Privacy policy
Controller
Observe & Report LLC
104 Himrod Street
Brooklyn, NY 11221
JarganSupport@observe.report

Contact Details in Data Protection Matters: JarganSupport@observe.report

Updated: October 27, 2025
Effective Date: November 1, 2025

Contact Details in Data Protection Matters

JarganSupport@observe.report

This Privacy Policy informs you how Observe & Report LLC as a data controller processes your personal data. This Privacy Policy concerns Jargan's websites and all products and services which collect personal data, or which are linked to this Privacy Policy. We have a shared customer, marketing, and stakeholders register, and our group companies act as joint controllers for that register. If you are a consumer who resides in the State of California, this supplementary privacy notice for California residents applies to you.

Name of Register

Customer, Marketing and Stakeholders Register

What Data Do We Process and What is the Purpose and Legal Basis?

Data subjects are the customers, potential customers, stakeholders, and users of Observe & Report LLC.

Among the types of personal data we collect are:

Basic Information:

• Name, customer number, username and/or other identifier, preferred language

• Email address (including Google Workspace email for app users)

• Phone number, address information

App-Specific Data (Jargan Beta Users):

• Google Workspace email address for identification

• Engagement information (project names, timelines, stages you create)

• Partner information (names, contact details you enter)

• Channel and Voice library selections

• Deliverable tracking and scheduling information

• Folder structures you designate for projects

• Presentations generated from your data

• Export files you request

Website and Business Data:

• Information related to company contact persons

• Direct marketing opt-outs

• Information you provide in connection with events we host

• Registration data, special dietary requirements, invoicing data

• Information about customer relationships and contracts

• Payment details and voluntarily provided information

• Connection and device data such as IP address, device ID, and cookies (website only)

Minimal Anonymous Tracking (Jargan App):

• Error logs (anonymous, no user identification)

• Feature usage counts (which features are used, not by whom)

• Performance metrics (how long operations take, anonymously)

Purposes of Processing

We process personal data for the following purposes:

• Delivering and improving our products and services according to your needs

• Operating the Jargan Beta Google Apps Script add-on

• Customer surveys and feedback

• Fulfilling contractual and other obligations

• Purchasing necessary services and products to operate our business

• Invoicing and bookkeeping

• Marketing our services (with consent where required)

• Managing customer relationships

• Targeting advertising (website visitors only, not app users)

• Analyzing and profiling behavior (website visitors only, not app users)

• Recording sales calls for employee training and sales process improvement

• Minimal anonymous error logging and performance tracking for app improvement

Legal Basis of Processing

We process data based on:

• Consent for one or more specific purposes

• Processing is necessary for the performance of a contract

• Processing is necessary for compliance with a legal obligation

• Processing is necessary for the purposes of legitimate interests pursued by Observe & Report LLC or a third party

OAuth Permissions (Jargan Beta App)

The Jargan Beta Google Apps Script add-on requests the following Google Workspace permissions:

PermissionPurposeData Accessed

Spreadsheets AccessStore engagement, partner, and project dataSpreadsheet content you create with Jargan

Google Drive AccessOrganize project files in folder structuresFolders and files you designate for Jargan projects

Google PresentationsGenerate automated presentations from your dataPresentations created by Jargan

Google CalendarSchedule engagement timelines and milestonesCalendar events created by Jargan

External RequestsAccess Voice library and enable minimal error loggingOnly whitelisted domains (googleapis.com), anonymous error logs

User Email AddressIdentify you within the appYour Google Workspace email address only

Data Storage

Jargan App Data: All data created through the Jargan add-on is stored exclusively in your Google Workspace (Spreadsheets, Drive, Calendar, Presentations). We do not maintain separate databases or external copies of your app data. You maintain full control through your Google Workspace.

Website and Business Data: Data from website visitors, marketing contacts, and business operations is stored in our IT and marketing systems managed by third-party service providers.

From Where Do We Receive Data?

We receive information primarily from:

• Yourself (directly provided)

• Your Google Workspace (for app operations only)

• Public registers and authorities

• Credit information companies

• Contact information providers

• Our websites and services

We may collect and update data from publicly available sources and third parties as permitted by law.

To Whom Do We Disclose Data?

Jargan App Data: Your app data stored in Google Workspace is NOT shared with third parties, marketing partners, or advertising networks. It remains in your Google Workspace under your control.

Website and Marketing Data: We may disclose website visitor and marketing data to partners who help us with marketing, campaigns, and events. These partners act as independent controllers (e.g., social media and advertising networks).

We use subcontractors to process data on our behalf. We may share data when required by law.

Data Transfers Outside EU/EEA

We may transfer data outside the EU/EEA, ensuring legal safeguards like EU Standard Contractual Clauses or other GDPR-approved measures.

For Jargan app users, your data is stored in your Google Workspace region according to your Google Workspace settings. We do not transfer app data internationally.

How Do We Protect Data?

Only authorized employees may access personal data. Systems are protected with personal credentials, firewalls, and secure facilities. We implement regular security audits and updates.

Data Retention

Jargan App Data: You control all data retention for app-generated content. Data exists only in your Google Workspace. Delete data anytime by removing files/spreadsheets. We do not maintain separate copies. Revoking app access immediately stops all data access.

Business Data: We store personal data as long as needed for its purpose. Typically, personal data is erased 10 years after the end of a customer or service relationship, or when no longer needed. Marketing contacts are retained until opt-out or 3 years of inactivity.

We regularly assess data retention and ensure no incompatible, outdated, or inaccurate data is stored.

Cookies

Our websites use cookies and similar technologies for operations, analysis, experience improvement, and advertising. Cookies collect data such as referrer websites, page views, browser types, and IP addresses.

The Jargan Beta add-on does NOT use cookies or tracking beyond minimal anonymous error logging.

Your Rights as a Data Subject

You have the right to:

• Access your personal data

• Request rectification or deletion of your data

• Withdraw consent, where applicable (this won't affect previous lawful processing)

• Object to or restrict processing

• Data portability

• Lodge a complaint with a supervisory authority

You may also object to profiling or processing based on legitimate interest by specifying your reason. We may refuse requests only where permitted by law.

For Jargan app users, you can also exercise rights directly through Google Workspace or by revoking app permissions.

Send any rights requests to: JarganSupport@observe.report

How to Revoke App Access (Jargan Beta Users)

To remove Jargan's access to your Google Workspace:

1. Go to your Google Account Security settings

2. Navigate to "Third-party apps with account access"

3. Find "Jargan Beta" in the list

4. Click "Remove Access"

5. All permissions are immediately revoked

Changes to This Privacy Policy

If this Privacy Policy changes, we will post the updated version on our website with the amendment date. For significant changes, we may also notify you via email or other channels. Please review this policy periodically to stay informed.

Compliance Certifications

• GDPR Compliant

• CCPA Compliant (California residents)

• Google Apps Script Add-on Policy Compliant

• CASA Security Assessment Ready

Questions or Concerns?

Email: JarganSupport@observe.report
Data Protection Officer: Available upon request

APPENDIX: California Privacy Rights

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA). Contact us at JarganSupport@observe.report for more information about your California privacy rights.

Document Version: 2.0
Last Updated: October 27, 2025
Review Schedule: Quarterly or upon material changes