to whom we choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this Privacy Notice.
E) Affiliates and Subsidiaries
Personal information that we collect about you through the Services may be shared with the employees, contractors, and agents of Joraleka and our affiliated and subsidiary entities (“Affiliates”) who are involved in providing or improving the Services that we offer to you. We obligate the employees, contractors and agents of Joraleka and our Affiliates to ensure the security and confidentiality of your personal information and to act on that personal information only in a manner consistent with this Privacy Notice.
Legal Obligations and Security
If we are required to disclose personal information by law, such as pursuant to a subpoena, warrant or other judicial or administrative order, our policy is to respond to requests that are properly issued by law enforcement within the United States. Under such circumstances, unless prohibited by applicable law, we will attempt to provide you with prior notice that a request for your personal information has been made in order to give you an opportunity to object to the disclosure. We will attempt to provide this notice by email, if you have given us an email address. However, government requests may include a court-granted non-disclosure order, which prohibits us from giving notice to the affected individual. In cases where we receive a non-disclosure order, we will notify you when it has expired or once we are authorized to do so.
Note that if we receive information that provides us with a good faith belief that there is an exigent emergency involving the danger of death or serious physical injury to a person, we may provide information to law enforcement trying to prevent or mitigate the danger (if we have it), to be determined on a case-by-case basis.
G) With your Consent
There may be situations where you are asked to consent to share personal information with third parties for additional reasons not included in this Privacy Notice. In such event, we will only share such personal information if we have received your prior consent and only for the purposes as listed in the request to share such information.
Marketing Communications
If you are a registered user and have not otherwise opted out (or with your consent where required by applicable law), or if you have opted in to receive direct marketing emails from us, we may use your personal information to send you marketing information about the Services, other Joraleka products and services, new product releases, and new feature releases of the Services that we think may interest you. We carry out direct marketing by email.
If you no longer wish to receive marketing communications, you have the right at any time to opt out as further explained in Your Choices.
Your Choices
If you are a registered user and have not otherwise opted out (or with your consent where required by applicable law), or if you have opted in to receive direct marketing emails from us, we may use your personal information to send you marketing information about the Services, other Joraleka products and services, new product releases, and new feature releases of the Services that we think may interest you. We carry out direct marketing by email.
A) Accessing, Updating and Correcting Personal information
If you would like to correct or update certain personal information (such as your contact information and/or Profile information), you can update this information in your Account and/or Profile page. If there is other information that you have provided to us you wish to correct and/or update please contact us and we will use reasonable efforts to correct and/or update such information.
B) Additional European and International Data Rights
If you are a resident of the European Economic Area or another country with data protection laws that provide for certain data subject rights, you may have additional rights you can exercise as described here.
C) Direct Marketing
You may manage the receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of any of our marketing e-mails. We will use commercially reasonable efforts to process such requests in a timely manner. Note that you cannot opt out of receiving transactional e-mails or communications related to the Services (e.g., requests for support), which, for clarification, are not marketing communications.
D) Cookies & Targeted Advertising
You can manage your cookie and tracking preferences as described in our Cookie Policy.
Third Party Social Plug-Ins
External Websites
On or through the Services, we provide third-party “share” buttons which enable you to share certain content via social media sites (e.g., Facebook, Twitter, Instagram, YouTube, and LinkedIn). These “share” buttons may function as web beacons when you interact with the button. Please note that when you “share” using the buttons, you may send to the third party provider of the “share” button the information that you are viewing. If you are not logged into your account with the third party provider, then the third party may not know your identity. If you are logged in to your account with the third party, then the third party may be able to link information or actions about your interactions with the Services to your account with the applicable third party provider. Please refer to each third party’s privacy policies to learn more about its data practices.
Data Retention
Data Security and Protection
California Privacy Rights – Shine the Light
Joraleka does not share your personal information with any unaffiliated third party for its direct marketing purposes without your express consent.
California residents who have provided us with personal information have the right (under California Civil Code§ 1798.83) to request and obtain from us, once each year, the details of any personal information we shared with a third party for that third party’s direct marketing purposes during the prior calendar year. The details would include the categories of personal information and the names and addresses of the third party with which it was shared.
To request information about this sharing, you may submit a request with "Your California Privacy Rights" in the subject line, along with your first and last name, and complete mailing address (including street address, city, state, and zip code) by either: sending an email message to admin@joraleka.com or writing to us at the mailing address in Contact Us.
If you do not submit and send your request with complete information as set forth above, we will not process it.