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Jimdo – Privacy Policy for the Jimdo Co-Pilot program

As part of Jimdo’s all-in-one solution for the self employed, Jimdo offers various Business Plans that include certain services, e.g. a personal introduction to the purchased product portfolio or information sessions on optimal website design, collectively referred to as  "Co-Pilot Program Services”.  Jimdo GmbH, Stresemannstr. 375, 22761 Hamburg, Germany ("Jimdo" or "We") is the responsible data controller under data protection law as regards the personal data processed via the Co-Pilot Program Services. This Privacy Policy explains how we process your personal data when you, the founder, use these Co-Pilot Program Services.

You can find information about how your personal data is processed as a customer of Jimdo in conjunction with your usage of Jimdo's online services in the Jimdo Privacy Information.

1. Contact information

1.1 Contact information for Jimdo GmbH

Should you have any questions regarding this Privacy Policy or wish to assert your legal rights, you are welcome to contact our data protection experts at the following email address or by post to the following address:

Jimdo GmbH
Stresemannstraße 375
22761 Hamburg
privacy@jimdo.com

1.2 Contact details of the Jimdo data protection officer

Jimdo has appointed a Data Protection Officer who can be reached at the following address:

B³ | Informationstechnologie
Papenbergallee 34 25548 Kellinghusen
privacy@jimdo.com

2. Processing activities

In this Privacy Policy we provide you with information about the processing of personal data by Jimdo within the scope of the Co-Pilot Program Services, the purposes and legal basis for processing the data, as well as the categories of data and the categories of recipients. You can find the definitions of the individual terms used in this text in Section 6 of this Privacy Policy.

2.1 Use of the Jimdo Co-Pilot Services

Jimdo uses the personal data you provide via the use of Jimdo’s all-in-one solution for the self employed, first and foremost to fulfil the contract with you, and to provide our Co-Pilot Program Services (Art. 6 (1) (b) GDPR). This involves the following processing activities:

2.1.1. Questionnaires

Jimdo collects your contact data via the questionnaires relating to Jimdo’s all-in-one solution for the self-employed. These questionnaires enable you to initiate contact with Jimdo and/or select an appointment for Co-Pilot Program Services. 

We process Contact Data, language selection and with some Co-Pilot Program Services, Founder Data is also collected. Processing is carried out to prepare and implement our contractual obligations (Art. 6 (1) (b) GDPR). We transfer personal data to the following categories of recipients as part of this processing: server hosting provider, questionnaire provider, service provider for sending emails, service provider for documents. We transfer personal data to processors in the USA for these purposes. You can find information about the transfer of personal data to third countries in Section 3. Information about the length of time for which the various categories of personal data are stored can be found in Section 4.

2.1.2. Founder Coaching 

Jimdo forwards the relevant contact details to the founder coach in order to enable the coaching sessions with the founder coach. Jimdo, as the data controller, is responsible  for processing the feedback given by you, the founder and the founder coach. The founder coach is responsible under data protection law for conducting the founders coaching and transferring the feedback about the conducted founders coaching to Jimdo. Jimdo has entered into a corresponding agreement with the founder coaches, who will inform you as and if necessary, as to their data processing via their individual privacy policies. 

We process Contact Data, language selection, Founder Data and Founder Coaching Data. Processing is carried out to prepare and implement our contractual obligations (Art. 6 (1) (b) GDPR), specifically for the purpose of preparing, conducting, and evaluating the founders' coaching.  With regard to the Founder Coaching Data, the processing is carried out on the basis of our legitimate interest in improving the Jimdo Founders Coaching. We transfer personal data to the following categories of recipients as part of this processing: founders coach, server hosting provider, questionnaire provider, video conferencing provider, online appointment scheduling provider or calendar, service provider for sending emails. We transfer personal data to processors in the USA for these purposes. You can find information about the transfer of personal data to third countries in Section 3. Information about the length of time for which the various categories of personal data are stored can be found in Section 4.

2.1.3. Co-Pilot Program Sessions

In order to provide the individual Co-Pilot Program Services, as described within the Jimdo’s all-in-one solutions for the self employed, Jimdo collects and processes your data. In order to provide you with a comprehensive session, Jimdo will also analyze and utilize existing data where applicable, pertaining to your use of the Jimdo online service as described in the Jimdo Privacy Information.

Depending on the Co-Pilot Program Service booked, different categories of personal data may be processed. These can be for example Contact Data, Founder Data, Design Data, Web Analysis Data, Event Data, Session Data Newsletter Data, Marketing Data and Jimdo Online Service Data. Processing is carried out to prepare and implement our contractual obligations (Art. 6 (1) (b) GDPR). The scope and type of data processed is determined by you within the scope of the booked session and the information provided. We transfer personal data to the following categories of recipients as part of this processing: server hosting provider, questionnaire provider, service provider for sending emails, service provider for documents, service provider for event analysis. We transfer personal data to processors in the USA for these purposes. You can find information about the transfer of personal data to third countries in Section 3. Information about the length of time for which the various categories of personal data are stored can be found in Section 4.

2.1.4. Co-Browsing

In some Co-Pilot Program sessions, at Jimdo’s discretion, we may offer the option of temporarily sharing your browser window with a Jimdo Expert on a limited basis. When you initiate co-browsing you are stating that you agree to this. The Jimdo Expert will have read permissions only. You can end the co-browsing session at any time. We do not collect or store any data from your browser screen. We save the data about the session once co-browsing has finished to avoid misuse.

To do this we process Session Data. The legal basis for processing the data is fulfilling the contract concluded with you in accordance with Art. 6 (1) (b) GDPR, or our legitimate interest in improving our support services and preventing misuse (Art. 6 (1) (f) GDPR). We transfer your data to the following categories of recipients as part of this processing: Co-browsing providers. We transfer your personal data to processors in the USA for these purposes. You can find information about the transfer of personal data to third countries in Section 3. Information about the length of time for which the various categories of personal data are stored can be found in Section 4.

2.1.5. Surveys about our Co-Pilot Program Services

You have the option to answer surveys about our Co-Pilot Program Services. These surveys allow us to improve and optimize Jimdo’s all-in-one solution for the self employed. We may also invite you to take part in such surveys by email.

To do this we process Contact Data, Survey Data and HTTP Data. The legal basis for processing is our legitimate interest in improving our services (Art. 6 (1) (f) GDPR). If you no longer wish to receive such requests you can unsubscribe at any time via clicking on the unsubscribe link at the bottom of the email. We also analyze the queries dealt with by our Customer Support team to improve our customer support. We transfer your data to the following categories of recipients as part of this processing: Survey providers. We transfer your personal data to processors in the USA for these purposes. You can find information about the transfer of personal data to third countries in Section 3. Information about the length of time for which the various categories of personal data are stored can be found in Section 4.

3. Data transmission to third countries

Jimdo ensures that wherever possible your data is processed in the EU or in the European Economic Area. If data transfer to a third country is necessary due to the use of certain services from providers in third countries, Jimdo will ensure, after prior review, that an adequate level of data protection that meets the requirements of the Court of Justice of the European Union and the EU Commission is adhered to in the country the data is transferred to. In these cases, the data is transferred on the basis of an Adequacy Decision of the European Commission or the Standard Contractual Clauses for the transmission of personal data to third countries in its current valid version. These can be accessed here. We regularly reassess the measures we have taken to assess the requirements arising from new regulatory guidance and case law. If data is transferred to a third country on the basis of your explicit consent, we will inform you of this separately.

4. Retention Periods

Insofar as we receive and process your personal data for the purposes of implementing, initiating, and processing your contract with Jimdo, we store it until the purpose of storage has been achieved (in particular achieved in the event of the contract being terminated), or insofar as this is required within the statutory retention periods in accordance with section 257 of the German Commercial Code (HGB) and section 147 of the German Tax Code (AO) and/ or any other applicable legislation.

5. Information about your rights

As the data subject you have the following rights with regard to the processing of your personal data by Jimdo, in the event of the respective legal requirements:

  • Right of access (Art. 15 GDPR)
  • Right to rectification (Art. 16 GDPR)
  • Right to erasure (“right to be forgotten”) (Art. 17 GDPR)
  • Right to restriction of processing (Art. 18 GDPR)
  • Right to data portability (Art. 20 GDPR)
  • Right to object (Art. 21 GDPR)
  • Right to withdraw consent (Art. 7 (3) GDPR)
  • Right to lodge a complaint with a supervisory authority (Art. 77 GDPR)

You will find specific information on exercising these rights in Section 5 of the Jimdo Privacy Information.

6. Definitions

The terminology used in this Privacy Policy generally has the meaning given in the General Data Protection Regulation. We also use other terms which we explain below, along with the most important terminology from the General Data Protection Regulation:

  • “Contact Data” means initial data you provide to us via questionnaires to enable us and/or the founder coach to contact you and arrange the provision of the Co-Pilot Program Services. This includes your name, email address, (optional) telephone number.
  • “Design Data” refers to the design of your website. This includes the Jimdo template used, color scheme, images used, font etc. 
  • “Event data” means data which is collected by the web analysis tool referencing the unique visitor ID of the respective visitor contained in the device’s data. This includes actions that take place on the website which are called “events”. For example, this includes making a purchase, registering, adding payment information, commencing the order finalization process, adding items to your cart, adding items to your wish list, carrying out searches, and considering content. This also includes information associated with the actions that are carried out and are referred to as “parameters”. This includes, for example, the value of purchases made.
  • “Feedback Data'' refers to data optionally provided by the founder regarding the Co-Pilot Program Services, their provision, their experience with Jimdo’s all-in-one solution for the self employed. 
  • “Founder Data” means data that describes the current status and phase of your self employment, the industry your business operates in etc.
  • “Founder Coaching Data” refers to all of the questions posed and feedback received and provided during the founder coaching sessions. 
  • “HTTP data” means protocol data that has arisen by design when accessing the website via the Hypertext Transfer Protocol (Secure) (HTTP(S)). This includes your IP address, type, and version of your Internet browser, the operating system you used, the page you accessed, the page you accessed before our website (referrer URL), as well as the date and time of your visit.
  • “Jimdo Online Service Data” means any data pertaining to Jimdo’s provision of Online Services to the founder, as described in the Jimdo Platform Privacy Policy. For example the progress you make on your website, the Jimdo products you use etc.
  • “Newsletter Data” means data pertaining to your newsletters, amount and type of subscribers, success and other rates and any other available newsletter data that you choose to share with us to enable the customer reach analysis. 
  • “Marketing Data” refers to any marketing campaign data that you decide to share with us to enable the customer reach session, such as details of your last marketing campaign if any, channels used, customers reached, learnings, etc. 
  • “Session Data” means data that we have collected from the co-browsing session. This includes a unique session ID for your contact session as well as the IP address, date, and time of the session, operating system, and browser.
  • “Web Analysis Data” means data which is generated by the web analysis software and stored in pseudonymized user profiles. This includes information about the use of the website, in particular pages accessed, frequency of access and time spent on the accessed pages referencing the unique visitor ID of the respective visitor, which is contained in the device’s data.

7. Version and changes to this Privacy Policy

Valid from: 09.01.2024.

It may be necessary to make adjustments to or further develop our Co-Pilot Program Services due to technical developments and/or changes to the law. As a result, we will update this Privacy Policy as required. The current valid version of our Privacy Policy can be accessed at any time in the version published on our website.