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:
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:
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:
4. How We Use Your Personal Data
We use the personal information you provide us for one or more of the following purposes:
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:
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:
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 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:
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:
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:
This Policy is released on 3 August 2021.
Changes to this Notice take effect when they are posted on our website.
