Juro's commitment to the GDPR

Juro was founded and built in Europe and is committed to building and maintaining a contract collaboration platform that you can use with confidence if your personal data processing is regulated by the EU General Data Protection Regulation (2016/679) - the GDPR.

This page sets out information about how Juro meets these requirements to enable you to comply with the GDPR.

Your responsibility

When choosing a contracts platform, you have a duty to use only providers who provide sufficient guarantees to implement the appropriate technical and organizational measures.

This will ensure that the processing of personal data meets the requirements of the GDPR. There are also other technical requirements that your provider must meet to comply with the GDPR.

Juro’s approach to GDPR compliance

Juro has a strong track record of empowering customers based in the European Union and EFTA states to agree and manage contracts 10x faster than traditional tools.

At Juro, we take data protection and compliance with the GDPR extremely seriously. We know that our customers entrust us with their most sensitive business information, and it is our responsibility to handle personal data within that information with care.

Our approach to GDPR compliance is built on a foundation of accountability, transparency, and proactive risk management.

We've implemented an extensive GDPR compliance programme that incorporates the GDPR’s principles into our product development, documentation, contractual agreements, security policies, and organizational practices.

Data protection by design is at the heart of how we build, maintain and develop Juro.

Key GDPR compliance topics

Juro’s data processing agreement

For customers whose processing of personal data using Juro is governed by the GDPR, Juro’s master services agreement includes a detailed data processing agreement (DPA) in a schedule that contains the mandatory clauses required by Article 28(3) of the GDPR.

Below you can find the mandatory clauses, plus more information about how Juro meets those obligations. Click on the collapsible menus to find out more on:

GDPR reference: Article 28(3)(a)

DPA reference: paragraphs 3.1.1 to 3.1.3

Unless legally required to do otherwise, Juro may only process personal data on your behalf in accordance with your documented instructions. Juro may not process that personal data for any other purpose.

The DPA includes a written instruction to process that personal data in accordance with your contract with Juro (DPA paragraph 2.1), but you may issue other documented instructions through using the Juro platform or in writing to our onboarding or support teams.

We’ll tell you if we think that one of your instructions breaks data protection laws.

GDPR reference: Article 28(3)(b)

DPA reference: paragraph 3.1.6

Juro must ensure that people it authorizes to process personal data on your behalf are bound by obligations of confidentiality in relation to that personal data.

All of Juro’s personnel and all of Juro’s sub-processors are subject to binding obligations of confidentiality in relation to the personal data Juro processes on your behalf.

These obligations are put in place when we first engage those personnel or sub-processors, and continue to apply after our relationship with them ends.

GDPR reference: Article 28(3)(c)

DPA reference: paragraph 3.1.4

Juro must adopt appropriate technical and organisational measures to ensure an appropriate level of security for the personal data processed on your behalf.

You can find more information about the security measures that Juro currently has in this article on application security. We audit and review these measures frequently.

Juro’s security team keeps the measures described in Juro’s information security policy and in Juro’s encryption policy under constant review to ensure that we continue to adopt best practices in response to emerging threats.

GDPR reference: Articles 28(3)(d) and 28(4)

DPA reference: paragraph 5

Like nearly all SaaS providers, Juro relies on trusted third-party technology providers. However, Juro must respect the GDPR’s rules for engaging sub-processors to assist with processing personal data on your behalf. In short, that means:

1. Authorization. Our DPA (paragraph 5.1) contains a general authorization to appoint sub-processors. We take this approach because it isn't practical with shared infrastructure to get specific authorizations to appoint each new sub-processor when we make changes and improvements to our platform.

Instead, in accordance with the GDPR, we offer all customers a meaningful opportunity to object to new sub-processors - more on this in DPA paragraph 5.2.2. We’ll consider all objections fully, and also consider objections based on reasons other than GDPR compliance. In the case of the latter, we ask that the customer objecting covers the cost of accommodating the objection.

2. Agreement. We have written agreement with all of our sub-processors that require those sub-processors to comply with obligations equivalent to Juro’s under the DPA. Juro remains responsible to you for the performance of any obligations carried out by Juro’s sub-processors - see DPA paragraph 5.3.

You can find a current list of our sub-processors in our privacy policy - simply click “read more” in the “third parties who process your data” section.

GDPR reference: Article 28(3)(e)

DPA reference: paragraph 3.1.7.2

Juro must help you by appropriate technical and organisational measures to respond to requests from data subjects exercising their rights under Chapter III of the GDPR.

In most cases, you can use features in Juro to find, produce and delete the information you require. For any complex requests that you can’t serve using existing functionality in the platform, just email support@juro.com and we’ll be happy to help.

GDPR reference: Article 28(3)(f)

DPA reference: Paragraphs 3.1.4, 3.1.5, 3.1.7.1 and 3.1.7.3

Juro must help you with your own compliance obligations under Articles 32 to 36 of the GDPR.

These obligations relate to security of processing, notification of breaches, data protection impact assessments and prior consultation with supervisory authorities. Here’s how Juro helps with:

1. Security. You can find information about how we keep Juro secure on our application security page. If you need further information, contact support@juro.com, your sales representative, or get in touch here.

2. Breach notifications. We are required by law to notify you without undue delay if we become aware of a personal data breach affecting personal data we process on your behalf, irrespective of the level of risk arising from the breach - see Article 33(2) GDPR.

We also commit in our DPA to meeting this requirement - see DPA Paragraph 3.1.5. If Juro suffers a personal data breach that affects personal data processed by Juro on your behalf, we’ll provide you with reasonable assistance, at no additional cost to you, to help you meet your notification obligations as a controller under the GDPR.

We won’t notify any supervisory authority or affected data subject directly, since this is your obligation as the controller, not ours as the processor.

3. Data protection impact assessments. If you decide it is necessary to conduct a data protection impact assessment (DPIA) and that requires information about the Juro platform, we’ll provide that information.

For some features (like our AI Assistant), we can provide useful DPIA templates to help you on your way. If you make repeat requests or requests that involve significant effort on our part, we may charge for our time in providing that support. We’ll tell you up front if we need to do that.

4. Prior consultation with supervisory authorities. If you need to consult with supervisory authorities about your personal data processing and you need information about the Juro platform to do so, we’ll provide that information.

If you make repeat requests or requests that involve significant effort on our part, we may charge for our time in providing that support. We’ll tell you up front if we need to do that.

GDPR reference: Article 28(g)

DPA reference: paragraph 3.1.10

Juro must return or delete personal data it processes on your behalf at the end of the services, unless retention is required by law. Clause 2.7 of our MSA sets out exactly how this works.

When you terminate your Juro subscription, you have until 60 days after your termination date to request a copy of your data from Juro. If you request this data within this window, we’ll provide it. If we don’t receive a request from you within that window, we’ll securely destroy your data.

We don’t provide a copy of your data automatically because we need to confirm that the request for a copy is genuine before providing it. We also need to make sure we have the right information about where to send your data before sending it. This step helps keep your data secure.

GDPR reference: Article 28(h)

DPA reference: paragraph 3.1.9

Juro must make available to you all information necessary to demonstrate Juro’s compliance with the obligations set out in Article 28 GDPR, and allow for and contribute to audits and inspections.

We meet this obligation by providing a copy of our most recent System and Organization Controls (SOC) 2 report, or other relevant documentation describing the controls implemented by Juro that replace or are substantially equivalent to SOC 2.

Any report Juro provides is confidential, and is covered by the confidentiality obligations in place under our MSA.

International transfers

At Juro, we take seriously our responsibility to put in place appropriate measures designed to protect the personal data we process on your behalf, wherever in the world that data is processed.

Uploading personal data into Juro

Juro is hosted on AWS servers in the Europe (Ireland) (eu-west-1) region - within the European Economic Area.

For this reason, your general use of Juro does not involve any transfer of personal data to a third country or international organisation. This means you do not need to take any additional measures required for international transfers of personal data.

Our customer support team is based in the United Kingdom. Since 31 January 2020, the United Kingdom is a third country for the purposes of the GDPR. The United Kingdom benefits from an adequacy decision from the European Commission in relation to processing personal data under the GDPR.

This means that, under Article 45 GDPR, transfers of personal data to Juro are permitted from controllers who are subject to the GDPR.

Juro’s international sub-processors

Juro has selected trusted partners and technology providers to help provide the Juro platform. These are our sub-processors, since they help Juro process personal data on your behalf.

To ensure we can offer best-in-class capabilities, some of our sub-processors are located in countries that are ‘third countries’ under the GDPR.

It’s Juro’s responsibility (as the data exporter) in these cases to ensure that international transfers of personal data comply with the rules in the GDPR.

Where we have selected a third country sub-processor, we put in place the following measures to ensure an equivalent level of protection for personal data:
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As a controller, it’s important that you tell data subjects that their personal data will be transferred to a third country as a result of your use of Juro.

This demonstrates that your processing of personal data is fair, and is a specific requirement under Article 13(1)(f) of the GDPR.

Data subject rights

As a controller, you need to be able to use your contract tools to find personal data and implement requests from data subjects to exercise their rights under Chapter III of the GDPR.

With Juro, you can use features in the platform for most routine requests. Juro’s OCR functionality allows users to find and retrieve personal data from contracts easily - an essential step in responding to a request from a data subject exercising data rights.

For more complex requests that you can’t serve using existing functionality in the platform, just contact support@juro.com and we’ll be happy to help.

Incident planning

As part of Juro’s compliance programme, we've implemented robust incident response plans to ensure we're prepared for any incidents affecting the Juro platform or our business more generally.

We have documented procedures for quickly detecting, investigating and remediating incidents, particularly those that could impact personal data.

Our procedures outline roles and responsibilities, communication protocols, containment and mitigation steps, and integration with our personal data breach notification processes.

Juro carries cyber insurance with a market-leading underwriter, which includes rapid access for the Juro team to the specialist resources and support required to respond to sophisticated cyber incidents.

Personal data breaches

We have a documented data breach response plan for detecting, investigating and mitigating the effects of any actual or suspected personal data breach. All personnel at Juro are trained to follow this plan if there is a suspected personal data breach, and that training is refreshed regularly.

If there is a personal data breach affecting personal data that Juro processes on your behalf, Juro will notify you without undue delay (as required under Article 33(2) GDPR).

When you sign your contract with Juro, we’ll collect details of a privacy contact at your organisation so that we can communicate directly and quickly with the right person in this situation.

We’ll also support you to respond to the personal data breach in line with your own obligations under the GDPR, in particular by providing information to support any notification you are required to make to a supervisory authority or affected data subjects.

As your processor, we won’t notify any supervisory authority or data subject ourselves.

Business continuity and disaster recovery

We have documented procedures to ensure the continuity and recoverability of our business in the event of an incident. You can find out more about the specific platform measures we have in place on our [security page].

Other incidents (including service outages)

We have an incident response plan for responding to all incidents affecting the Juro service (even those which do not affect personal data). Juro’s support and engineering teams are trained to respond to this if there is an incident, and we have engineers on-call outside of business hours to respond to urgent incidents.

You can find view the current operational status of the Juro platform (including historic uptime) on our status page.

We offer an uptime service level agreement to all our enterprise level customers.

Sub-processors

Juro has selected trusted partners and technology providers to help provide the Juro platform. These are our sub-processors, since they help Juro process personal data on your behalf.

Before selecting any sub-processor, we carry out a detailed assessment of that sub-processor, including an assessment of the technical and organisational security measures in place to protect personal data.

All our sub-processors have written agreements with Juro that contain the minimum contractual commitments required under Article 28(3) GDPR.

We update our sub-processor list when we make changes to our platform that remove or add a new sub-processor. When we make changes, we inform you by updating the sub-processor list.

We need the ability to make these updates so that we can continue to improve the Juro platform, and to respond to technological developments and evolving security requirements. For that reason, our DPA contains a general authorisation to appoint new sub-processors in accordance with Article 28(2) GDPR.

We remain legally responsible to our customers for the processing of personal data that our sub-processors carry out on our behalf, as set out in Article 28(4) GDPR.

EU representative

Juro has appointed its subsidiary SIA Juro Riga as its representative in the European Union in accordance with Article 27(1) GDPR. You can contact SIA Juro Riga via support@juro.com.

Security

We take our responsibility to protect the confidentiality, availability and integrity of the personal data we process on our customers’ behalf very seriously.

We have implemented a comprehensive security programme designed to protect personal data in our custody against unauthorised or unlawful processing and against accidental loss, destruction or damage.

You can find out more about the specific measures we have in place on our security page.

We update these measures from time to time to reflect updated security practices and to respond to emerging threats.

Last but not least, our disclaimer: this article is for general information only - it is not legal advice, so you should not rely on it.