Effective starting: September 25th, 2023

Your privacy is important to us, and so is being transparent about how we collect, use, access, process on behalf of another party, transfer, and/or store and/or retain personal information we process through Jellyfish’s websites, social media channels, and through your use or access to our products and/or services. 

This Privacy Notice describes the types of personal information that Orthogonal Networks, Inc. (d/b/a Jellyfish) and its affiliates and assigns (“Company” “we” or “us”) may process about you to deliver our Services and/or that you provide to us when you visit any of the Company’s website properties including, but not limited to; the website located at  https://jellyfish.co/ (collectively referred to as the “Website(s)”); access features of our software as made available on  Websites or any mobile application (the “App”); or obtain any professional services from Jellyfish (The Website, App, and professional services are hereinafter collectively referred to as the “Services”) 

As used in this Privacy Notice, Personal Information means information and/or data that can identify a natural person. In addition to explaining how Jellyfish processes Personal Information, this Privacy Notice further explains how Jellyfish collects, uses, accesses, maintains, protects, and/or discloses Personal Information based on its business interest and/or by obtaining your consent. By using our Services or interacting with any other aspect of our business, you agree to this policy and how Jellyfish processes Personal Information.  

If you do not agree with this policy, do not access or use our Services and/or interact with any other aspect of our business. This Privacy Notice may change from time to time in accordance with applicable privacy and/or data protection law as well to provide additional clarity around Jellyfish’s processing of Personal Information. We will provide reasonable notice of material changes to this Privacy Notice to all applicable parties and also make note of administrative changes. If you wish to continue to benefit from the Services please check back periodically for updates to this Privacy Notice, as continued use of the Services constitutes acceptance of all changes.

This Privacy Notice applies only to Jellyfish Services and does not apply to the services and/or websites offered by Jellyfish’s customers, partners, or any other third parties. Furthermore, this Privacy Notice does not apply to Personal Information processed by Jellyfish offline or through means outside of the Services.

Personal Information we collect and how we collect it

We collect Personal Information about you when you use, access, and/or input data into the Services or otherwise provide it directly to us. We also collect Personal Information automatically as you navigate the Services. This Personal Information may include: usage details; IP addresses; and information collected through cookies, web beacons, analytics tools, and other tracking technologies.  We may also collect Personal Information about you from third parties, for example, our business partners and service providers. Jellyfish ensures that Personal Information collected about you from third parties meets the same or higher security and protection standards as Jellyfish provides to you.

We collect different types of Personal Information from and about you when you use our Services, including: 

1. Direct Personal Information such as your name, postal address or location, e-mail address, telephone number, gender, age, birth date, employment status, or any other identifier by which you may be precisely identified; and/or

Indirect Personal Information such as your local time zone, your internet connection, the equipment you use to access our Services, and usage details that cannot directly identify you but may relay distinguishing information that makes you identifiable. 

The Personal Information we collect on or through our Services includes:

Context	Types of Data	Primary Purpose for Collection and Use of Data
Personnel Information	Depending on the nature of your registration with us and the information you agree to provide to us  as a Customer of our Services, to create or modify Customer user profile, or set preferences in the Services, we may collect your contact information which includes data elements such as salutation, full name of contact, contact phone number, email address, work location, billing and mailing address, professional title, company name, salary, and account log-in credentials.	We process this Personnel Information on behalf of our Customers in order to deliver the Services. We collect this Personnel Information based on the Customer user’s consent.
Customer Account Information	Depending on the nature of your registration with us we collect this Direct Personal Information from the customer account holder to support the Services. This information could also include your salutation, full name, business phone number, business email address, business location, billing and mailing address, professional title, company name, and account log-in credentials.	We have a legitimate interest in contacting our Users and communicating with them concerning business administration such as providing and supporting the Services and billing.
Network Activity Data	We use technology to monitor how internet or other electronic network activity information, such as browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement.	We have a legitimate interest in understanding how you interact with our Services to better improve it and to understand your preferences and interests in order to select offerings that you might find most useful. We also have a legitimate interest in detecting and preventing fraud.
Cookies and First Party Tracking Data	We collect cookies and clear GIFs to deliver the Services. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a website is viewed. See our Cookie Policy for more information.	We have a legitimate interest in making our Services operate efficiently.
Cookies and Third Party Tracking Data	We participate in targeted advertising, this means that a third party uses technology (e.g., a cookie) to collect information about your use of our Services so that they can provide advertising about products and services tailored to your interests on our Website.	We have a legitimate interest in advertising to our customers and potential customers, as well as capturing website analytics to promote our business and rely on individual preferences to determine whether Jellyfish may collect and/or further process Direct and Indirect Personal Information.
Log File Data	We may collect and store information about your computer hardware and software when you visit our websites or use our Services. This information can include your IP address, browser type, domain names, internet service provider (ISP), and the files viewed on our websites (e.g., HTML pages, graphics, etc.), your operating system, access times and referring website addresses.	We have a legitimate interest in understanding the needs of our customers and improving our Services to provide you with secure and protected Services.
Metadata Information	When your company uses our Services, we collect the metadata contained in certain integrations in order to provide products or services, or in connection with our engineering management platforms.	We use this information to perform our contract to provide you with products or Services. Additionally we use this information to improve our Services and to understand your preferences and interests in order to select offerings that you might find most useful. We also have a legitimate interest in detecting and preventing fraud.
Mobile Device Data	When you access our Services from a mobile device, we may collect information about your location and your mobile device, including a unique identifier for your device. Most mobile devices allow you to turn off location services. If you have questions about how to disable your device’s location services, we recommend you contact your mobile service carrier or your device manufacturer.	We have a legitimate interest in connection with our efforts to prevent fraud or illicit use of our mobile Services and to provide you with secure and protected mobile Services.
Communication Information	When you sign up for one of our mailing lists or newsletters, we collect your email address and/or postal address. If you receive email from us, we use certain tools to capture data related to when you open our message, click on any links or banners it contains, and make purchases. When registering or attending an in-person or virtual event we offer, we collect information you provide during registration, such as salutation, name, business email address, profile photograph, job title, professional interests, requested accommodation, and Information you provide throughout the conference to receive additional research or materials (e.g. via badge scan or QR scan) and collected when we record any of these events.     Promotions, incentives or giveaways may be made available by us or third parties from time to time. You do not have to participate in these, however, if you choose to participate, you may be asked to disclose some personal information. Additionally, at the time of entering the promotion, we will disclose in the promotion’s materials specific terms and conditions regarding how your personal information will be used. Please do not participate in any promotion if you do not agree to such usage. If we give you the option to participate in a survey and you agree to participate, we collect information that you provide through the survey such as your email address, name, and any other information you choose to include in the body of your email or responses. If the survey is provided by a third-party service provider, the third party’s privacy policy applies to the collection, use, and disclosure of your information.	We have a legitimate interest in understanding how you interact with our communications to you.
Candidate/Employment Information	If you apply for a job posting, or become an employee, we collect information necessary to process your application or to retain you as an employee. This may include, among other things, your Social Security Number. Providing this information is required for employment.	We use information about current employees to perform our contract of employment, or the anticipation of a contract of employment with you. In some contexts, we are also required by law to collect information about our employees. We also have a legitimate interest in using your information to have efficient staffing and workforce operations.
Customer Support Information	We collect personal information from you contained in any inquiry you submit to us regarding our Website or Services, such as completing our online forms, calling, or emailing for the purposes of general inquiries, support requests, or to report an issue. When you communicate with us over the phone, your calls may be recorded and analyzed for training, and quality control and for limited sales and marketing purposes.  During such calls we will notify you of the recording via either voice prompt or script.	We have a legitimate interest in receiving, and acting upon, your feedback, issues, or inquiries. Additionally, your use of our Services indicates consent to receive support for the maintenance of your Jellyfish SaaS license in accordance with the Agreement.
Social Media Interaction Data	When you link a User account with your social media accounts including your LinkedIn, Twitter, Instagram, YouTube or similar, we collect information from your profile, including your profile photograph. We use this information to provide a more customized experience, enable peer networking, monitor social media, and conduct internal analysis and research to help us improve our existing product and services, and create new products and services.	By linking your Social Media Account to our SaaS you provide consent to use this information to enable you to access your User account across devices, customize your experience, and to manage and promote our business and brand.

Information we receive from other sources

In addition to information that you provide us or that we collect through the Services, we receive information about you from other sources like, other users of our Services, from our related companies, social media platforms, public databases, from our business partners, and/or from third-party services, Information we receive from third party services may include company information, demographic information, employment history and salary information, and professional/business contact details.. 

How we use personal information

How we use the information we collect depends in part on which Services you use, how you use them, and any preferences you have communicated to us.  Below are the specific purposes for which we use the information we collect about you.

• To provide the Services and personalize your experience.  We use information about you to provide the Services to you, including to process transactions with you, authenticate you when you log in, provide customer support, and operate, maintain, and improve the Services.  
• For research and development.  We are always looking for ways to make our Services smarter, faster, secure, integrated, and useful.  We use information and collective learnings (including feedback) about how people use our Services to troubleshoot, to identify trends, usage, activity patterns, and areas for integration and to improve our Services and to develop new products, features, and technologies that benefit our users and the public. 
• To communicate with you about the Services: We use your contact information to send transactional communications via email and within the Services, including confirming your purchases, reminding you of subscription expirations, responding to your comments, questions and requests, providing customer support, and sending you technical notices, updates, security alerts, and administrative messages. Depending on your chosen method of contact, we may send you SMS notifications or call you. We also provide tailored communications based on your activity and interactions with us.  
• To market, promote and drive engagement with the Services: We use your contact information and information about how you use the Services to send promotional communications that may be of specific interest to you, including by email and by displaying ads on other companies’ websites and applications.  You can control whether you receive these communications by opting-out.
• Customer support. We use your information to resolve technical issues you encounter, to respond to your requests for assistance, to analyze crash information, and to repair and improve the Services. Where you give us permission to do so, we may share information with our affiliates and a third party service provider for the purpose of responding to support-related or technical requests.
• For safety and security. We use information about you and your use of the Services to verify accounts and activity, to detect, prevent, and respond to potential or actual security incidents and to monitor and protect against other malicious, deceptive, fraudulent or illegal activity, including violations of Service policies. 
• To protect our legitimate business interests and legal rights. Where required by law or where we believe it is necessary to protect our legal rights, interests, and the interests of others, we use information about you in connection with legal claims, compliance, regulatory and audit functions, and disclosures in connection with the acquisition, merger or sale of a business.  

How we share information we process

We may make collaboration tools available to you for your benefit, and we want them to work well for you.  This sometimes means sharing information through the Services and with other Service users and certain third parties.  We share information we collect about you in the ways discussed below, including in connection with possible business transfers. We are not in the business of selling information about you to advertisers or other third parties.

• Sharing with other Service users.  When you use the Services, we share certain information about you with other Service users for the purposes of collaboration and to participate in community forums.
• Service Providers. We work with third-party service providers to provide website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis, and other services for us to provide the Services to you, this may require them to access or use information about you.  If a service provider needs to access information about you to perform services on our behalf, they do so under close instruction from us, including appropriate security and confidentiality procedures designed to protect your information. Contracted service providers may also deliver artificial intelligence and generative artificial intelligence capabilities to analyze data, determine trends, make predictions and create AI-generated responses or other content.
• Jellyfish AI Product Functionality. Jellyfish developed AI products and/or features do not collect Personal Information unless they are enabled by the Customer before use. Jellyfish developed artificial intelligence products or features are not enabled automatically and must be enabled and consented to by the Customer before use through an opt-in process. 
• Affiliates. To facilitate our global operations and provision of Services to you, we may transfer information to our affiliates. This Privacy Notice will apply even if we transfer your personal information to other countries. We have taken appropriate measures and employed safeguards to require that your personal information will remain protected wherever it is transferred. When we share personal information of individuals in the European Economic Area (“EEA”), Switzerland or the United Kingdom (“UK”) within and among our affiliates, we make use of the Standard Contractual Clauses (which have been approved by the European Commission), as amended for Switzerland and the UK. 
• Partners. We work with third parties who provide consulting, sales, support, and technical services to deliver and implement customer solutions around the Services. We may share your information with these third parties in connection with their services, such as to assist with billing and collections, to provide localized support, and to provide customizations.  We may also share information with these third parties where you have agreed to that sharing.
• Third Party Apps. You or other Service users may choose to add new functionality or change the behavior of the Services by installing third party apps within the Services.  Doing so may give third-party apps access to your account and information about you like your name and email address, and any content you choose to use in connection with those apps. Third-party app policies and procedures are not controlled by us, and this Privacy notice does not cover how third-party apps use your information. We encourage you to review the privacy policies of third parties before connecting to or using their apps or services to learn more about their privacy and information handling practices. If you object to information about you being shared with these third parties, please uninstall the third party app.
• Links to Third Party Websites. The Services may include links that direct you to other websites or services whose privacy practices may differ from ours. If you submit information to any of those third-party websites, your information is governed by their privacy policies, not this one. We encourage you to carefully read the privacy policy of any website you visit.
• Third Party Services. We may offer you the ability to interact with or share information with third parties through the Services. For example, we may offer users the ability to log in to the Services via a third-party service like Google, access embedded maps through Google Maps, or interact with social media networks via links on the Services. When you intentionally interact with these third parties, we may share certain information with those third parties or receive information with those third parties, consistent with your privacy settings on the third-party service. Such information may include contact information, identification, and demographic information and device information, and identifiers. You should always check the privacy settings and notices in these third-party services to understand how those third parties may use your information.
• Third Party Widgets. Some of our Services contain widgets and social media features, such as the Twitter “tweet” button or Facebook “like” button. These widgets and features may collect your IP address, which page you are visiting on the Services, and may set a cookie to enable the feature to function properly. Widgets and social media features are either hosted by a third-party or hosted directly on our Services. You should always check the privacy settings and notices in these third-party services to understand how those third parties may use your information.  
• With your consent. We share information about you with third parties when you give us consent to do so.  For example, we often display personal testimonials of satisfied customers on our public websites. With your consent, we may post your name alongside the testimonial. 
• Compliance with Enforcement Requests and Applicable Laws; Enforcement of Our Rights. In exceptional circumstances, we may share information about you with a third party if we believe that sharing is necessary to (a) comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements, (b) enforce our agreements, policies, and terms of service, (c) protect the security or integrity of our products and services, (d) protect Company, our customers, or the public from harm or illegal activities, or (e) respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person. 
• Business Transfers. We may share or transfer information we collect under this Privacy notice in connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. We, or the acquiring entity, will use reasonable commercial effort to notify you by  email and/or a prominent notice on the Services if a transaction takes place, as well as any choices you may have regarding your information. 

How we store and secure information we collect

We use industry standard technical and organizational measures to secure the information we store. We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL technology.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot fully guarantee the security of your personal information transmitted to our Website. Jellyfish provides a SOC 2 certified SaaS and implements industry standard technical and organizational measures to protect and secure the Personal Information you transmit to us, but we are not responsible for circumvention of any privacy settings or security measures contained on the Website.

How long we keep information

How long we keep information we collect about you depends on the type of information.  Generally, we will hold your personal information for as long as you are a customer and/or access and use our Services to ensure accuracy and to help maintain quality of service, or if we are obliged to retain such information for legal, regulatory, fraud prevention, and legitimate business purposes. After such time, we will either delete or de-identify your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.  

How to access and control your information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

1. Tracking Technologies. You can set your choices in your browser and/or through a Jellyfish provided consent manager to refuse all or some cookies, or to alert you when cookies are being sent. You can choose whether or not to allow the Services to collect information through other tracking technologies by deleting your profile on the Settings screen. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the Services may then be inaccessible or not function properly. We do not currently recognize automated browser signals regarding tracking mechanisms, which may include “Do Not Track” instructions.
2. Location Information. You can choose whether or not to allow the Services to collect and use real-time information about your device’s location through the device’s privacy settings. If you block the use of location information, some parts of the Services may then be inaccessible or not function properly.
3. Promotion by Us. If you do not want us to use your contact information to promote our own or third parties’ products or services, you can opt-out by sending us an email stating your request to privacy-notifications@jellyfish.co. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions or use the ‘unsubscribe’ link provided in the applicable email. 

1. Targeted Advertising by Us. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can delete your profile on the Settings screen and/or use our consent manager to update your preferences. You may also opt-out of specific email promotions by using the ‘unsubscribe’ link provided in the applicable email. 
2. Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by deleting your profile on the Settings screen or by sending us an email stating your request to privacy-notifications@jellyfish.co. 

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the NAI on the NAI’s website.

Your rights to your information

Depending on where you are located and subject to applicable law, you may have the following choices regarding your personal information:

• Access to your personal information. You can review and change your personal information by logging into the Website or App and adjusting your account profile settings. You may also send us an email at privacy-notifications@jellyfish.co to request access to personal information that you have provided to us. If required by law, upon request, we will grant you reasonable access to the personal information that we have about you.  We will provide this information in a portable format, if required.  Note that California residents may be entitled to ask us for a notice describing what categories of personal information (if any) we share with third parties or affiliates for direct marketing.  
• Changes to your personal information. We rely on you to update and correct your personal information. To update or correct certain information, you contact us at privacy-notifications@jellyfish.coin order to request that your information be modified. Note that we may keep historical information in our backup files as permitted by law.  
• Deletion of your personal information. Typically, we retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Notice, unless a longer retention period is required or permitted by law.  You may, however, request information about how long we keep a specific type of information, or request that we delete your personal information by contacting us at the address described below.  We cannot delete your personal information except by also deleting your user account. If required by law we will grant a request to delete information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes.  
• Objection to certain processing.  Where we are relying on a legitimate purpose of Company or a third-party recipient of the information, in order to use and disclose your personal information, you may object to our use or disclosure of your personal information by contacting us at the address described below.  We will cease to use and process your personal information for that purpose unless we can show there are compelling legitimate reasons for it to continue or it needs to use your personal information for the purposes of legal claims.
• Revocation of consent.  If you revoke your consent for the processing of personal information, then we may no longer be able to provide you Services. In some cases, we may limit or deny your request to revoke consent if the law permits or requires us to do so, or if we are unable to adequately verify your identity. You may revoke consent to processing (where such processing is based upon consent) by contacting us at the address described below.

How we transfer information we collect internationally

We are located in the United States.  Our service providers and other third parties you may interact with in connection with our Services may be located in the United States and other countries around the world. As a result, your information may be processed in a foreign country where privacy laws may be less stringent than the laws in your country.  Nonetheless, where possible we take steps to treat personal information using the same privacy principles that apply pursuant to the law of the country in which we first received your information.  By submitting your personal information to us you agree to the transfer, storage, and processing of your information in a country other than your country of residence including, but not necessarily limited to, the United States.  To the extent personal information is collected and subsequently transferred out of the European Economic Area, the transfer will take place consistent with the Standard Contractual Clauses or other accepted transfer mechanism. If you would like more information concerning our attempts to apply the privacy principles applicable in one jurisdiction to data when it goes to another jurisdiction you can contact us using the contact information below.

Other important privacy information

Children under 16

The Services are not directed to individuals under 16. No one under age 16 may provide any personal information to us via the Services. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on the Services or on or through any of their respective features, register on the Website or through the App, make any purchases through the Services, use any of the interactive or public comment features of the Services or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we become aware that a child under 16 has provided us with personal information, we will take steps to delete such information. If you become aware that a child has provided us with personal information, please contact the appropriate support team at privacy-notifications@jellyfish.co.

Changes to our Privacy Notice

It is our policy to post any changes we make to our Privacy Notice on this page. If we make material changes to this Privacy Notice to how we treat our users’ personal information, we will notify you by a notice on the Website home page. The date the Privacy Notice was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting this Privacy Notice to check for any changes.

Contact Us

If you have any questions or comments about this Privacy Notice, our privacy practices, or to exercise your rights to delete, correct, or modify your Personal Data, please contact us by using the following form or by writing to us at the address below:

Jellyfish Privacy Form

Write to us directly at: 
Jellyfish
225 Franklin St., 20^th Floor
Boston, MA 02110

privacy-notifications@jellyfish.co 
ATTN: Privacy Office

To Unsubscribe from Our Communications 

You may unsubscribe from our marketing communications through one of the following methods:

– by clicking on the “unsubscribe” link located on the bottom of any of our e-mails;
– updating your communication preferences; or
– by contacting us at privacy-notifications@jellyfish.co