Effective date: December 1st, 2022
Our websites and the Jua Platform may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies and practices.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you and your organisation depending on the Jua services you use and your relationship with us. We may process the following categories of information:
We use different methods to collect data from and about you including through:
We may receive personal data about you from various third parties, including:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Typical cases for which we may use your personal data include:
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Generally, we do not rely on consent as a legal basis for processing your personal data. However, we will not send you any marketing communications and we will not share your personal data with any third party for marketing purposes without your prior explicit opt-in. You have the right to withdraw consent to marketing by following the opt-out links on any marketing message sent to you or by contacting us at any time.
We may share your personal data with the parties set out below:
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Some of our external third parties may be based outside the EEA so their processing of your personal data may involve a transfer of data outside the EEA. Where we transfer your personal data to countries outside the EEA that have not been deemed to provide an adequate level of protection for personal data by the European Commission we will undertake to incorporate contractual clauses approved by the European Commission which give your personal data the same protection it has in Europe.
We have put in place appropriate technical and organisational measures to prevent your personal data from being accidentally lost, used, altered, disclosed or accessed in an unauthorised way. We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. Those will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. By law we have to keep basic information about our customers (including Contact and Identity Data) for six years after they cease being customers for tax purposes. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. In some circumstances you can ask us to delete your data as per the provisions in the following sections.
You have the right to:
Usually no fee required You will not have to pay a fee to access your personal data or to exercise any of your rights listed above. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances. What we may need from you We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. Time limit to respond We aim to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.