Welcome to our Privacy Policy! Last modified: August 30, 2019

JASMIN is an entertainment site, offering informative, educational and entertaining content such as articles, images and videos.

When you decide to register on Jasmin directly as an Influencer or under an Agency, and provide content and other services on our site (hereinafter, the “Services”, as defined in our Services Agreement with you, and available here), we will collect some of your personal information.

We want you to use and contribute to our site and trust us. Please be assured that we are fully dedicated to the protection of your personal information.

Your privacy is important to us. This Privacy Policy will explain how we collect, use and share your personal information, so that you can make informed choices about the use of your data.

Please read this Privacy Policy carefully.

You can contact us if you have any questions about our privacy practices or about what we are doing with your personal information. We will be happy to assist you in any way we can.

1. WHO DECIDES “HOW” AND “WHY” YOUR PERSONAL DATA IS PROCESSED?

The Data Controller decides “how” and “why” your personal data is processed. JASMIN’s Data Controller is:

Duodecad IT Services Luxembourg S.à r.l.
Private Limited Liability Company
44, Avenue John F. Kennedy
L-1855, Luxembourg
Grand Duchy of Luxembourg
Company Registration No.: 171.358

2. What Personal Data do We Process?

We provide two possibilities for you to create an account on our site:

Influencer Account

This means you register directly and individually as an Influencer.

Agency Account

You can register an Agency Account under which you can create several Influencer Accounts. Please note that these will be associated with the primary Agency Account.

If you are the creator of the account, and therefore named Agency, you can either be:

  • An Influencer yourself willing to provide services on our site and open an Influencer account under your Agency account
  • A person (natural or legal) having contracted with Influencers and opening an Agency account to enable the provision of Services by them

This Privacy Policy will apply to you regardless of what kind of account you decide to create/register.

We collect, use, share, transfer, and store different types of personal data as a result of your registration and provision of Services on our site.

The personal data we collect include the following categories of data:

2.1. Personal Data You Provide

Please note that if your account has been created as part of an Agency, the Agency will provide us with some or all of the information indicated below.

Influencer Account

When you create an Influencer Account on our site, we require the following details about you:

  • Email address
  • Password
  • Screen name
  • ID information

    This includes the following:

    • Full Name
    • Date of Birth
    • Gender
    • Country
    • Nationality
    • Ethnicity

    We will also request that you upload an official document (e.g. ID card, passport, driving license) for identity verification purposes.

Once your account has been created, you can choose to do the following:

  • Add any information about you, including your interests and Services provided
  • Upload any images (i.e. profile picture) and videos onto your “My Content” page
  • Add “My Story” content to the site

This information is OPTIONAL but providing it could increase your earnings.

You may delete this information at any time, which will not affect your use of the site.

Please also be aware that any content you provide to the site is subject to intellectual property protection. Read clause 6 of the Services Agreement for the specifics of how you are affected.

Agency Account

When you create an Agency Account on our site, we require the following details about you:

  • Email address
  • Password
  • ID information

    This includes the following:

    • Full Name
    • Date of Birth
    • Gender
    • Country
    • Nationality
    • Ethnicity

    We will also request that you upload an official document (e.g. ID card, passport, driving license) for identity verification purposes.

Once your account has been created, you can choose to do add any further information about yourself including your preferences and age. This is especially relevant if you yourself are an Influencer willing to provide Services on the site.

You may delete this information at any time, which will not affect your use of the site.

Please also be aware that any content you provide to the site is subject to intellectual property protection. Read clause 6 of the Services Agreement for the specifics of how you are affected.

Billing Support & Influencer Support

We collect all information you choose to share with our Billing Support & Influencer Support teams, including:

  • Your personal email
  • The Services, Fans or other Influencers associated with your request
  • Your comments or opinions about a Fan or another Influencer
  • Your conversations with the relevant team

More generally, when you communicate with us in any other way, we will collect whatever information you provide us with.

Pay-Out Page

When you complete the Pay-Out Page to receive payment of your earnings, we will collect any information you provide via that page, including:

  • Your billing address
  • Payment method (i.e. virtual account, wire transfer)

    This will affect what other information we collect, including if you have to provide the following:

    • Account information
    • Other ID/Payment information
  • ID Details
  • Address of beneficiary (if applicable)

If you are a company, we will ask you to provide the identification details of the managing director or representative of your company.

Please note that, if you choose to receive money through a virtual account, we will not be responsible for the data you provide to the third party who creates and manages your virtual account. Please ensure you check the privacy policy of the virtual account provider if you want to learn more.

If you wish to change your pay-out details, you can do so at any time by sending an email to payinfo@jasmin.com from your registered email address and providing us with the following minimum documents:

  • Scanned copy of your photo ID
  • Photo of you holding your ID next to your face

2.2. Personal Information from Site Use

We collect and process certain information about you when you navigate the site and provide Services.

This means that, when you browse the site, offer Services, or take any action on our site, we collect certain information, including:

Usage information

We collect information about your activity on our site and about how you interact with the features of the site, including:

  • Activity history
  • Special features used, e.g.:
    • Video contest participation
    • Uploading content on your “My Content” page

We collect information about how you communicate with Fans, including:

  • Time & Date of communication
  • Method of communication (e.g. Messenger)

Content information

We collect any content you share on our site including the following:

  • Images, text or videos uploaded onto your “My Content” page
  • Messages sent or received
  • Information about the content you create/provide

We also know the number of likes of and interactions with the content associated with your account and who purchased any specific content.

Please be aware that any information you make public on our site (e.g., comments on a picture) will be visible and may appear in search engine results.

Please also be aware that we collect all communication data between yourself and our company, including but not limited to, telephone conversations, chat logs, text messages, faxes and letters.

Earnings

We calculate your earnings by given period based on the following:

  • Your activity on the site
  • Amount paid by Fans

You can access the details of your earnings via your account settings in the pay-out section. However, please note that this differs depending on how your account was created:

  • Individual Influencer Account
    You can access this information within your account settings, as described above.
  • Agency-affiliated Influencer Account
    Whether you can see your earnings, will depend on whether your Agency has decided to share this information with you.
  • Agency Account
    You can see the earnings of all Influencers under your Agency, and choose whether or not they (the influencers) will be able to see their individual earnings.

Log Data & Device Information

We automatically collect log data and information from/about your computer, phone or other device you use to access or navigate our site, including:

  • IP address
  • Date and time you logged in
  • pages viewed
  • Features used
  • Hardware/Software/Internet browser used
  • Operating System/Application version used
  • Cookies / other technologies that may uniquely identify your device / browser

If you are using a mobile device, we might also collect:

  • data that identifies your mobile device
  • Device-specific settings & characteristics
  • location details
  • App crashes & other system activity

Cookies / Other Technologies

Like many websites and applications, we use cookies and other technologies (e.g., web beacons, web storage, unique advertising identifiers, etc.) to collect information about your activity, browser and device.

It is no longer permitted for web browsers to accept cookies by default. You must explicitly accept or reject Cookies on your browser or device. You may withdraw your consent to Cookies use through the settings of your browser or device.

Please keep in mind that blocking cookies may negatively affect your use of the services on our site.

To learn more about how we use cookies, and your choices, please check out our Cookies Policy.

HOTJAR

Hotjar is a third party technology service that helps us better understand our users (e.g. which pages they spend the most time on, which links they click on, what they do and don’t like, etc.), enabling us to build and maintain our service with user feedback.

Hotjar uses cookies and other technologies to collect data on our users’ behaviour and their devices (e.g., IP address, device screen size, device type, browser information, geographic location (country only), preferred language, etc.). They store this information in a pseudonymized user profile.

Neither Hotjar nor we will use this information to identify individual users or to match it with further data on an individual user.

For further details, please see Hotjar’s privacy policy here.

You can opt-out of a user profile on Hotjar and Hotjar’s use of tracking cookies by following this opt-out link.

2.3. Data Collected by Third Parties

The following are situations where your personal data has been collected by a third party:

Fans

When discussing with our Support teams, Fans or other Influencers may provide information about you, which will be collected.

Agency registration of Influencer Accounts

If you are an Influencer and your account was created by a separate organisation/person, then be aware that the Agency will provide us with certain or all of the registration details required to create your account as mentioned in clause 2.1: “Personal Data You Provide”

Third Party Partners/Service Providers

These third parties assist us in maintaining data accuracy and providing and enhancing our Services.

We use external partner ad networks, which help us to promote our sites, including JASMIN. They may collect information about your experiences and interactions with our ads on our behalf. They do not have permission to use the collected data for their own purposes.

2.4. Public Personal Data

We collect publicly available information about you only when it is necessary to prevent fraud and illegal activities on our site (e.g., when we witness child abuse cases or paedophilic activity, etc.), as well as to perform a general background check on you for know-your-customer (KYC) purposes in databases containing publicly available information.

This data may comprise publicly available information you share on social media like Facebook, a personal blog and/or site, and any other public data available on the internet.

This information is always associated or combined with the data we collect through our site to finalize our investigation before reporting any fraud and/or illegal activity to the authorities. We never use publicly available data for any other purpose.

2.5. Special Category Data

This means data of a sensitive nature, the exposure of which would significantly impact your fundamental rights and freedoms; for example, it could be used against you for unlawful discrimination (e.g. your ethnicity).

The only sensitive data we will process is your ethnicity (e.g. African American, Asian, Hispanic, etc.), if you provide this upon registration of your account.

In order to provide you with the utmost level of data protection, we categorize such data as sensitive, which is highly protected and handled with utmost care.

Where possible, we always ask you for your consent to the use of your sensitive data. If an Agency has created your account, then they will be responsible for asking your consent for providing us with and allowing us to process your sensitive information.

Please note that due to the nature of our site, refusing to provide or revoking your consent to have this data collected and processed by us means that you will not be able to register as an Influencer or log in to your account.

Please also note that we regularly test and update our security measures, so we can ensure that we are providing the highest protection possible.

3. Why do We Process Your Personal Data?

We use the information we collect for the following purposes:

3.1. Account Activation

Required Information

We primarily use the data you give us when creating your online account to open and manage this account. The account then allows you to upload content and notably provide the Services stipulated in the Services Agreement.

Your account will also allow you to exercise control over your personal data. Through your account, you can view your pay-out page and manage your personal settings. You are in control of what you use to complete your profile and can choose the content you wish to share with us and the Fans.

We process this information to perform the contract that we have with you and provide you with the platform you can use to provide Services. If you fail to provide the minimum details required, we will not be able to create your account and allow you to use our services.

Additional Information & Content

You have the option to provide us with additional information on your profile. This information and content may be shared with our Fans upon certain conditions (e.g., when a Fan subscribes to paid features, buys premium content, etc.).

We process this information to perform the contract that we have with you and provide you with the platform you can use to provide Services. If you fail to provide the minimum details required, we will not be able to create your account and allow you to use our services.

3.2. Improve and promote our services

To understand how we can improve our services and find better ways to promote them to others, we collect your personal data for the following purposes:

Analytics & Statistics

We use the information you provide us with and that we collect ourselves to detect general trends regarding the preferences/habits of our users. This helps us to generate statistical reports on Agencies and Influencers including indicating earnings per country.

Feedback

We process the data relating to your activity and income to provide you with feedback on your performance. For example, regarding your earnings.

Please note that we display income statistics and a pay-out overview in the pay-out section of your account.

Improvements

We use your data for testing, troubleshooting and improving the functionality and quality of our online entertainment services. Our main goal is to optimize our site and services, making them easier and more enjoyable to use.


We process this information with the legitimate interest of developing and improving our site and users’ experience.

When we use cookies or similar technologies for the same purpose (i.e. product enhancement/improvement), we rely on your consent for the use of cookies, including third party cookies.

To learn more about how we use cookies, and your choices, please check out our Cookie Policy.

3.3. Influencer/Agency Relationship Management

Influencer/Agency management is key to our service. Included in this section is any contact we have with you. The following are related instances where we collect and process your personal data:

Influencer Support

Influencer Support operates 24/7. By sharing your personal data with our Influencer Support team, we will be able to provide you with your answers, and any help you may require, more efficiently.

All of your communications with the team and any information you provide, including comments/reviews of Fans or another Influencer, are stored and reviewed so that we may respond to your request. This way we can ensure the full compliance of all users with our Terms & Conditions and Service Agreements (as applicable).

Some of these communications will be used for training purposes within the Influencer Support team, so that we can provide you with an excellent service.

Please be aware that our Influencer Support team will have access to all information that has been collected about you. By having this access, we ensure that our Support team has everything they need to give you an appropriate and efficient response. This will also allow our Support team to detect any fraudulent activity.

General Exchanges

Please note that we may contact you through emails or other appropriate means, to inform you of any changes regarding the site or announcements relating to your account (e.g. successful registration).

Contests & Events

We organise contests and events occasionally, and we use your email address to invite you to participate. We may contact you via email or phone if you decide to participate in a contest or event.


Please be advised that the processing and use of your personal information is strictly necessary for support and contact purposes (i.e. to perform the contract we have with you).

3.4. Payment & Accounting

We use your data for payment and accounting purposes, to process transactions and maintain legally required financial records.

We also use your data, if necessary to investigate any issues we might encounter with your bank (e.g. bank transfer issues with your account).

The use of your personal data is strictly necessary in this instance in order to execute any payments for the adequate performance of the contract we have between you once you have registered on the site.

3.5. Ensure a safe and Trusting Environment

To protect you and our business, we use your personal data in the following ways:

  • To detect and prevent fraud/illegal activities
  • To detect potential breaches to our Terms & Conditions or to the rules of our site, as explained in the Services Agreement
  • For security & risk assessment (e.g. authentication & verification of identity)

We have a legitimate interest in keeping you and our business safe and ensuring compliance with the T&Cs/rules, which attempt to guarantee this.

3.6. Marketing/Information Messages

Generally, when you sign up to use our site, we will send you informative messages and marketing to keep up to date with the release of new features and/or services.

In terms of informative messages, these will include newsletters and information regarding any workshops or events, which could help you to improve your services or develop your activity.

For marketing, these will be tailored to your profile (e.g., country). We will never use data classed as “sensitive” for marketing purposes.

We may also send you emails inviting you to participate in surveys so that we can receive feedback on your experiences with our business and/or brand in order to improve them.

We may pseudonymize your email address and use it to generate statistical results. These statistics are in the form of aggregated data and not personal information (e.g. number of registered Influencers per country).

We have a legitimate interest in keeping you informed and in the outcome of our marketing campaigns. You can, of course, unsubscribe from receiving these messages at any time by using the link located within the emails themselves. You can also opt-out via the “Consent Settings” in your account; however, this means that you may miss out on interesting newsletters, workshops, and events, some of which are designed to help you develop your content and activity on our site.

3.7. Comply with any legal requirements and enforce our legal rights

We may rely on a legal obligation to process your personal data. For example, we must retain your transaction information to maintain legally required accounting records.

We may also use your information to respond to requests from competent authorities or given our legitimate interest to establish, exercise or defend legal claims. If necessary, we would use your data to investigate issues with the relevant bank processing your payment, or with a debt collector, in cases of unpaid transactions, chargebacks or refunds.

We may also combine your data with information lawfully obtained from other third-party sources, for the above purposes.

4. How do We Protect Your Personal Data?

We implement serious security measures, technical and organisational, to ensure the maximum protection possible of your personal information against unauthorized access, modification, disclosure or deletion.

We periodically test our IT systems, conduct sophisticated penetration tests and actively implement data loss prevention systems against leakage, theft and data breach to ensure that our site and entire IT infrastructure is regularly updated against the latest network security vulnerabilities.

5. HOW LONG DO WE RETAIN YOUR PERSONAL DATA?

5.1 Active Account Retention

We will retain your personal data for as long as we consider it necessary for:

Legal Obligation Compliance

For example, we may keep some of your information for tax, legal reporting and statutory obligations. Please note that in accordance with Luxembourg legislation, financial information (i.e. transaction information, including supporting documents like invoices) will be kept for a minimum period of 10 years (cf. Article 16 of the Luxembourg Commercial Code). It is the Company’s policy to destroy all documents after this minimum period has lapsed.

Legitimate Interests & Business Conduct

To enable us to provide you with the platform and for you to use it, including maintaining your Influencer/Agency Account and conducting our business, we keep all of your personal data for 10 years (cf. Article 189 of the Commercial Code). This only differs when different retention periods are specified to a particular set of data (e.g., some data which are subject to clause 6 “Intellectual Property” of the Services Agreement may be retained longer than 10 years).

By “conducting our business” and “legitimate business interests”, we mean the following:

  • Establishing, exercising or defending legal claims
  • Fraud detection and prevention
  • Hindering any other illegal activity on our site
  • Enhancing Safety

All of your personal information shall also be kept available in case of ongoing judicial proceedings and/or investigations.

Security

As we have said, the protection of your information and our site from accidental or malicious loss and destruction is one of our top priorities.

Residual copies of some of your personal data will be kept on our backup systems for 30 days.

5.2 Retention after Erasure of Account

Please note that even if you request the erasure of your personal information, in addition to the data we keep for legal obligation compliance and security (as specified above), we will retain some of your personal data for as long as we consider it necessary for the following reasons:

Our Legitimate Interests

Including:

Establishing, Exercising or Defending Legal Claims:

We will retain the following data for 10 years, which is the commercial prescription period in Article 189 of the Commercial Code of the Grand Duchy of Luxembourg:

  • Screen name
  • Full Name
  • Country/state
  • Nationality
  • Personal email address
  • Status (e.g. blocked)
  • Sign up date (UTC)
  • Agency name (if applicable)
  • Birth date
  • Influencer earnings

Fraud Detection & Prevention

We blacklist all former screen names for a certain period; these usernames will not be available for new registrations during that time.

If you had any fraudulent or illegal activity history with us, we will retain all of your personal information from 2 to 10 years (depending on your case) or more (in case of ongoing litigation).

This is based on business/management decision to keep the data for a period of 2 years in normal circumstances (i.e. in case of minor infractions). In very exceptional circumstances, the data may be kept longer than that, but this is in case of serious infractions such as murder, sex trafficking, rape, terrorism, etc. In these cases, the data is kept for 10 years.

Illegal Activity Detection

We keep unique identifiers (which cannot identify a data subject directly) relating to existing and former accounts, for an unlimited period of time. An illegal activity would be, for example, if you are in breach of the policy applicable to multiple accounts owners (i.e. the Agency-Fan Account Policy).

Enhancing Safety

For example, if we suspend or close your account due to fraud or illegal activities, we may retain certain information about you to prevent you from opening a new account in the future. Such information will also be kept available in case of ongoing judicial proceedings and/or investigations.

Support Staff Training

We keep your chat or other type of conversation you had with our Influencer Support team for 2 years. After this deadline the data is anonymised.


Some anonymized copies of your information (e.g. log records) may also remain in our database.

If you have a question about any specific retention periods of certain personal data, please contact us via the contact details provided in clause 10: “HOW TO CONTACT US?”

6. With Whom do We Share Your Data?

6.1. Fans

The data you use to complete your Influencer profile will be publicly visible to Fans, including:

  • Screen name
  • Interests

Please remember that you are in control of what you choose to put in your profile and you may also add or delete optional information about you, including any content on your “My Content” page.

Be assured that we will never publish any identification details about you, which would lead to Fans identifying your true identify (i.e. your full name, address, birthdate, etc.).

6.2. Entities of our company’s group

We share your personal information with the following companies of our group based in Luxembourg, Hungary and the US, as they are helping us deliver our service to Fans:

  • Jasmin IP S.à r.l., 44, Avenue John F. Kennedy, L-1855, Luxembourg, Grand Duchy of Luxembourg;
  • Docler Services S.à r.l., 44, Avenue John F. Kennedy, L-1855, Luxembourg, Grand Duchy of Luxembourg;
  • Docler IP S.à r.l., 44, Avenue John F. Kennedy, L-1855, Luxembourg, Grand Duchy of Luxembourg;
  • Docler SSC Kft, Expo tér 5-7, H-1101, Budapest, Hungary;
  • Jasmin IP S.à r.l. Hungary Branch, Expo tér 5-7, H-1101, Budapest, Hungary;
  • Docler Media LLC, 10811 Washington Blvd, Culver City, CA 90232, USA;
  • Escalion S.à r.l., 44, Avenue John F. Kennedy, L-1855, Luxembourg, Grand Duchy of Luxembourg.

6.3. Service providers

We use carefully selected and trusted third parties, who act as processors to our site.

We ensure that they are contractually obligated to process information we share with them in accordance with our instructions, this Privacy Policy, and all applicable data protection laws.

As we constantly work on the development and enhancement of the technology to support our site, our third party processors may regularly change.

Such entities mainly operate in the following areas:

  • Business intelligence and analytics
  • Marketing & Sales
  • Customer care
  • Fraud prevention

6.4. Payment Providers & Financial Institutions

For pay-out purposes, we may share certain information with a third party bank or payment processor.

You may receive transactional emails from this party confirming the payment, including dispatch and follow-up invitations to leave feedback for this party.

We may share information with relevant financial institutions if we consider it strictly necessary for fraud detection and prevention purposes.

This Privacy Policy does not govern the processing of your personal information by third parties if it was shared directly with them.

6.5. Law Enforcement Agencies & Governmental Authorities

To the extent permitted by applicable laws, we may also share information with law enforcement agencies or authorities, if such disclose is reasonably necessary for the following:

  • To comply with our legal obligations
  • Respond to information requests for fraud investigations and other alleged illegal activities
  • Enforce and administer our Terms and Conditions, Services Agreement & any other applicable policies
  • Protect our rights and defend ourselves against any claims

6.6. Business transfers

Your information may be transferred to another entity of our group (i.e. as a result of reorganisation, restructuring, etc.) or third party (i.e. as a result of sale, merger and/or acquisition, etc.) if part (more than 50%) or whole of the business (or related assets) is either directly or indirectly transferred under the control of the new owner.

This would be the case providing the new owner operates in the same or similar line of business as ours and commits to comply with this Privacy Policy.

7. How do We Transfer Your Personal Data Outside of the European Economic Area?

As we are a Luxembourg-based company, we comply with the EU Data Protection Regulation, “GDPR” (click here to learn more), which provides for a high level of protection of your personal data.

During the course of operation and exploitation of the site and provision of services, your personal information may be transferred outside of the European Economic Area (“EEA”) to our affiliated companies, or third party data processors, located in the US and other countries, for the purposes specified in this Privacy Policy.

If we transfer your personal data outside of the EEA, we endeavour to ensure that your rights and freedoms in respect of the processing of your personal data are adequately and appropriately protected. For this purpose, we utilize the Standard Contractual Clauses approved by the European Commission that you can find here.

Please note that regardless of where you live, your personal data will be protected by the GDPR as our business is located within the EEA.

8. What are Your Rights Regarding Your Personal Data?

8.1. Data Access

You have the right to access the personal information we hold about you. You can request a copy of your personal data, free of charge, through the “Data Download” section in your account settings.

Upon verification of your identity, your request will be sent to our Influencer Support team.

If we consider that your request is manifestly unfounded or excessive (e.g., due to multiple requests in a short period), we may refuse to act or charge a reasonable fee taking into account the administrative costs for providing you with the information.

8.2. Data Portability

Please note that the following is separate from the right to access your data.

In certain cases, you are entitled to request copies of your personal information in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).

For clarification, only the following information can be made available:

  • The data actively and knowing provided by you (e.g. email address, screen name, etc.)
  • The observed data provided by you by virtue of the use of the service or the device (e.g. traffic data, location, etc.)

You should keep this in mind when you delete your account or your account is terminated.

To exercise this right, you can send an email to privacy@jasmin.com.

8.3. Rectification of inaccurate or incomplete data

You have the right to request that we correct any inaccuracies in your personal data.

For this purpose, you can contact our Influencer Support team or send an email to privacy@jasmin.com.

8.4. Data Erasure

If you no longer want us to use your personal information, you can request that we erase it and close your account, requests for account cancellation or closure will be considered as a request for the erasure of your personal data.

To close your account, please click “Forget My Data” in the “Privacy Rights” section of your account settings. Your request will then be sent to our Support team who will contact you. However, if you face any difficulties please contact us at any time.

Please note that your request for the erasure of your personal data will be considered as a notice for termination of the Services Agreement.

Moreover, if your account is inactive for more than six (6) months, we have the right to terminate your account and proceed with the erasure of your data in accordance with our Services Agreement.

Please note that if you request the erasure of your personal information, we will retain some of it for as long as we consider it necessary for compliance with our legal obligations or other legitimate interests as explained above in clause 5.2: “Retention after Erasure of Account”.

8.5. Right to object

We process your data for a variety of reasons (see clause 3: “WHY DO WE PROCESS YOUR PERSONAL DATA?”).

Applicable law may entitle you to require us not to process your personal information for certain specific purposes where such processing is based on a legitimate interest. If you object to such processing, we will stop processing your personal data for those purposes.

In specific situations, we may have to refuse the execution of your request. This would only be in the cases where we have legitimate grounds to continue such processing or if we have to establish, exercise or defend legal claims.

Please keep in mind that objecting to certain uses of your data may disable the use of your account.

Please also remember that you may ask us, at any time, to stop sending you marketing emails by opting-out in your account settings.

8.6. Right to restriction of processing

You have the right to request that we stop processing your data, while we resolve any issues.

This is only possible in the following four cases:

Accuracy

If you contest the accuracy of your personal data, processing would be stopped while we verify your claim.

Legitimate Interest

If you object to a processing activity based on a legitimate interest, you can require the processing operation to be put on hold while we verify your grounds for objection.

Unlawful Processing

You can request the restriction of data process if you consider your data is being processed unlawfully, but do not wish for your data to be immediately erased.

Data Storage

You can request us to store your data, if you require it to establish, exercise or defend any legal claims, and we have no further need of it.


Despite your request, we may continue to process your data, if we have to establish, exercise or defend legal claims. We will notify you before lifting any restriction.

8.7. Right to lodge a complaint with a supervisory authority

If you consider that our processing of your personal data infringes the GDPR or any other applicable national laws, you have the right to lodge a complaint with the relevant supervisory authority (i.e. your local authority or the CNPD).

9. Changes to Our Privacy Policy

We may occasionally amend this Privacy Policy to reflect changes to our services and the way we are handling your personal data or changes in applicable laws.

If we make any important changes, we will let you know by placing a notice on the relevant site and/or contact you directly, using other methods such as email.

To the extent permitted by applicable law, such changes will be applicable from the time they are published on our site, unless we specify a date of entry into force. Your continued use of our site from that day on would be subject to the new Privacy Policy.

10. How to Contact Us?

If you have any comments or questions about this privacy policy or generally about our privacy practices, please send an email to privacy@jasmin.com or by mail to the address indicated below, and we will get back to you as soon as possible.

Duodecad IT Services Luxembourg S.à r.l.
44, Avenue John F. Kennedy
L-1855, Luxembourg
Grand Duchy of Luxembourg

We are happy to inform you that we have an employee dedicated to ensuring your privacy, our Data Protection Officer. You can directly reach our Data Protection Officer via email at dpo@jasmin.com or by mail at the following address:

To the attention of the DPO
Duodecad IT Services Luxembourg S.à r.l.
44, Avenue John F. Kennedy
L-1855, Luxembourg
Grand Duchy of Luxembourg