JustCo Group's Privacy Policy

1. Introduction

At the JustCo Group ("JustCo") we respect the privacy and confidentiality of the personal information of our members and others whom we interact with in the course of providing our services as well as of applicants who apply for positions with us. We are committed to implementing policies, practices and processes to safeguard the collection, use and disclosure of the personal information you provide us.

We have developed this Policy to assist you in understanding how we collect, use, disclose, process, protect and retain your personal information that is in our possession. We will comply with all applicable laws with regards to information privacy, and where local laws are more stringent than this policy, then such laws shall prevail and JustCo shall comply with such laws.

This Policy will introduce:

  • How We Collect Your Personal Information
  • Types of Personal Information We Collect About You
  • How We Use Your Personal Information
  • Who We Disclose Your Personal Information To
  • How We Manage the Collection, Use and Disclosure of Your Personal Information
  • How We Ensure the Accuracy of Your Personal Information
  • How We Protect Your Personal Information
  • How We Retain Your Personal Information
  • How You Can Access, Delete and Make Correction to Your Personal Information
  • How We Handle Children's Personal Information
  • How Is Your Personal Information Transferred Around The World
  • Contacting Us
  • Changes to this Information Policy

Please read this Policy before using our products or enjoying our services.

2. How We Collect Your Personal Information

Personal information refers to any information that can uniquely identify an individual person (a) on its own, or (b) when combined with other information.

We collect your personal information when you:

  • Subscribe or purchase our services
  • Use our services
  • Enquire / respond to our range of services via our marketing, promotional campaigns including electronic direct mails (EDMs)
  • Are referred to us by one of our members and business partners
  • Provide feedback to us on our quality of service
  • Visit our websites and leave behind your contact information
  • Visit our locations which are being monitored by closed circuit television
  • Communicate with us via emails or written correspondences

We may also collect personal information from third parties such as your representatives or publicly available sources of information. If someone other than you provide us with personal information about you that we did not ask for and we determine that we could have collected this information from you had we asked for it, we will notify you as soon as practicable. This notice will be given unless to do so would be in breach of an obligation of confidence. If we could not have collected this personal information, we will lawfully dispose of or destroy that personal information.

3. Types of Personal Information We Collect About You

The types of personal information we collect about you include:

  • Contact information (Name, Phone No., Email Address)
  • Biometric information (Pictures, Video from security cameras, voice recordings)
  • Payment information (Credit/Debit Card Information)
  • Account information (account balance, valid subscriptions)
  • Location Data
  • Information on the use of our services (frequency of use of our services, location of use etc)
  • Information from other organisations (your employer or other entities we believe you have authorized to provide your personal details on your behalf)

4. How We Use Your Personal Data

We use the personal information you provide us for one or more of the following purposes:

  • Verify your identity
  • To provide you with our products or services
  • Manage and improve our business and operations to serve you better or enhance customer experience
  • Respond to opinions, comments or feedback about our products or services
  • Process and manage membership programme
  • Process billing, payment and other credit-related activities
  • Conduct direct marketing and lead generation activities
  • Conduct joint marketing with other companies and service providers
  • Communicate with customers, members and website visitors
  • Analyse the use of our products, services or websites
  • Comply with or fulfil legal obligations and regulatory requirements
  • Ensure the security and safety of our users

5. Who We Disclose Your Personal Information To

We disclose some of the personal information you provide us to our related corporations, as well as the following entities or organisations outside JustCo for one or more of the purposes set out in section 4:

  • EDM / Email Service Vendors
  • Payment processors and financial institutions
  • Research institutions
  • Advertisers / Advertising Agencies
  • Event Organisers
  • Our Information Processing and IT Services Providers to facilitate guest registration
  • Freight / Courier Services
  • HR / Payroll Processing Services and Insurance Companies
  • Government Agencies
  • Third party services providers in relation to providing our services to you

Where required to do so by law, we may disclose personal information about you to the relevant authorities or to law enforcement agencies.

6. How We Manage the Collection, Use and Disclosure of Your Personal Information

6.1 Obtaining Consent

Before we collect, use or disclose your personal data, we will notify you of the purpose why we are doing so, including via this Privacy Policy. You consent to the collection, use and disclosure of your personal data for the purposes set out in this Privacy Policy.

We will not collect more personal information than is necessary for the stated purpose.

Under certain circumstances, we may assume deemed consent from you when you voluntarily provide your personal information for the stated purpose, e.g. when you provide your name and payment details in order to purchase services from us.

We may rely on exceptions to the need for consent under applicable for the collection, use or disclosure of your personal information under the following circumstances. for example:

  • The personal information is publicly available
  • The personal information is disclosed by a public agency or disclosed to a public agency
  • The personal information is necessary for any investigation or proceedings
  • The personal information is necessary for evaluative purposes
  • The personal information is necessary to recover a debt owed by an individual to JustCo, or for JustCo to pay a debt owed to the individual
  • The personal data is necessary for a business asset transaction

6.2 Withdrawal of Consent

If you wish to withdraw consent, you should give us reasonable advance notice. We will advise you of the likely consequences of your withdrawal of consent, e.g. without your personal contact information we may not be able to inform you of future services offered by us.

Your request for withdrawal of consent can take the form of an email or letter to us, or through the "UNSUBSCRIBE" feature in an online service.

6.3 Use of Cookies

We use "cookies" to collect information about your online activity on our website. A cookie is a small text file created by the website that is stored in your computer to provide a way for the website to recognise you and keep track of your preferences. The cookie makes it convenient for you such that you do not have to retype the same information again when you revisit the website or in filling electronic forms.

Most cookies we use are "session cookies", which will be deleted automatically from the hard disk of your computer at the end of the session.

You may choose not to accept cookies by turning off this feature in your web browser. Note that by doing so, you may not be able to use some of the features and functions in our web applications.

7. How We Ensure the Accuracy of Your Personal Data

We will take reasonable steps to ensure that the personal data we collect about you is accurate, complete, not misleading and kept up-to-date.

From time to time, we may do a data verification exercise for you to update us on any changes to the personal data we hold about you. If we are in an ongoing relationship with you, it is important that you update us of any changes to your personal data (such as a change in your mailing address).

8. How We Protect Your Personal Data

We have implemented appropriate information security and technical measures (such as data encryption, firewalls and secure network protocols) to protect the personal data we hold about you against loss; misuse; destruction; unauthorised alteration/modification, access, disclosure; or similar risks.

We have also put in place reasonable and appropriate organisational measures to maintain the confidentiality and integrity of your personal data, and will only share your data with authorised persons on a 'need to know' basis.

When we engage third-party data processors to process personal data on our behalf, we will ensure that they provide sufficient guarantees to us to have implemented the necessary organisational and technical security measures, and have taken reasonable steps to comply with these measures.

9. How We Retain Your Personal Data

We have a document retention policy that keeps track of the retention schedules of the personal data you provide us, in paper or electronic forms. We will not retain any of your personal data when it is no longer needed for any business or legal purposes.

We will dispose of or destroy such documents containing your personal data in a proper and secure manner when the retention limit is reached.

10. How You Can Access and Make Correction to Your Personal Data

You may write in to us to find out how we have been using or disclosing your personal information. Before we accede to your request, we may need to verify your identity. We will respond to your request as soon as possible, and, where possible we will let you know and give you an estimate of how much time we require. We may also charge you a reasonable fee for the cost involved in processing your access request.

If you find that the personal information we hold about you is inaccurate, incomplete, misleading or not up-to-date you may ask us to correct the information. Where we are satisfied on reasonable grounds that a correction should be made, we will correct the information as soon as possible, or within 30 days from the date we receive your request.

You may request us to delete your personal information under the following circumstances:

  • If we deal with your personal information has violated any laws and regulations;
  • If we collect and use your personal information without obtaining your consent;
  • If we deal with personal information has violated any agreement with you;
  • If you no longer use our products or services;
  • If we no longer provide you with services.

If we decide to respond to your deletion request, we will also notify the entities that receive your personal information from us to delete it in a timely manner, unless otherwise required by laws and regulations, or those entities have obtained your independent authorization.

When you delete information from our services, we may not delete the corresponding information from the backup system immediately, but we will delete this information when the backup is updated.

We will not be able to respond to your request under the following circumstances:

  • It is related to the performance of obligations stipulated by laws and regulations by us;
  • It is directly related to national security and national defense security;
  • It is directly related to public safety, public health and major public interests;
  • It is directly related to criminal investigation, prosecution, trial and execution of judgment;
  • We have sufficient evidence to show that the subject of personal information has subjective malice or abuse of rights;
  • It is difficult to obtain consent for the purpose of safeguarding the life, property and other important legitimate rights and interests of the subject of personal information or other individuals;;
  • Responding to the request of the personal information subject will cause serious damage to the legitimate rights and interests of the personal information subject or other individuals and organizations;;
  • Involving commercial secrets.

11. How We Handle Children's Personal Information

Our products, websites and services are provided only to adults. Children should not create their own primary account for personal information without the consent of a parent or guardian.

In the case of collecting children's personal information with parental consent, we will only use or publicly disclose such information when permitted by law, with the express consent of a parent or guardian, or when it is necessary to protect the child.

Although local laws and customs define children differently, we consider anyone under the age of 14 to be a child.

If we find that we have collected children's personal information without first obtaining verifiable parental consent, we will seek to delete the information as soon as possible.

12. How Is Your Personal Information Transferred Around The World

In principle, the personal information we collect and generate in the People's Republic of China will be stored in the People's Republic of China.

Because we offer products or services through resources and servers worldwide, this means that, with your authorized consent, your personal information may be transferred to, or accessed from, foreign jurisdictions in the country/region in which you use products or services.

Such jurisdictions may or may not have different data protection laws. In such cases, we will ensure that your personal information is adequately and equally protected within the People's Republic of China. For example, we may request your consent to transfer your personal information across borders, or implement security measures such as data de-identification prior to cross-border data transfer.

13. Contacting Us

If you have any query or feedback regarding this Policy, or any complaint you have relating to how we manage your personal information, you may contact our Information Protection Officer (IPO) at: Dataprotection@JustCoGlobal.com

Any query or complaint should include, at least, the following details:

  • Your full name and contact information
  • Brief description of your query or complaint

We treat such queries and feedback seriously and will deal with them confidentially and within reasonable time.

14. Changes to this Information Policy

We may update this Information Policy from time to time. We will notify you of any changes by posting the latest Policy on our website. Please visit our website periodically to note any changes.

For material changes, we will also provide more prominent notice (including email notification for certain services stating specific changes to our personal information protection policy).

Material changes referred to in this Policy include, but are not limited to:

  • Material changes have taken place in our service model. Such as the purpose of personal information processing, the type of personal information processing, the use of personal information, etc.;
  • We have made material changes in ownership structure, organizational structure, etc. Such as business adjustment, bankruptcy and merger caused by the owner change;
  • The main objects of personal information sharing, transfer or public disclosure change;
  • Your rights of participating in the processing of personal information and the way to exercise them have changed significantly;
  • The department responsible for dealing with personal information security, contact information and complaint channels change;
  • The personal information security impact assessment report indicates that there is a high risk.

This Policy is released on 3 August 2021.

Changes to this Notice take effect when they are posted on our website.