Josys International Pte. Ltd.
– Privacy Policy
Last Updated: December 19, 2024
Josys International Pte. Ltd. (“Josys”, “we”, “us”, or “our”) is in the business of providing an integrated employee IT lifecycle management solution in the cloud, for businesses to drastically simplify their employee onboarding, offboarding and management of their overall IT needs.
Josys wants you to be familiar with how we collect, use and disclose Personal Information. This privacy policy (the “Privacy Policy”) explains how we collect, use, disclose, and safeguard your Personal Information when you:
- visit and use our website at stg.en.josys.com (the “Website”), which links to this Privacy Policy;
- register with us via the Website;
- participate in our training, seminars, webinars or other events (the “Events”);
- contact us (e.g., via post or email, or via the Website);
- subscribe to our newsletter (the “Newsletter”);
- use our social media pages which link to this Privacy Policy (collectively, our “Social Media Pages”) and/or
- receive HTML-formatted email messages or other communications that we send to you that link to this Privacy Policy,
(together, the “Offerings”).
Josys is committed to protecting the privacy of its users and this Privacy Policy is applicable to each of the Offerings.
- PERSONAL INFORMATION COLLECTED
- PERSONAL INFORMATION PROCESSING PURPOSES
- DISCLOSURE OF PERSONAL INFORMATION
- SECURITY
- EMAIL MARKETING CHOICES
- RIGHTS REQUESTS
- RETENTION PERIOD
- THIRD-PARTY SERVICES
- THIRD-PARTY ADVERTISING
- USE OF THE OFFERINGS BY MINORS
- CROSS-BORDER TRANSFERS
- SENSITIVE INFORMATION
- UPDATES TO THIS PRIVACY POLICY
- CONTACTING US
- OUR AFFILIATES
- CALIFORNIA SUPPLEMENT
- EEA/UK SUPPLEMENT
PERSONAL INFORMATION COLLECTED
“Personal Information” is information that identifies an individual or relates to an identifiable individual. We collect the following categories of Personal Information:
Personal Information we receive from you: |
|
---|---|
Name & Contact Details |
Such as first and last name, title, email address, telephone number, postal address. |
Business Contact Details |
Such as company name, name of employer, job title, business email address, business telephone number, business postal address, country of business. |
Account Information |
Such as your chosen username and password, and other information you share in your account. |
User Content |
Such as reviews about our products and services that we have provided to you, and other content you may create or share regarding our products and services, including posts on our Social Media Pages, and comment sections. |
Preferences |
Such as language, interests, and other feedback/preferences that you might express during your use of our services, products or Offerings. |
Marketing Data |
Such as your choices regarding our Newsletters, surveys, and other marketing/advertising displayed or provided to you, and preferred methods of such promotional communication. |
Relationship History |
Such as details of your communications with us, and details of your claims, complaints, and queries in general. |
Transaction Information |
Such as details of products and services that you have purchased from us. |
Visitor and Event Information |
Such as issued identification passes to access the premises, and other details specific to a particular event or conference that you share with us. |
User Photographs and Videos |
Such as photos and videos submitted by you while using our Offerings. |
Recordings |
Such as audio and/or video recordings of telephone calls when you contact us or of online webinars, and other Events provided by us. |
Personal Information we collect through your use of our Offerings or from other sources, such as publicly available databases, joint marketing partners, service providers, public and/or government and/or regulatory authorities, including the courts. |
|
Billing Information |
Such as debit or credit card details, bank account details, billing address. |
IP Address |
Your IP address is automatically assigned to your computer by your internet service provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Offerings, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications, and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems, and administering the Offerings. We may also derive your approximate location from your IP address. |
Device Information |
Such as information about your devices (e.g., internet connection) and your use of our Offerings. |
Event Photographs and Videos |
Such as photos and videos taken at one of our Events. |
CCTV and Site Security Information |
Such as images or video footage captured or recorded by CCTV and other security measures on our premises. |
Social Media Information |
Such as profile pictures, social media account ID, and other social media profile information, including individual profile URLS and lists of friends/followers on social media. |
We need to collect Personal Information to provide the requested Offerings to you. If you do not provide the information requested, we may not be able to provide the Offerings. We will note which Personal Information is required to provide the Offerings at the time of its collection.
If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Offerings, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.
PERSONAL INFORMATION PROCESSING PURPOSES
We use Personal Information for legitimate business purposes, including:
Purpose |
Examples of Processing Activities |
---|---|
Providing the functionality of the Offerings |
Providing the functionality of the Offerings to you, such as arranging access to your online account; facilitating your purchases and provision of purchased products and services; verifying your information; processing your orders and related payments; processing requests for a refund. |
Customer Services |
Verifying your information; administering customer-care services to facilitate and address inquiries, requests, comments and complaints about any of our products, services or Offerings (such as in person, through phone lines, email, or on social media), for example, to send you documents or product information you request or assist you in using the Offerings. |
Communicating important changes / Messages about our Offerings |
Sending you important information regarding our relationship with you, our products, services or Offerings, any changes to our terms, conditions, policies and procedures, and/or other administrative information. |
Operations and general business |
Administering online Offerings (including troubleshooting and diagnostic testing, conducting performance analyses of our systems and Offerings, testing new system features to evaluate their impact, system and log maintenance, technical support, system debugging, and hosting data); employee training and managing work activities and personnel generally; and facilitating mergers, acquisitions and other reorganizations and restructurings of our business (including prospective transactions). |
Conferences, visits, and other Events |
Facilitating and participating in conferences and other Events, and welcoming guests and visitors to our premises. |
Marketing |
Sending promotional information about our Offerings, products, services, Newsletters, promotions, offers and other news about our company that we think may be of interest to you; fulfilling your Event registration requests and providing services, including the providing seminars and other Events. |
Promotions and contests |
Conducting prize promotions, contests and other promotional offers, in relation to Josys products. If you participate, we will use your information to administer such promotions and offers. Some of these promotions have additional rules containing information about how we will use and disclose your Personal Information, which we will communicate to you separately. |
Relationship building and engagement |
Facilitating and responding to any social sharing and posts on our Offerings. |
Personalizing our Offerings |
Personalizing our interactions with you and providing you with information and/or offers tailored to your interests, such as targeted advertising tailored to your interests, on our Website, delivering content via email that we believe will be relevant and interesting to you. |
Improving and developing new products and Offerings that we may provide to you |
Conducting data analysis, for example, monitoring and analyzing use of our Offerings and using data analytics to improve the efficiency of our Offerings; developing new Offerings; considering ways to enhance, improve, repair, maintain or modify our current products.services and Offerings; identifying usage trends, for example, understanding which parts of our Offerings are most interesting to users; determining the effectiveness of our promotional campaigns, so we can adapt our campaigns to the needs and interests of our users; and operating and expanding our business activities, for example, understanding which parts of our Offerings are of most interest to our users so we can focus our energies on meeting our users’ interests. |
Aggregation and/or anonymization |
Aggregating and/or anonymizing Personal Information so that it will no longer be considered Personal Information. |
Security and fraud prevention |
Conducting audits, verifying that our internal processes function as intended and are compliant with legal, regulatory, or contractual requirements; monitoring for and preventing fraud; and for security purposes, including maintaining system security and on-site security of our premises. |
Legal and compliance |
Fulfilling our legal and compliance-related obligations, including complying with applicable laws; complying with legal processes; responding to requests from public and government authorities; meeting national security or law enforcement requirements, compliance with requirements set by industry-specific supervisory bodies. Enforcing our terms and conditions and standards; protecting our operations; protecting our rights, privacy, or property; responding to auditors; and allowing us to pursue available legal remedies and make insurance claims, defend claims, and limit the damages that we may sustain. See the “EEA/UK SUPPLEMENT” section for more information regarding our processing for legal and compliance purposes. |
Emergency and incident response |
Ensuring the safety of on-site personnel and visitors; responding to, handling, and documenting on-site accidents and medical and other emergencies; actively monitoring properties to ensure adequate incident prevention, response, and documentation (including CCTV); requesting assistance from emergency services; and sending notifications and alerts in the event of incidents or emergencies (such as via SMS, email, call, audio-visual device prompts, etc.). |
For more information on our use of Personal Information subject to the EU or UK General Data Protection Regulation for the purposes described above, please see the “EEA/UK SUPPLEMENT” section.
DISCLOSURE OF PERSONAL INFORMATION
We disclose Personal Information to third parties and for the purposes described below, depending on each specific jurisdiction and applicable law:
Recipients |
Purpose |
---|---|
Josys affiliates |
|
Payment processing service providers |
|
Website hosting service providers |
|
Information technology and related infrastructure service providers |
|
Email delivery service providers |
|
Advertising networks |
|
Customer service or related benefits (including special promotions) service providers |
|
Order fulfillment service providers |
|
Analytics providers for our Offerings |
|
Law enforcement, public, regulatory and government authorities, courts or tribunals |
|
Emergency services |
|
Other services, including, without limitation, our Social Media Pages |
|
To comply with applicable law and regulations |
|
To a third party, such as an acquiring entity and its advisors, in connection with a sale or business transaction |
You will be notified of any such business transaction and of possible changes to the processing of your Personal Information in accordance with applicable law and the “UPDATES TO THIS PRIVACY POLICY” section |
SECURITY
We seek to use reasonable organizational, technical, and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “CONTACTING US” section below.
EMAIL MARKETING CHOICES
You have choices regarding marketing-related communications. Where required by applicable law, we will ask for your prior opt-in consent.
If you no longer want to receive marketing-related emails from us in the future, you may opt-out by following the unsubscribe instructions in any such message or by contacting us by email at support@stg.en.josys.com.
We will try to comply with your request as soon as reasonably practicable. Please note that if you opt out of receiving email marketing from us, we may still send you important administrative messages, from which you cannot opt out.
RIGHTS REQUESTS
If you would like to request to access/review, correct, update, suppress/delete, object to, restrict or opt out of the processing of Personal Information, withdraw your consent (which will not affect the lawfulness of processing prior to the withdrawal), or if you would like to request to receive an electronic copy of your Personal Information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), please feel free to contact us via email at support@stg.en.josys.com. We will respond to your request consistent with applicable law. If you are a California resident, please refer to the “CALIFORNIA SUPPLEMENT” section at the end of this Privacy Policy for more information about the requests you may make under California law.
In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. For your protection, we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion). Further, certain Personal Information may be exempt from requests pursuant to applicable data protection laws or other laws and regulations.
You may also lodge a complaint with a data protection authority for your country or region, or where an alleged infringement of applicable data protection law occurs. A list of EEA data protection authorities is available at: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm. Information regarding the UK data protection authority is available at: https://ico.org.uk/.
RETENTION PERIOD
We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained as outlined in this Privacy Policy, unless a longer retention period is required or permitted by applicable law (e.g., for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements). The criteria used to determine our retention periods include:
- The length of time we have an ongoing relationship with you and provide our products, services or Offerings to you (for example, for as long as you have an account with us or keep using our products, services or Offerings);
- Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
- Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).
Where we are subject to a legal obligation or retention is recommended in light of our legal position, we will retain certain Personal Information even after your account has been deleted and/or we no longer provide our products, services or Offerings to you, for example:
- To cooperate with law enforcement or public, regulatory and government authorities: If we receive a preservation order or search warrant, related to your products, services or Offerings account, we will preserve Personal Information subject to such order or warrant after you delete your products, services or Offerings account;
- To comply with legal requirements: We may retain your Personal Information, such as Relationship History, and/or Transaction Information after you delete your products, services or Offerings account, as required by tax law and to comply with bookkeeping requirements; or
- To pursue or defend a legal action: We may retain relevant Personal Information in the event of a legal claim or complaint, including regulatory investigations or legal proceedings about a claim related to your Personal Information, or if we reasonably believe there is a prospect of litigation.
In some circumstances, we will anonymize your Personal Information (so that it can no longer be associated with you) for research or statistical purposes so that we can obtain insights (e.g., into the average number of applications managed by customers using our platforms), in which case we may use this information indefinitely without further notice to you.
THIRD-PARTY SERVICES
This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties. This includes any third party operating any website or service to which the Offerings link. The inclusion of a link on the Offerings does not imply endorsement of the linked site or service by us or by our affiliates.
The Offerings may provide functionality allowing you to make payments to us using third-party payment services with which you have created your own account. When you use such a service to make a payment to us, your Personal Information will be collected by such third party and not by us, and will be subject to the third party’s privacy notice, rather than this Privacy Policy. We have no control over, and are not responsible for, this third party’s collection, use, and disclosure of your Personal Information.
In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Apple, Google, Microsoft or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Website or our Social Media Pages.
THIRD-PARTY ADVERTISING
We use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the Offerings and other websites or online services.
You may receive advertisements based on information relating to your access to and use of the Offerings and other websites or online services on any of your devices, as well as on information received from third parties. These companies place or recognize a unique cookie on your browser (including through the use of pixel tags). They also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop. If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this Privacy Policy, please visit http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/#/. You may download the AppChoices at www.aboutads.info/appchoices to opt out in mobile apps.
USE OF THE OFFERINGS BY MINORS
The Offerings are not directed to individuals under the age of 18, and we do not knowingly collect Personal Information from individuals under 18.
CROSS-BORDER TRANSFERS
Your Personal Information may be stored and processed in any country or region where we have facilities or in which we engage service providers. By using the Offerings, you understand that your Personal Information will be transferred to countries outside of your country or region of residence, which may have data protection rules that are different from those of your country or region. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries or regions may be entitled to access your Personal Information.
As required by applicable law, we implement safeguards to protect your Personal Information when we transfer it outside your country or region of residence. For example:
- For transfers from within the UK and/or EEA to outside the UK and/or EEA, we ensure a similar degree of protection is afforded to it by ensuring that at least one of the following safeguards is implemented:
- Adequacy Decisions: Some countries outside of the European Economic Area (the “EEA”), are recognized as providing an adequate level of data protection (the full list of these “specified countries” for the EEA is available here and for the UK is available here).
- Adequate Measures: For transfers from the EEA, Switzerland, and/or the UK to countries not considered adequate, we have put in place adequate measures, such as standard contractual clauses adopted by the relevant authority, to protect your Personal Information. You may obtain a copy of these measures by emailing us at support@stg.en.josys.com.
- For transfers from Japan to countries not considered adequate by the Japanese government (as applicable), we have also put in place adequate measures, such as data transfer agreements containing provisions required under Japanese law, to protect your Personal Information.
SENSITIVE INFORMATION
Unless we request it, we ask that you not disclose or send us, on or through the Offerings, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership).
UPDATES TO THIS PRIVACY POLICY
The “LAST UPDATED” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Offerings.
CONTACTING US
Josys is the company responsible for collection, use and disclosure of your Personal Information under this Privacy Policy. If you have any questions about this Privacy Policy, please contact us at:
- Email: support@stg.en.josys.com
- Address: Josys International Pte. Ltd., 600 North Bridge Road, #12-04, Singapore 188778
Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.
OUR AFFILIATES
For purposes of this Privacy Policy, these entities are considered Josys affiliates:
- Josys, Inc.
- Josys Digital Technologies India Private Limited
CALIFORNIA SUPPLEMENT
Pursuant to the California Consumer Privacy Act (“CCPA”), we are providing the following additional details regarding the categories of Personal Information about California residents that we collect, use, and disclose. This section supplements the information provided above in this Privacy Policy. [
We collect and disclose to affiliates and service providers for our operational business purposes (including in the preceding 12 months) the following categories of Personal Information about California residents:
- Identifiers such as name, postal address, online/device identifier, IP address, username and password, email address, and social media account and business contact information.
- Personal information as defined in the California customer records law, such as name, signature, contact information, and other information you may share or make public on our Social Media Pages.
- Commercial information, such as Offerings transaction history, financial details, and payment information.
- Internet or other electronic network activity information, such as browsing history and interactions with our Website, systems, and emails.
- Geolocation data, such as IP location.
- Audio, electronic, visual, and similar information, such as call recordings and CCTV footage created for safety and security purposes, and audio and video recordings of Events.
- Professional or employment-related information, such as employer name, business contact information, and role/title.
- Sensitive Personal Information. Personal Information that reveals an individual’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation.
We retain each category of Personal Information, including Sensitive Personal Information, as described above under “RETENTION PERIOD”.
We do not “sell” Personal Information, including Sensitive Personal Information, and we do not “share” Personal Information, including Sensitive Personal Information, for purposes of cross-context behavioral advertising, as defined under the CCPA. We have not engaged in such activities in the preceding 12 months. Without limiting the foregoing, we do not sell or “share” Personal Information, including Sensitive Personal Information, of minors under 16 years of age.
We collect, use, and disclose Personal Information for the purposes described above under “PERSONAL INFORMATION COLLECTED”.
We collect, use and disclose Sensitive Personal Information for purposes of performing services for our business, providing products or performing services as requested or reasonably expected by you, ensuring safety, security and integrity, countering wrong or unlawful actions, short term transient use, servicing accounts, providing customer service, verifying customer information, processing payments, activities relating to quality and safety control or product improvement, and other collection and processing that is not for the purpose of inferring characteristics about an individual. We do not use Sensitive Personal Information for additional purposes.
We collect Personal Information from a number of sources as described above under “PERSONAL INFORMATION COLLECTED”.
Individual Rights and Requests
You may request that we:
- Disclose to you the following information:
- The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
- The business or commercial purpose for collecting Personal Information about you; and
- The categories of Personal Information about you that we disclosed, and the categories of third parties to whom we disclosed such Personal Information (if applicable).
- Correct inaccuracies in your Personal Information.
- Delete Personal Information we collected from you.
- Provide the specific pieces of your Personal Information, including a copy in a portable format.
To make a request, please email support@stg.en.josys.com or call us at +1 888-904-2349.
We will verify and respond to your request consistent with applicable law, considering the type and sensitivity of the Personal Information subject to the request. For your protection, we may need to request information such as your name, email address, mailing address, and relationship with us in order to verify your identity and protect against fraudulent requests. If you make a deletion request, we may ask you to verify your request before we delete your Personal Information.
You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.
If an agent would like to make a request on your behalf as permitted by applicable law, the agent may use the submission methods noted above. As part of our verification process, we may request that the agent provide, as applicable, proof concerning their status as an authorized agent. In addition, we may require that you verify your identity as described above or confirm that you provided the agent permission to submit the request.
De-Identified Information
Where we maintain or use de-identified information, we will continue to maintain and use that information only in a de-identified form and will not attempt to re-identify the information.
Sharing your Personal Information with Third Parties for Direct Marketing Purposes
California Civil Code Section § 1798.83 permits California residents to request certain information regarding our disclosure of their Personal Information to third parties for their direct marketing purposes. If you would like to learn more about this or to make a request to discontinue this type of sharing, please email us at t support@stg.en.josys.com. We will provide a list of the categories of Personal Information disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We will respond to your request in accordance with applicable law.
EEA/UK SUPPLEMENT
We and our service providers use Personal Information for legitimate business purposes, including:
Processing Purpose (See Section 2) |
Personal Information Categories (See Section 1) |
Legal Basis |
Third-Party Sources |
---|---|---|---|
Providing the functionality of the Offerings |
Name & Contact Details; Business Contact Details; Account Information; Billing Information; User Content; Preferences; Marketing Data; Relationship History; Transaction Information; Visitor and Event Information; Device Information; Recordings; IP Address; and Social Media Information. |
Performance of the contract, including fulfilling the terms and conditions of the Josys Services Agreement we enter into with you to provide the Offerings. Legal obligations, such as to inform you of material changes to our terms and conditions to comply with applicable consumer and/or data protection laws. |
Publicly available databases, joint marketing partners. |
Providing customer Services |
Name & Contact Details; Business Contact Details; Account Information; Billing Information; Relationship History; Transaction Information; Device Information; Recordings; and Preferences. Personal information about third parties in connection with the Offerings we are instructed to provide. |
Performance of the contract, including fulfilling the terms and conditions of the Josys Services Agreement we enter into with you to provide the Offerings. Legitimate interests, such as responding to inquiries or complaints. Legal obligations, such as when you submit a request to access your Personal Information. |
N/A |
Operations and general business |
Personal Information as relevant for the specific business operation. |
Legitimate interests, such as responding to customer complaints and concerns. Legal obligations, for example, relating to financial transactions, such as the obligation to maintain books and records. |
Third party organizations, for example, to facilitate mergers, acquisitions and other business reorganization and restructurings. |
Visits, conferences, and other Events |
Name & Contact Details; Business Contact Details; Account Information; Preferences; Billing Information; Relationship History; Transaction Information; Device Information; Marketing Data; Event Photographs and Videos; IP Address; CCTV and Site Security information. |
Performance of a contract with you, such as collecting information regarding a planned Event in which you participate. Legitimate interests, such as responding to customer complaints or concerns relating to an Event. |
Event management service providers. |
Marketing |
Name & Contact Details; Business Contact Details; Account Information; Relationship History; Transaction Information; Preferences; Marketing Data; Event Photographs and Videos; User Content; Device Information; IP Address; and Social Media Information. |
Legitimate interests, such as to promote our Offerings and/or products. Consent, for example, where we would like to send you direct email marketing communications, but do not have an existing relationship with you. |
Publicly available databases. Marketing / advertising service providers. Data broker service providers. |
Promotions and contests |
Name & Contact Details; Business Contact Details; Account Information; Relationship History; Transaction Information; Preferences; Marketing Data; Device Information; User Content; User Photographs and Videos; Event Photographs and Videos; and Social Media Information. |
Legitimate interests, such as to promote our Offerings and/or products. Performance of contract, such as fulfilling obligations associated with a contest. |
|
Personalizing our Offerings |
Name & Contact Details; Business Contact Details; Account Information; Marketing Data; Social Media Information; Relationship History; IP Address; Transaction Information; Device Information; and Preferences. |
Consent, for example, where we would like to send you alerts tailored to your specific interests. Legitimate interests, such as providing tailored Offerings based on past usage and/or preferences, and such tailoring would be based on basic and privacy-non-intrusive segmentation. |
|
Improving and developing new products and Offerings |
Name & Contact Details; Business Contact Details; Relationship History; Account Information; Transaction Information; Preferences; User Content; Device Information; IP Address; Recordings; and Social Media Information. |
Legitimate interests, such as developing new Offerings and/or products. |
|
Relationship building and engagement |
Name & Contact Details; Business Contact Details; Account Information; Marketing Data; Social Media Information; IP Address; and User Content. |
Legitimate interests, such as when we engage with individuals who post on our Social Media Pages. |
Marketing / advertising service providers. Data broker service providers. |
Aggregation and/or anonymization |
Personal Information as relevant for the specific business purpose. |
Legitimate interests, such as to generate non-personal information that we may use and disclose for any purpose. |
N/A |
Fraud prevention and security |
Name & Contact Details; Business Contact Details; Account Information; Billing Information; Device Information; Relationship History; Recordings; CCTV and Site Security Information; IP Address; and Transaction Information. |
Legal obligations, such as to detect and prevent cyberattacks. Legitimate interests, such as to identify and/or prevent fraudulent transactions. |
N/A |
Legal and compliance |
Personal Information as relevant for the specific legal action, regulatory investigation, and/or legal processes in question, which may include: Name & Contact Details; Business Contact Details; Account Information; Billing Information; User Content; Preferences; Marketing Data; Relationship History; Transaction Information; Visitor and Event Information; User Photographs and Videos; Social Media Information; Event Photographs and Videos; CCTV and Site Security Information; Recordings; Device Information; and IP Address. |
Legal obligations, such as to comply with legal processes and corporate governance obligations. Legitimate interests, such as to enforce terms and conditions, to protect trademarks, and to bring or defend legal claims. |
Public and/or government and/or regulatory authorities, including courts, tribunals, and regulators. Third persons relevant to the specific legal action and/or processes in question (such as lawyers, auditors, insurers, advisory firms etc.). |
Emergency and incident response |
Name & Contact Details; CCTV and Site Security Information; IP Address; and Visitor and Event Information. |
Legal obligations, for example, relating to health and safety regulations and to document on‑site accidents. Legitimate interests, such as to monitor properties through CCTV to ensure individuals’ safety. Protecting individuals’ vital interests, such as contacting medical or emergency services where an individual’s life is at risk. |
Not applicable |
In addition, we process Personal Information:
- To comply with applicable law and regulations. This may include laws outside your country of residence, which could give rise to a legal obligation requiring us to process your Personal Information, including:
- Civil and commercial matters: where we are in receipt of a court order to disclose information for the purposes of court proceedings, such as under Regulation (EU) No 1215/2012 on jurisdiction and the recognition and enforcement of judgments in civil and commercial matters or equivalent UK law.
- Criminal matters: to comply with requests and orders from EU and EU Member State or UK law enforcement to provide information in relation to a criminal investigation in compliance with applicable local laws, or to take steps to report information we believe is important to law enforcement where so required or advisable under applicable local laws.
- Consumer matters: to comply with requests from competent authorities under EU or EU Member State or UK consumer protection law, such as under Directive (EU) 2019/2161 and its implementing laws in EU Member States or equivalent UK law.
- Corporate and taxation matters: to comply with our obligations under applicable EU Member State or UK corporate and tax legislation, such as where a national tax law of an EU Member State or the UK requires collection of specific transactional Personal Information for tax purposes.
- Regulatory matters: to respond to a request or to provide information we believe is necessary or appropriate to comply with our obligations to engage with regulators, such as when relevant EU Member State or UK data protection supervisory authorities initiate investigation under the EU or UK General Data Protection Regulation into our company. These can include authorities outside of your country or region of residence.
- Compliance and internal investigations: to comply with whistleblowing requirements under Directive (EU) 2019/1937 and its implementing laws in EU Member States.
- Health and safety regulations: to comply with health and safety reporting obligations in accordance with applicable local laws, such as in relation to accidents involving members of the public on our premises.
- To cooperate with public and government authorities and law enforcement, and for other legal reasons:
- When we respond to a request or provide information to public and government authorities (these can include authorities outside your country or region of residence);
- When we respond to law enforcement requests and orders or provide information to law enforcement;
- For dispute resolution purposes;
- To enforce our terms and conditions; and
- To protect our rights, privacy, safety, property, and/or that of our affiliates, you, or others.
- In connection with a sale or business transaction based on our legitimate interests.