Privacy Policy

This Privacy Policy explains how Jolly Green Frogs Limited collects, uses, stores, and shares your personal data, and what rights you have in relation to that data.

1. Who We Are

Jolly Green Frogs Limited (CRO 805235), with its registered office at Gortnamuinga, Flagmount, Co. Clare, Ireland ("JGF", "we", "us", "our") is the data controller for personal data processed in connection with our website, platform services, and consumer applications.

Where JGF processes personal data on behalf of a business customer (for example, data relating to that customer's end users stored on the JGF platform), JGF acts as a data processor. In that case, the business customer is the data controller and our Data Processing Agreement applies.

Contact us with any privacy questions: [email protected]

2. What Data We Collect

2.1 Data you provide to us

• Account and registration data: name, email address, organisation name, job title, and account credentials when you sign up for our services.
• Billing and payment data: billing address, VAT number (for business customers). We do not store full payment card details — these are handled by our third-party payment processors.
• Communications: messages you send to us by email or through support channels.
• Content you create: data, content, and materials you upload or create within our platform ("Customer Content").

2.2 Data we collect automatically

• Usage and log data: pages visited, features used, session duration, IP address, browser type, and device information when you access our website or platform.
• Cookies and similar technologies: we use cookies to maintain sessions, remember preferences, and understand how our services are used. See section 8 for more detail.

2.3 Data relating to AI features

Where you use Vira (our AI assistant), your inputs and interaction data may be processed to provide responses. Depending on your plan, Vira may retain session or persistent memory to improve continuity. We do not use your inputs to train third-party AI models without your consent.

2.4 Data we receive from third parties

We may receive limited data about you from payment processors, identity verification services, or integration partners where you have authorised those services.

3. How We Use Your Data

We use your personal data for the following purposes:

• Providing our services: to set up and manage your account, deliver the platform and applications you have subscribed to, and process payments.
• Supporting you: to respond to support requests, troubleshoot issues, and communicate about your account.
• Improving our services: to understand how our platform is used, identify issues, and develop new features. Where possible we use aggregated or anonymised data for this purpose.
• Security and fraud prevention: to detect and prevent unauthorised access, misuse, or fraudulent activity.
• Legal compliance: to meet our obligations under applicable law, including data protection, tax, and company law.
• Marketing (where permitted): to send you information about JGF products, updates, or events where you have consented or where we have a legitimate interest and you have not opted out. You can unsubscribe at any time.

4. Legal Basis for Processing

We rely on the following legal bases under the GDPR (and UK GDPR where applicable):

• Contract performance: processing necessary to provide the services you have subscribed to or taken steps to subscribe to.
• Legitimate interests: improving and securing our services, communicating with existing customers, and preventing fraud — where these interests are not overridden by your rights.
• Legal obligation: where processing is required to comply with applicable law.
• Consent: where we have asked for and received your consent (for example, for certain marketing communications or optional cookies).

5. Who We Share Your Data With

We do not sell your personal data. We share it only in the following circumstances:

• Payment processors: we use third-party payment processors (such as Stripe) to handle billing. They process your payment data under their own privacy policies and are bound by applicable data protection law.
• Hosting and infrastructure providers: our platform is hosted on cloud infrastructure. Providers are bound by data processing agreements and appropriate safeguards.
• AI service providers: Vira may use third-party AI model providers to generate responses. These providers process data under our instructions and are bound by data processing agreements.
• Analytics and monitoring tools: we may use third-party tools to monitor platform performance and usage. Where possible we configure these to minimise personal data collection.
• Professional advisers: our solicitors, accountants, and insurers may receive personal data where necessary.
• Legal requirements: we may disclose personal data to law enforcement, regulatory authorities, or courts where required by law or to protect the rights, property, or safety of JGF, our customers, or others.
• Business transfers: if JGF is acquired or merges with another organisation, personal data may be transferred as part of that transaction. We will notify affected individuals in advance where required by law.

6. International Data Transfers

JGF is based in Ireland and processes data within the European Economic Area (EEA). Some of our third-party service providers may process data outside the EEA or the UK.

Where data is transferred outside the EEA or UK, we ensure appropriate safeguards are in place, such as:

• Standard Contractual Clauses approved by the European Commission or the UK ICO; or
• An adequacy decision covering the destination country.

For UK customers: transfers of your data from the UK to JGF in Ireland are covered by the UK's adequacy decision for the EU. Transfers from Ireland to non-EEA third-party providers are covered by Standard Contractual Clauses.

7. How Long We Keep Your Data

We retain personal data only for as long as necessary for the purpose for which it was collected, or as required by law.

• Active account data: retained for the duration of your subscription plus a reasonable period after closure to handle queries or disputes.
• Billing records: retained for 7 years as required by Irish tax and company law.
• Support communications: retained for up to 3 years after your last interaction.
• Platform content (Customer Content): following termination or account closure, we will make Customer Content available for export for 30 days, after which it will be deleted from our systems.
• Marketing data: retained until you unsubscribe or withdraw consent.

8. Cookies

We use cookies and similar technologies on our website and platform. Cookies are small text files stored on your device.

We use cookies for:

• Essential operation: session management, authentication, and security. These cannot be disabled without affecting core functionality.
• Preferences: remembering your settings and preferences.
• Analytics: understanding how visitors use our website and platform (for example, which pages are visited most). We use anonymised or aggregated data where possible.

You can control non-essential cookies through your browser settings or our cookie consent tool. Disabling essential cookies may prevent parts of our services from functioning correctly.

9. Your Rights

Depending on where you are located, you have the following rights in relation to your personal data:

• Access: to request a copy of the personal data we hold about you.
• Rectification: to ask us to correct inaccurate or incomplete data.
• Erasure: to ask us to delete your personal data in certain circumstances.
• Restriction: to ask us to restrict processing of your data in certain circumstances.
• Portability: to receive your data in a structured, machine-readable format and have it transferred to another controller, where technically feasible.
• Objection: to object to processing based on legitimate interests, including for direct marketing.
• Withdraw consent: where processing is based on consent, to withdraw that consent at any time without affecting the lawfulness of processing before withdrawal.

To exercise any of these rights, contact us at [email protected]. We will respond within one month. We may need to verify your identity before processing your request.

10. Complaints

If you are unhappy with how we handle your personal data, you have the right to lodge a complaint with a supervisory authority.

For EU / Irish residents

Data Protection Commission (Ireland)
Website: www.dataprotection.ie
Phone: +353 57 868 4800

For UK residents

Information Commissioner's Office (ICO)
Website: ico.org.uk
Phone: 0303 123 1113

We would appreciate the opportunity to address your concerns before you contact a supervisory authority — please reach out to us at [email protected] first.

11. Children

Our platform services and consumer applications intended for adults require users to be 18 or over to create an account. Where a parent or guardian purchases a subscription on behalf of a child, the parent or guardian is responsible for managing the child's use and ensuring it is appropriate.

We do not knowingly collect personal data from children under 13 without verified parental consent. If you believe we have collected data from a child without appropriate consent, please contact us and we will delete it promptly.

12. Changes to This Policy

We may update this Privacy Policy from time to time. Where changes are material, we will notify you by email or by a prominent notice on our website before the changes take effect. The date at the top of this page shows when the policy was last updated.

13. Contact Us