Application Privacy Policy

Last updated: September 10, 2018

This Privacy Policy (hereinafter, the “Policy”) addresses data subjects whose personal data (“PII”) may be received or otherwise processed by Surveybot (a trade name of JICT Ventures Inc.), (“us”, “we,” “our,” or “Surveybot”) in our hosted online chatbot survey platform, the “Surveybot Service”). This Policy does not apply to the Surveybot publicly accessible website, the employees of Surveybot, or to any PII we collect outside of the Services.

With respect to the PII processed in the Services, Surveybot is a data processor. The organization or natural person who is licensed to use the Services (the “Surveybot Account Holder” or “Account Holder”) is the data controller. Notwithstanding the foregoing, the payment card data and other personal data of the Account Holder that is submitted to Surveybot via the Services, is controlled by Surveybot.

1. Confidentiality

If you are a data subject and submit PII via a bot created by a Surveybot User, the PII you submit will be shared with the relevant Surveybot Users and will be processed in accordance with this Policy.

Except as described in this Policy, we maintain the PII processed in the Surveybot Service in confidence.

2. Categories of PII

The categories of PII processed by the Services, and their purposes of use depend on how each Surveybot User configures their respective Services.

Generally, a Surveybot bot will process a data subject’s name, locale, profile picture and gender. In addition, the Surveybot Service contains User-customizable fields, which can be used to solicit any category of PII, including sensitive PII. The Surveybot Service also enables you to upload files to a User’s bot, which might also contain any category of PII, including sensitive PII.

The Surveybot Service is designed to collect PII via Users’ Facebook Messenger and Facebook pages, via Facebook Workplace and via its API through various integrations with other third-party information systems that are controlled by Surveybot Users, and with respect to Surveybot Users, from within the Surveybot Team members tab.

2.1 Cookies (Required)

The Services use cookies. Some of these cookies enable us to remember data you have entered or choices you have made, such as your email address, time zone, and date and time preferences, and provide you with a better user experience. We use session ID cookies to recognize you, as you move from one page to another within the application.

If you have chosen to identify yourself to the Surveybot Service, we use cookies containing encrypted data to enable us to uniquely identify you. Each time you log into the Surveybot Service, a cookie containing an encrypted unique identifier that is tied to your account is placed on your computer. These cookies allow us to uniquely identify you when you are logged into the Surveybot Service and enable us to provide you with the best user experience.

Since cookies are essential to the operation of the Services, you cannot opt out of these cookies without compromising the intended functionality of the Surveybot Service.

2.2 Third Party Cookies (Opt Out Possible)

The Services use analysis cookies that collect data about how people use our web applications, including which pages are visited most often, how fast they load, and other statistical information. These cookies do not collect data that individually identifies a visitor, aside from an IP address. All data these cookies collect is only used to tell us how the Services are used, so that we can optimize the user experience.

2.3 Google reCAPTCHA

We use Google reCAPTCHA for the purpose of verifying administrative users of the Surveybot Service. The reCAPTCHA is a service provided by Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA.

The reCAPTCHA is used to check whether data entered in the Surveybot Service by administrative users has been entered by a human or by an automated program.

To do this, reCAPTCHA analyses the behaviour of an administrative user based on various characteristics. This analysis starts automatically as soon as an administrative user enters the Surveybot Service. For the analysis, reCAPTCHA evaluates various information (e.g. IP address, how long the user has been on the website, or mouse movements made by the user). The data collected during the analysis will be forwarded to Google. The reCAPTCHA analyses takes place completely in the background. Users are not advised that such an analysis is taking place.

Data processing is based on Art. 6 (1) (f) of the GDPR. Surveybot has a legitimate interest in protecting its site from abusive automated crawling and spam. We consider this to be proportionate and will not be prejudicial or detrimental to data subjects.

For more information about Google reCAPTCHA and Google's privacy policy, please visit the following links:

3. Lawful Basis of Processing

If you are an Account Holder, we process your PII based on your consent, and based on the need to perform the obligations of our contract with you. If you are a member of the workforce of an organization that is a Surveybot Account Holder, or if you are not a User of the Services and you, a User, or an Account Holder submits your PII to the Services, we will process such PII based on the documented instructions of the data controller.

4. Purposes of Processing

We collect and use PII for the purposes of providing the Services to our Users and Account Holders at their instruction, processing PII on behalf of Users and Account Holders, communicating with corporate business partners about business matters, providing information on the Services to prospective Surveybot Account Holders, improving the Services, and conducting related tasks for legitimate business purposes.

5. Sharing PII with Third Parties

We share PII with our data subprocessors, who further process such PII on behalf of, and under the instruction of, Surveybot. Such data subprocessors include:

  • infrastructure service providers;
  • software consulting service providers;
  • web-based productivity software providers;
  • email service providers.

We require those data subprocessors to maintain at least the same level of confidentiality, integrity, and availability that we maintain for such PII. Surveybot remains liable for the protection of your PII that we transfer to our subprocessors. Note that some of our subprocessors, and our non-U.S. group company, process your data, including PII, outside of the United States.

We may also disclose PII (i) to other third parties for the purposes for which we receive the PII (e.g., performance of contractual obligations and rights); (ii) to the extent required by law or if we have a good-faith belief that such disclosure is necessary in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, or private parties, including but not limited to: in response to subpoenas, search warrants, or court orders; (iii) if we sell or transfer all or a portion of our company’s business interests, assets, or both, or in connection with a corporate merger, consolidation, restructuring or other company change; and (iv) to our subsidiaries, only if necessary for business and operational purposes.

If we must disclose your PII in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, we may not be able to ensure that such recipients of your PII will maintain the privacy or security of your PII.

6. Data Integrity Security

Surveybot has implemented and will maintain technical, administrative, and physical measures that are reasonably designed to help protect PII from unauthorized processing such as unauthorized access, disclosure, alteration, or destruction.

7. Data Retention

PII that you submit to the Surveybot Service is retained for as long as is necessary for us to perform our obligations under the contract that is entered into between the Surveybot Account Holder and us. Note that we keep backup copies of our databases for a limited period of time as part of our disaster recovery/business continuity plans, and it may not be reasonably possible for us to delete data from such backups.

8. Access, Review

If you are a data subject of PII that was submitted to the Services by a User or a Surveybot Account Holder, you may have a right to request access to, and the opportunity to update, correct, or delete, such PII. To submit such requests or raise any other questions, please contact the User or Account Holder that provided your PII to us.

9. Privacy of Children

The Services are not directed at, or intended for use by, children under the age of 13. If you believe that PII pertaining to your under-13-year-old child has been submitted to the Services, and you would like to exercise your rights with regards to such PII, please contact the User whose Services the PII is processed in.

10. Changes to This Policy

We may update this Policy from time to time by posting a new version on our website. When we make a material change to the Policy, we will update the Last Updated date above to reflect the effective date of the most recent version of the Policy.

11. Contact Dispute Resolution Process

11.1 Contact

If you have any questions or complaints about how we process your PII, please contact us via our contact form or using the information below.

Security and Compliance Manager
2093 Philadelphia Pike #5585,
Claymont, DE 19703
Email: Dpo email

We will respond to your inquiry within four weeks of receipt.

11.2 Binding Arbitration

With regards to PII processed in the Surveybot Service, if your dispute or complaint can’t be resolved by us, you may have the right to require that we enter into binding arbitration with you.

11.3 Regulatory Oversight

Surveybot is subject to the investigatory and enforcement powers of the United States Federal Trade Commission.

Facebook, Facebook Workplace and Facebook Messenger is either a registered trademark or trademark of Facebook the United States and/or other countries. Google is either a registered trademark or trademark of Google Inc. in the United States and/or other countries.