Joovv Privacy Policy

Last updated: 6/17/2026

Joovv, Inc. (“Joovv,” “we,” “us,” or “our”) offers medical-grade red light therapy devices designed for home and professional use. This Privacy Policy describes how Joovv processes personal information that we collect through our digital and online properties or services that link to this Privacy Policy (including as applicable, our website, member platform, mobile app, electronic communications, and social media pages) as well as our marketing activities, live events, and other activities described in this Privacy Policy (collectively, the “Service”). This Privacy Policy does not apply to our employees or independent contractors or job candidates. 

US Residents: Please see the U.S. State Privacy Rights Notice at Collection section of this Privacy Policy for additional information if you are a U.S. resident.

European Users: Please see the Notice to European Users section below for additional information for individuals located in the European Economic Area or United Kingdom (which we refer to as “Europe,” and “European” should be understood accordingly). 

Table of Contents

  • Personal information we collect
  • Tracking technologies
  • How we use your personal information
  • How we share your personal information
  • Your choices
  • Advertising choices
  • Other sites and services
  • Security
  • International data transfers
  • Children and teens
  • Changes to this privacy policy
  • How to contact us
  • U.S. State Privacy Rights Notice at Collection
  • Notice to European users

Personal information we collect

Information you provide to us. Personal information you may provide to us includes:

  • Contact data, such as your first and last name, alias, salutation, email address, billing and mailing addresses, and phone number.

  • Demographic data, such as your city, state, country of residence, and postal code.

  • Profile data, such as the username and password that you may set to establish an online account on the Service, preferences, and any other information that you add to your account profile.  

  • Transactional data, such as information relating to or needed to complete your orders on or through the Service, including order numbers and transaction history. This includes purchase considerations, consuming history and tendencies. 

  • Payment data needed to complete transactions, including payment card information or bank account number. We use a third-party vendor to directly collect and process your payment card information, as described further below.

  • Communications data based on our exchanges with you, including when you contact us through the Service, communicate with us via email, phone, chat features, social media, or otherwise. 

  • Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.

  • Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources. We may combine personal information we receive from you with personal information of the kinds identified above that we obtain from other sources, such as:

  • Service providers that provide services on our behalf or help us operate the Service or our business.
  • Partners, such as joint marketing partners and event co-sponsors.
  • Ad networks
  • Data analytics providers
  • Social media platforms

Automatic data collection. We, our service providers, and our advertising partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

  • Device data, such as your browser type, device type (e.g., phone, tablet), and IP address.

  • General location data, such as your city, state, or geographic area, which is inferred from your IP address.

  • Communication interaction data such as your interactions with our email, text, chat or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails enabling us to detect if you have opened or forwarded a message. 

  • Online activity data, such as pages or screens you viewed, search history, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.

Tracking technologies. Some of our automatic collection is facilitated by the cookies and similar technologies. For more information, see our Cookie Policy. We will also store a record of your preferences in respect of the use of these technologies in connection with the Service.

How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and operations. We may use your personal information to:

  • provide and operate the Service;
  • process your requests, orders and transactions;
  • enable security features of the Service;
  • establish and maintain your user profile on the Service;
  • communicate with you about the Service, including by sending Service-related announcements, updates, and support and administrative messages;
  • communicate with you about events for which you register;
  • provide support for the Service, and respond to your requests, questions and feedback;
  • collect and share user product reviews; and 
  • fraud prevention and security.

Service personalization, which may include using your personal information to:

  • personalize the service, including remembering the devices from which you have previously logged in and remembering your selections and preferences as you navigate the Service; and

  • remember your selections and preferences as you navigate webpages.

Service improvement and analytics. We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services.

Marketing and advertising. We and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:

  • Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of marketing section.  

  • Interest-based advertising. We and our third-party advertising partners may use cookies, pixels and other technologies to collect information about your interaction (including the data described in the Automatic Data Collection section above) with the Service, our communications and other third party online services over time, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online properties. You can learn more about your choices for limiting interest-based advertising in the Your choices section. 

Events, promotions, and contests. We may use your personal information to administer promotions and contests, communicate with you about events in which you participate, or contact or market to you after collecting your personal information at an event.

Compliance and protection. We may use your personal information to:

  • comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, court orders, investigations or requests from government authorities;
  • protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); 
  • audit our internal processes for compliance with legal and contractual requirements or our internal policies; 
  • enforce the terms and conditions that govern the Service; and 
  • prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.  

To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business. 

Further uses, in some cases, we may use your personal information for further uses, in which case we will ask for your consent to use of your personal information for those further purposes if they are not compatible with the initial purpose for which information was collected.

How we share your personal information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.  

Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, internet service providers, information technology, order fulfillment, customer support, online chat functionality providers, email delivery, marketing, consumer research and website/data analytics). 

Payment processors. Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processors, such as PayPal. PayPal may use your payment data in accordance with its privacy policy, available at https://www.paypal.com/us/legalhub/paypal/privacy-full.

Advertising partners / ad networks. Third-party advertising companies for the interest-based advertising purposes described above. 

Social networks. We use their ad services to display ads to our customers, or other people like them, on social media.

Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties in litigation, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above. 

Corporate transactions. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in Joovv, financing of Joovv, public stock offerings, the sale, transfer or merger of all or part of our business, assets or shares, liquidation or reorganization). For example, we may need to share certain personal information with prospective counterparties and their advisers. We may disclose your personal information to an acquirer, successor, or assignee of Joovv or a portion of our business assets as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

Third-party data safeguards. We make commercially reasonable efforts to verify that the parties with whom our mobile application shares personal information provide a level of protection of personal information consistent with the practices described in this Privacy Policy, except that all such parties described above other than service providers and affiliates may, to the extent permitted by law, use personal information as described in their own privacy policies.

Your choices 

In this section, we describe the choices available to you.

Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account and navigating to your account profile and settings. 

Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. It may take time for your opt-out to be effective. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails. 

Cookies. For more information about cookies and similar technologies employed by the Service and how to manage your preferences, see our Cookie Policy.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Retention period for personal information. We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, including Sensitive Personal Information, we may consider factors such as the length of time we have an ongoing relationship with you and provide services to you; the amount, nature, and sensitivity of the personal information; the potential risk of harm from unauthorized use or disclosure of your personal information; the purposes for which we process your personal information and whether we can achieve those purposes through other means; whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); whether retention is advisable in light of our legal position, such as in regard to applicable statutes of limitations, litigation or regulatory investigations; and applicable legal requirements. For example, we will retain your personal information for as long as you have an account with us or keep using our services, and the length of time thereafter during which we may have a legitimate need to reference your personal information to address issues that may arise. When we no longer require the personal information we have collected about you, we may either delete it or de-identify it. 

Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security 

We employ technical, organizational and physical safeguards that are designed to protect the personal information we collect. However, security risk is inherent in all Internet and information technologies, and we cannot guarantee the security of your personal information.

International data transfers

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country. Users in Europe should read the information provided below about the transfer of personal information outside of Europe.

Children and teens  

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a minor from whom you believe we have collected personal information in a manner prohibited by law, or if information was provided on your behalf when you were under 18, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information. 

Changes to this Privacy Policy 

The “LAST UPDATED” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. We reserve the right to modify this Privacy Policy at any time. We will notify you by updating the “Last Updated” date. Depending on the kind of change we make, we may also notify you directly or ask for your consent to the change. Any modifications to this Privacy Policy will be effective upon our posting the modified version or as otherwise indicated at the time of posting. 

How to contact us

U.S. State Privacy Rights Notice at Collection

Except as otherwise provided, this section applies to residents of California and other states to the extent they have privacy laws applicable to us that grant their residents the rights described below (collectively the “State Privacy Laws”).

This State Privacy Rights Notice at Collection is part of our full Privacy Policy

This section describes how we collect, retain, use, disclose, sell and share for the purposes of targeted advertising personal information of residents of these states and the rights these users may have with respect to their personal information. Please note that not all rights listed below may be afforded to all individuals and that if your state does not afford you these rights, you may not be able to exercise these rights. In addition, we may not be able to process your access, correction or deletion request if you do not provide us with sufficient detail to allow us to confirm your identity and understand and respond to your request.

For purposes of this section, the term personal information means information that relates to an identified or identifiable natural person, or that is reasonably capable of being used to identify, contact, or precisely locate a natural person, household, or a particular computing system or device. 

We do not attempt to reidentify deidentified information derived from personal information, except for the purpose of testing whether our deidentification processes comply with applicable law. 

Your privacy rights. You may request to exercise the rights listed below. We will respond to your request in accordance with applicable law. We may decline to honor your request where an exception applies.

  • Right to know. You can request to know whether we process your personal information. You can also request the following information about how we have collected and used your personal information during the past 12 months and how we will continue to do so:

    • The categories of personal information that we have collected.
    • The categories of sources from which we collected personal information.
    • The business or commercial purpose for collecting, selling, and/or sharing personal information for targeted advertising purposes.
    • The categories of personal information that we sold or shared for targeted advertising purposes, and the categories of third parties to whom this information was sold or shared, categorized by the type of personal information for each type of third party.
    • The categories of personal information that we disclosed for business purposes and the types of entities to whom this information was disclosed.
    • The specific third parties to which we have disclosed personal information.
  • Access. You can request a portable copy or representative summary of the personal information that we have collected about you. 

  • Correction. You can ask us to correct inaccurate personal information that we have collected about you.

  • Deletion. You can ask us to delete the personal information that we have collected from or about you.

  • Revoke consent. You may have the right to revoke your consent to our processing of your personal information.

  • Opt-out.

    • Opt-out of targeted advertising. We process personal information for targeted advertising purposes. You can opt out of the use of your personal information for targeted advertising purposes. 

    • Opt-out of sale of your Personal Information. We sell personal information. You can opt out of our sale of your personal information. 

    • Automated decision making. We do not use your personal information to engage in automated processing or profiling personal information to evaluate, analyze, or predict personal aspects related to your economic situation, health, personal preferences, interests, reliability, behavior, location, or movements to make a decision that produces legal or similarly significant effects.

  • Sensitive Personal Information

    • California Residents: Limit processing of Sensitive Personal Information. We do not collect or process Sensitive Personal Information. 

  • Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the State Privacy Laws.  

Exercising your right to know, access, correction, and deletion. You may submit requests via email to help@joovv.com.  

We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

Exercising your right to opt-out of/revoke your consent to the “sale” of your personal information or “sharing” of your personal information for targeted advertising purposes. You can submit requests to opt-out of targeted advertising and other sales of personal information here: https://joovv.com/pages/data-sharing-opt-out , via email to help@joovv.com or by broadcasting the Global Privacy Control signal. For information about how to use the Global Privacy Control, please visit https://globalprivacycontrol.org/. These signals set your opt-out preferences only for the particular browser or device you are using and any consumer profile that we associate with that browser or device unless you are logged into your account, in which case we will honor the signal with respect to that browser or device and your account, including your offline consumer profile associated with that account. If you wish to set your opt-out preferences for offline uses of your personal information and you are not logged into your Company account, please email help@joovv.com. 

Verification of Identity; Authorized agents. We may need to verify your identity to process your know, access, correction, deletion, or appeal requests and reserve the right to confirm your residency. We may need to request you to provide government identification, a declaration under penalty of perjury, or other information, where permitted by law, in order to verify your identity and protect against fraudulent requests. If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to reauthenticate yourself before disclosing or deleting your personal information. If you make a request to delete, we may ask you to confirm your request before we delete your personal information. 

Under some State Privacy Laws, you may enable an authorized agent to make a request on your behalf. However, we may need to verify your authorized agent’s identity and authority to act on your behalf. Depending on the kind of request you have made, we may require a copy of a valid power of attorney given to your authorized agent pursuant to applicable law. If you have not provided your agent with such a power of attorney, we may ask you to take additional steps permitted by law to verify that your request is authorized, such as by providing your agent with written and signed permission to exercise your State Privacy Law rights on your behalf, the information we request to verify your identity, or confirmation that you have given the authorized agent permission to submit the request.

Personal information that we collect, use and disclose. We have summarized the personal information we collect and may disclose, sell to or share with third parties by reference below to both the categories of personal information defined in the “Personal Information we collect,” “How we use your personal information,” and “How we share your personal information” sections of this Policy above and the categories of personal information specified in state law. This table describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described below.

See our full Privacy Policy for descriptions of each entry in this table. 

Personal Information (“PI”) we collect

California  statutory category of PI

Business/commercial purpose for PI collection

Categories of service providers and contractors to whom we “disclose” PI for a business purpose

Categories of third parties with whom we “share” PI for cross-context behavioral advertising purposes 

Categories of third parties to whom we “sell” PI

Contact data

Identifiers

Customer records

Service delivery and operations

Service personalization

Direct marketing

Interest-based advertising

Compliance and protection

Analytics

Corporate transactions

Service providers

Payment processors

Ad partners/networks

Social media platforms

Third parties designated by you

Professional advisors

Authorities

Counterparties and advisors/professionals in corporate transactions



Ad partners/networks

Social media platforms

N/A

Demographic data

Identifiers

Customer records


Service delivery and operations

Service personalization

Direct marketing

Interest-based advertising

Compliance and protection

Analytics

Corporate transactions

Ad partners/networks

Social media platforms

N/A

Profile data

Identifiers

Customer records

Internet activity


Service delivery and operations

Service personalization

Direct marketing

Interest-based advertising

Compliance and protection

Analytics

Corporate transactions

Ad partners/networks

Social media platforms

N/A

Transactional data

Identifiers

Customer records

Commercial information

Internet activity


Service delivery and operations

Direct marketing

Interest-based advertising

Compliance and protection

Analytics

Corporate transactions

Ad partners/networks

Social media platforms

N/A

Payment data

Identifiers

Customer records

Service delivery and operations

Corporate transactions


N/A

Communications data

Identifiers

Customer records

Commercial information

Internet activity

Service delivery and operations

Direct marketing

Interest-based advertising

Compliance and protection

Analytics

Corporate transactions

Ad partners/networks

Social media platforms

N/A

Marketing data

Identifiers

Customer records

Commercial information

Internet activity

Inferences

Service delivery and operations

Service personalization

Direct marketing

Interest-based advertising

Compliance and protection

Analytics

Corporate transactions

Ad partners/networks

Social media platforms

N/A

Device data

Identifiers

Internet activity


Service delivery and operations

Service personalization

Direct marketing

Interest-based advertising

Compliance and protection

Analytics

Corporate transactions

Ad partners/networks

Social media platforms

N/A

Communication interaction data

Commercial information

Internet activity


Service delivery and operations

Service personalization

Direct marketing

Interest-based advertising

Compliance and protection

Analytics

Corporate transactions

Ad partners/networks

Social media platforms

N/A

Online activity data

Commercial information

Internet activity

Service delivery and operations

Service personalization

Direct marketing

Interest-based advertising

Compliance and protection

Analytics

Corporate transactions

Ad partners/networks

Social media platforms

N/A

Inferences from the above kinds of personal information

Inferences

Service delivery and operations

Service personalization

Direct marketing

Interest-based advertising

Compliance and protection

Analytics

Corporate transactions

Ad partners/networks

Social media platforms

N/A


Consumers under 18. We do not have actual knowledge that we have collected, sold, or shared the personal information of residents who are under 18 years of age.

Retention Period for Personal Information. We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, including Sensitive Personal Information, we may consider factors such as the length of time we have an ongoing relationship with you and provide services to you; the amount, nature, and sensitivity of the personal information; the potential risk of harm from unauthorized use or disclosure of your personal information; the purposes for which we process your personal information and whether we can achieve those purposes through other means; whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); whether retention is advisable in light of our legal position, such as in regard to applicable statutes of limitations, litigation or regulatory investigations; and applicable legal requirements. For example, we will retain your personal information for as long as you have an account with us or keep using our services, and the length of time thereafter during which we may have a legitimate need to reference your personal information to address issues that may arise. When we no longer require the personal information we have collected about you, we may either delete it or de-identify it. 

Contact Us. If you have questions or concerns about our privacy policies or information practices, please contact us using the contact details set forth in the How to contact us section, above.

Notice to European users

General

Where this Notice to European users applies. The information provided in this ‘Notice to European users’ section applies only to individuals located in the European Economic Area (EEA) or United Kingdom (UK) (i.e., “Europe” as defined at the top of this Privacy Policy).

Personal information. References to “personal information” in this Privacy Policy should be understood to include a reference to “personal data” as defined in the “GDPR” (i.e., the General Data Protection Regulation 2016/679 (“EU GDPR”)) and the EU GDPR as it forms part of the laws of the United Kingdom (“UK GDPR”) Under the GDPR, “personal data” means information about individuals from which they are either directly identified or can be identified. The personal information that we collect from and about you is described in greater detail in the section “Personal Information we collect” that is set out above.

Controller. Joovv is the controller in respect of the processing of your personal information covered by this Privacy Policy for purposes of GDPR). See the ‘How to contact us’ section above for our contact details.

Our GDPR Representatives. We have appointed the following representatives in Europe as required by the GDPR – you can also contact them directly should you wish:

Our Representative in the EU. Our EU representative appointed under the EU GDPR is EDPO. You can contact them:

Our Representative in the UK. Our UK representative appointed under the UK GDPR is EDPO. You can contact them:


Our legal bases for processing 

In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a “legal basis” for that use. 

Our legal bases for processing your personal information described in this Privacy Policy are listed below.

  • Where we need to perform a contract, we are about to enter into or have entered into with you (“Contractual Necessity”).

  • Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your personal information for is set out in the table below.

  • Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).

  • Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”). 

We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your personal information – for more information on these Purposes and the data types involved, see ‘How we use your personal information’ and the description of associated data sharing relevant to such purposes set out in the ‘How we share your personal information’ section also above.

Purpose

Categories of personal information involved


Legal basis

Service delivery and operations

  • Contact data

  • Demographic data

  • Profile data

  • Communications data

  • Transactional data

  • Payment data

  • Data from Third-Party Sources.

  • Device data

  • Contractual Necessity

  • Legitimate Interests. We have a legitimate interest in ensuring the ongoing security and proper operation of our Service (including, where relevant, responding to any contact via any “contact us” feature or similar), our business and associated IT services, systems and networks.

Service personalization 

  • Demographic data 

  • Profile data

  • Data from Third-Party Sources.

  • Device data


  • Legitimate Interests. We have a legitimate interest in providing you with a good service via the Service, which is personalized to you and that remembers your selections and preferences.

  • Consent, in respect of any optional processing relevant to personalization (including processing directly associated with any optional cookies used for this purpose).

Service improvement and analytics

  • Contact data

  • Demographic data

  • Profile data

  • Communications data

  • Transactional data

  • Data from Third Party Sources

  • Device data

  • Online activity data

  • Communication interaction data

  • Legitimate Interests. We have a legitimate interest in providing you with a good service and analysing how you use it so that we can improve it over time, as well as developing and growing our business.

  • Consent, in respect of any optional cookies used for this purpose.

Direct marketing

  • Contact data

  • Demographic data

  • Profile data

  • Marketing data

  • Data from Third Party Sources

  • Legitimate Interests. We have a legitimate interest in promoting our operations and goals as an organization and sending marketing communications for that purpose.

  • Consent, in circumstances or in jurisdictions where consent is required under applicable data protection laws to the sending of any given marketing communications.

Interest-based advertising

  • Device data

  • Online activity data

  • Data from third-party Sources

  • Consent

Events, promotions and contests

  • Contact data

  • Demographic data

  • Profile data

  • Data from third-party Sources

  • Contractual Necessity, to administer events in accordance with the terms or rules thereof (including communicating with you as and where necessary).


  • In respect of promoting these events: 

    • Legitimate Interests – we have a legitimate interest in promoting these events, including associated publicising of our business and operations. 

    • Consent – in circumstances or in jurisdictions where consent is required under applicable data protection laws to the sending of any given promotional communications.

Compliance and protection

  • Any and all data types relevant in the circumstances

  • Compliance with Law.

  • Legitimate Interests. Where Compliance with Law is not applicable, we have a legitimate interest in participating in, supporting, and following legal process and requests, including through co-operation with authorities. We may also have a legitimate interest of ensuring the protection, maintenance, and enforcement of our rights, property, and/or safety.

Data sharing in the context of corporate events

  • Any and all data types relevant in the circumstances

  • Legitimate Interests. We have a legitimate interest in providing information to relevant third parties who are involved in an actual or prospective corporate event (including to enable them to investigate – and, where relevant, to continue to operate – all or relevant part(s) of our operations).

To create aggregated, de-identified and/or anonymized data

  • Any and all data types relevant in the circumstances

  • Legitimate Interests. We have legitimate interest in taking steps to preserve the privacy of our users.

Further uses 

  • Any and all data types relevant in the circumstances

  • The original legal basis relied upon, if the relevant further use is compatible with the initial purpose for which the personal information was collected. 

  • Consent, if the relevant further use is not compatible with the initial purpose for which the personal information was collected.


Other information

No obligation to provide personal information. You do not have to provide personal information to us. However, where we need to process your personal information either to comply with applicable law or to deliver our Service to you, and you fail to provide that personal information when requested, we may not be able to provide some or all of our Service to you. We will notify you if this is the case at the time.

No sensitive information. We ask that you not provide us with any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership, or biometric or genetics characteristic other than as requested by us as part of the Service) on or through the Service, or otherwise to us. If you provide us with any such sensitive personal information to us when you use the Service, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our Service.

No automated decision-making and profiling. As part of the Service, we do not engage in automated decision-making and/or profiling, which produces legal or similarly significant effects. 

Your additional rights

General. European data protection laws may give you certain rights regarding your personal information in certain circumstances. If you are located in Europe, you may ask us to take the following actions in relation to your personal information that we hold:

  • Access. Provide you with information about our processing of your personal information and give you access to your personal information.

  • Correct. Update or correct inaccuracies in your personal information.

  • Delete. Delete your personal information where there is no good reason for us continuing to process it - you also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below). 

  • Transfer. Transfer to you or a third party of your choice a machine-readable copy of your personal information which you have provided to us.

  • Restrict. Restrict the processing of your personal information, for example if you want us to establish its accuracy or the reason for processing it.

  • Object. Object to our processing of your personal information where we are relying on Legitimate Interests – you also have the right to object where we are processing your personal information for direct marketing purposes.

  • Withdraw Consent. When we use your personal information based on your consent, you have the right to withdraw that consent at any time.

Exercising These Rights. You may submit these requests by email to help@joovv.com or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information), if we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions. Typically, you will not have to pay a fee to exercise your rights; however, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We try to respond to all legitimate requests within a month of receipt. It may take us longer than a month if your request is particularly complex or if you have made a number of requests; in this case, we will notify you and keep you updated.

Your Right to Lodge a Complaint with your Supervisory Authority. Although we urge you to contact us first to find a solution for any concern you may have, in addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence. 

Data Processing outside Europe

We are a U.S.-based company and many of our service providers, advisers, partners or other recipients of data are also based in the U.S. This means that, if you use the Service, your personal information will necessarily be accessed and processed in the U.S. It may also be provided to recipients in other countries outside Europe.  

Where we share your personal information with third parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it by making sure one of the following mechanisms is implemented: 

  • Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the European Commission or UK Government (as and where applicable) (from time to time) or under specific adequacy frameworks approved by the European Commission or UK Government (as and where applicable) (from time to time), such as the EU-U.S. Data Privacy Framework or the UK Extension thereto.

  • Transfers to territories without an adequacy decision. 

    • we may use specific appropriate safeguards, which are designed to give personal information effectively the same protection it has in Europe – for example, standard-form contracts approved by relevant authorities for this purpose; or 

    • in limited circumstances, we may rely on an exception, or ‘derogation’, which permits us to transfer your personal information to such country despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your explicit consent to that transfer. 

    • We may transfer your personal information to countries or territories whose laws have not been deemed to provide such an adequate level of protection (e.g., the U.S.).  

    • However, in these cases:

You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe by contacting us at help@joovv.com.

 JV-MKT-DOC-10485 VER.1