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JConnect Privacy Policy

This notice sets out the privacy policy of JConnect Forum, a smart application owned by Rina Barbut of Israel (the “Owner”).


  1. Privacy Commitment


The Owner and any other person employed by or providing services to JConnect (“Representatives”, “we”, “us”, "our") are committed to protecting the privacy of all users of the JConnect Forum smart application (“JConnect”).


Our privacy policy is designed to be compliant with the laws and regulations of wherever we conduct our business. Without limiting the foregoing, our privacy policy is consistent with the privacy laws of the State of Israel, as well as the European Union’s General Data Protection Regulation 2016/679 (“GDPR”) and the version of the GDPR adopted by the United Kingdom (“GDPR UK”).  


This privacy notice describes how we collect and process the personal data of individuals using JConnect and we also provide you with details as to your rights in connection with your personal data that we control and process.


  1. Some Definitions


In this privacy notice, the following terms have the meanings provided below.


“Personal data” means any information of any kind relating to a natural individual and which can be connected to that individual either directly or indirectly by reference to other information. Personal information relating to an anonymised individual, the identity of whom cannot be recovered, is not personal data for the purposes of this privacy notice.


“Processing” of personal data means performing any operation or set of operations on personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of the personal data.


“Controller” of personal data is any person or entity that determines how personal data will be processed and by whom. We will be the controller of personal data that we have collected from you.  


“Processor” of personal data is any person or entity that undertakes any processing activity of the personal data. We both control and process personal data. We may also use third parties for certain processing activities related to the personal data.


  1. How we collect personal data


  1. Subscribing to JConnect. When you subscribe to JConnect, you must open an account by providing us with an email address, a username and a password. You may also open an account by registering via your Apple, Google and LinkedIn accounts. If you open an account through Apple, Google or LinkedIn, they send us a token which confirms your identity and allows us to obtain from them your email address and in the case of LinkedIn, also your first name, last name, profile photo and language preference. 


Using JConnect. When you use JConnect and communicate with other users or post content, any personal information that you include in the communications or posts will then be stored on JConnect. Only JConnect users have access to the content posted and contained in communications on JConnect. However, that does not mean that all personal data you include in posts and communications on JConnect will remain secure and non-public. A user you have shared personal data with may be prohibited by law from sharing or using your personal data in certain ways, but we cannot be responsible for whether or not another user will use or share your personal data in a manner that violates applicable privacy laws. Once you have shared personal data on JConnect, any user that has access to that personal data on JConnect has the ability to share that personal data, whether via JConnect or otherwise, with both other JConnect users and non-users or to put the personal data in the public domain. It is therefore your responsibility to determine which of your personal data you do not mind sharing with other JConnect users or making public and which of your personal data you want to remain confidential and post and share content on JConnect accordingly.  


  1. How and why we process your personal data


The table below provides details of how we process any of your personal data that we do collect, together with a description of the kind of personal data processed and the reasons and the legal basis for processing the personal data.

  Type of Data

Purpose of Processing

Legal Basis (See Below)

Data provided upon your subscription (name and email address, password, LinkedIN profile).

  • To enable you to subscribe for and log onto JConnect and to use the services provided by JConnect.

  • To communicate with you in connection with your JConnect account and use thereof. Communications may be for the purposes of research, marketing and promotional purposes or for resolving technical problems.


  • Performance of a contract between us (see our T&Cs here).

  • Exercise of legitimate interests

Data that you upload or post on JConnect or that is contained in communications with other users that may be seen by all or selected JConnect users

To enable you and other users to use JConnect in the manner that it was intended so that you may communicate and network with other users.

  • Performance of a Contract

  • Exercise of a legitimate interest

  • Your consent

Data provided by you upon your subscription and data shared by you with other JConnect users.


To comply with any legal obligations and law enforcement requests that we may receive from governmental/regulatory/police and other law enforcement authorities.

  • Exercise of legitimate interests

  1. The legal basis for us to collect and process your personal data


We ensure that we have at least one appropriate legal base for processing your personal data. We ensure that the legal bases are consistent with the legal bases required under the GDPR UK and GDPR, which unless specified otherwise are generally sufficient to establish the legality of the processing of the personal data in many other jurisdictions, including in Israel.

The legal bases that we rely on are stated in the table above and explained below.

  1. For the performance of a Contract. When you subscribe to JConnect and we accept your subscription, we enter into a contractual relationship made up of our terms and conditions (which may be viewed here,) pursuant to which, we provide you with certain services via the JConnect app and you make certain legally binding promises to us. We use your personal data to enable us to perform our obligations under our contract with you, essentially enabling you to subscribe to JConnect and enabling you to log onto JConnect and to use JConnect in the manner intended by an end-user (see descriptions in the T&Cs).


  1. To support our Legitimate Interests. We have legitimate business interests to process your personal data for the purposes described in the table above. To determine whether we may rely on this legal basis, we have considered the nature of your personal data that we will hold and process and that none of the processing adversely affects your interests or fundamental rights and freedoms.


  1. Consent.  From time-to-time, we may elect to use your personal data in a manner or for purposes not described above. Should any such processing not be justified by any other legal basis, then we will require your freely given, express, clear and informed consent. Until we receive your consent, we will not undertake any processing that does not have another appropriate legal basis. 


  1. How long will we hold your Personal Data?


We will retain your personal data only for as long as we need it for the purposes described in the table above and for so long as the legal bases that we rely on are still valid. Generally, this will mean that we will retain all of your personal data for so long as you are subscribed to JConnect and once your subscription with JConnect is terminated, we will only retain personal data that we determine continues to be relevant for us in case of establishing, exercising, or defending legal claims. However, there may be other reasons for holding onto your personal data for a longer period, if this is in our legitimate interests. Once we determine that we should no longer hold an item of your personal data, that data will be either deleted or anonymized and aggregated with the personal data of other JConnect users.


  1. When and how do we share your personal data?


To the limited extent stated below, we do not share any of your personal data with any other party. Should we decide to change our current policy, we will update this privacy notice and bring the changes to your attention. Where we determine that your express consent will be required before sharing your personal data, then we will first obtain that consent. However, note the information provided in paragraph C.2 above regarding how other JConnect users might use any personal data that you post, share or communicate to other users on JConnect.

  1. Transfer of personal data to third party servers. Personal data that we collect is stored on third party servers that have been selected, among other reasons, based on their commitments to hold and protect the personal data from unauthorized access or transfer and that have provided commitments consistent with the Israeli law, GDPR UK and GDPR. Currently, the personal data is stored on the servers owned and operated by  Amazon Web Services (AWS), which are located in Frankfurt, Germany (the “Servers”). The personal data is stored on the servers under our own unique account to which no other party has access.


  1. Transfer of personal data to third party processors. Currently, except with respect to the personal data being held on third party servers (see above), we do not currently share any personal data with any other party, other than with other users according to how you post and share your personal data (see paragraph C.2 above). If this changes, then we will update this policy notice accordingly. 


  1. International Transfers of Personal Data. Except for any transfer of personal data to AWS servers in Frankfurt, Germany (as described in paragraph G.1 above), we do not currently conduct any international transfers of personal data, except as described in this paragraph. By sharing your personal data on JConnect with users in other countries, the personal data is effectively transferred to the recipient users’ countries. Furthermore, as stated in paragraph C.2 above, once you share your personal data with any other user, that user may share your personal data with other users, including users in other countries. Therefore, by sharing any of your personal data in posts and communications with other JConnect users, you are expressly and unequivocally consenting to allow us to transfer that personal data to any other country in which there are JConnect users. 


If we decide to make any international transfers of personal data other than as described in paragraph 3 above, we shall ensure that such transfers are made in full compliance with applicable data privacy laws.


  1. Business transfers. If JConnect is acquired, or if the JConnect business is closed down, or the Owner enters bankruptcy, then personal data stored on our systems are likely to be among the assets transferred to or acquired by a third party.


  1. How we secure your personal data


We take the security of all personal data very seriously, regardless of whether the information is stored electronically or in another form.

We have put in place reasonable administrative, organisational and technical safeguards and security measures to protect personal data from unauthorised access, disclosure, destruction or alteration, accidental loss, misuse or damage. We regularly review and monitor such safeguards and security measures and update them when we deem it to be required.


Examples of measures taken include:


  • Ensuring that the personal data we hold is minimal.  

  • Ensuring that Representatives are informed and trained on the holding and processing of personal data.

  • Restricting access to personal data, not including personal data you share with other JConnect users, to only Representatives that have a need-to-know for our business purposes consistent with this privacy notice. 

  • Implementing technical measures to prevent unauthorized access to JConnect servers, such as "hacking". Please note, though, that no website, app or internet transmission is completely secure, so while we strive to protect your data, we cannot guarantee that unauthorized access, hacking, data loss or a data breach will never occur.





  1. Personal data relating to children.


JConnect is not offered to persons under the age of 18 and we do not collect or process any personal data of anyone under the age of 18. The only personal data of people under the age of 18 that may be stored and processed by JConnect is any such personal data that you share with other users on JConnect. In such a case you consent to that person’s personal data being used in the manner described in this privacy notice and if you are not the parent or legal guardian of the person under 18, then you represent and warrant to the Owner that you have the person’s parent or legal guardian’s full and explicit approval to share such personal data with the other users on JConnect together with the consequences of sharing described in this privacy notice.  


  1. Your Rights in Connection with Your Personal Data Held by Us.


You have certain rights in relation to personal data about you that we hold. Details of these rights and how to exercise them are set out below. We will require suitable evidence of your identity before we are able to act on any request.


  1. Right of Access


You have the right at any time to ask us for a copy of the personal data about you that we hold.  The applicable laws provide certain instances where we may refuse your request for a copy of your personal data, or certain parts of the personal data that we hold. If we refuse your request or any element of it, we will provide you with our written reasons for doing so as soon as possible.


  1. Right of Correction or Completion


If personal data we hold about you is not accurate, out of date or incomplete, you have a right to have the data rectified, updated or completed.


  1. Right of Erasure


You have the right to request that personal data we hold about you is erased if:

  • your personal data is no longer necessary for the purposes for which it was collected or otherwise processed;

  • if our processing of certain personal data was based on your consent and you wish to withdraw your consent, then you may do so and we will delete that personal data unless there is another legal basis justifying the processing of that personal data;

  • you consider and can establish that your personal data has been unlawfully processed; or

  • your personal data must be deleted in accordance with a legal obligation.

Please note that even if we accept your request to delete personal data about you, we may still retain data in an aggregated and anonymized form that does not identify you. We may also be legally prevented from deleting your data and if this is the case, we will inform you upon receipt of your request to be deleted. 


  1. Right to object to or restrict processing


You have the right to object to our processing of your personal data.


Please note that because at the moment the only personal data we collect that is not anonymised is the personal data you use to subscribe and log onto JConnect and that you post and share with other users on JConnect, deletion of that personal data or prevention of us processing that personal data will mean that you will no longer be able to use JConnect.

  1. Right of Data Portability


You have a right to receive any personal data that we hold about you in a structured, commonly used and machine-readable format. Please note that if you are requesting the personal data to be transferred to a third party’s system, we cannot guarantee technical compatibility with that system.


  1. Consent


To the extent that we are processing your personal data based on your consent, you have the right to withdraw your consent at any time.


  1. Exercising your rights


If you wish to exercise any of your rights listed above in connection with any personal data of yours that we hold and process, then please contact us via the “Contact Us” button on JConnect.


  1. Communications and Complaints


If you wish to exercise any of your rights described above, or if you wish to communicate with us in connection with any matter related to our processing of your personal data or if you are unhappy about any aspect of our use of your personal data, please do notify us, providing the reasons for any request or complaint and we will endeavour to rectify the problem. Please notify us via the “Contact Us” button on JConnect, or by email at ________________.


If you are based in the EU, you may also lodge a complaint with any Data Protection Authority set up to supervise and enforce the GDPR (“DPA”). There is a DPA in each EU member state   and you may report to any DPA, although generally you will report to the DPA set up in the member state in which you are located. Here is a list of all DPAs and their contact details. 


If you are based in the UK, you may also lodge a complaint with the Information Commissioner’s Office (ICO) which supervises and enforces GDPR UK. You can learn how to report a breach to the ICO here.


If you are based in Israel, you may also lodge a complaint with the Privacy Protection Authority and details of how to lodge a complaint can be found here.


For other countries, please check with local advisers or authorities as to whether you are entitled to make a complaint and to whom.   


However, we do take your rights with respect to your personal data very seriously and will appreciate the chance to resolve any issues that you may have before you address a DPA, ICO, Israel Privacy Protection Authority or similar authority.


  1. Changes to this Notice


We are constantly trying to improve JConnect and the services available through the app, so this privacy notice may need to be amended from time-to-time. If we amend the privacy notice, then we will notify you the next time you open JConnect.

By using JConnect, you consent to this privacy notice and all amendments hereto applying to how we collect, hold and process your personal data.

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