1. Introduction
At JustCo we respect the privacy and confidentiality of the personal data 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 data you provide us.
We have developed this Data Protection Notice to assist you in understanding how we collect, use, disclose, process, protect and retain your personal data that is in our possession. We will comply with all applicable laws with regards to data privacy, and where local laws are more stringent than this policy, then such laws shall prevail and JustCo shall comply with such laws.
This Data Protection Notice will apply to the collection and processing of the personal data of our members and others whom we interact with in the course of providing our services.
2. How We Collect Your Personal Data
Personal data refers to any information that can uniquely identify an individual person (a) on its own, or (b) when combined with other information.
In order to achieve the purposes as set forth in section 4, we collect your personal data when you:
The scope of the personal data collection will be kept to the minimum and necessary extent to achieve the specified purposes set forth in section 4.
3. Types of Personal Data We Collect About You
The types of personal data we may collect about you include:
4. How We Use Your Personal Data
We use the personal data set out in Section 3 for one or more of the following purposes hereunder, and solely for such purposes.
In the event of any changes in the processing purpose, we will take necessary measures such as obtaining your separate consent. Further, we will use and store your personal data from the date of consent until the purpose of collection and usage is achieved, other than the exceptions listed below. Thereafter, Personal Data will be destroyed in accordance with our data retention policy or applicable laws.
Processing Purpose | Data use and retention period | Categories of Personal Data |
Respond to opinions, comments or feedback about our products or services | From the date of consent until the purpose of collection and usage is achieved. Thereafter, Personal Data will be destroyed in accordance with our data retention policy or applicable laws. In accordance with the Act on the Consumer Protection, in Electronic Commerce, Etc.
| Contact Information |
Process and manage your accounts/contracts with us | From the date of consent until the purpose of collection and usage is achieved. Thereafter, Personal Data will be destroyed in accordance with our data retention policy or applicable laws. In accordance with the Act on the Consumer Protection, in Electronic Commerce, Etc.
| Contact Information Payment Information |
Process billing, payment and other credit-related activities | From the date of consent until the purpose of collection and usage is achieved. Thereafter, Personal Data will be destroyed in accordance with our data retention policy or applicable laws. In accordance with the Act on the Consumer Protection, in Electronic Commerce, Etc.
| Contact Information Payment Information |
5. Sharing of Personal Data to Third Parties & Entrustment
We disclose some of the personal data you provide us, as a way of provision or entrustment, to third-party entities or organisations outside JustCo in order to fulfil our services to you. Your personal data will only be shared with the specified recipients outlined if:
Third-party Entrustment
The name of third party | The purpose and use of the data | The period of use and retention | The items of personal data to be entrusted |
For the ad platform to understand our audience profile and optimise our audience targeting | From the date of consent until the purpose of collection and usage is achieved. Thereafter, Personal Data will be destroyed in accordance with our data retention policy or applicable laws. | Contact Information | |
For the ad platform to understand our audience profile and optimise our audience targeting | From the date of consent until the purpose of collection and usage is achieved. Thereafter, Personal Data will be destroyed in accordance with our data retention policy or applicable laws. | Contact Information | |
Naver | For the ad platform to understand our audience profile and optimise our audience targeting | From the date of consent until the purpose of collection and usage is achieved. Thereafter, Personal Data will be destroyed in accordance with our data retention policy or applicable laws. | Contact Information |
Stripe | For the processing of online payments | From the date of consent until the purpose of collection and usage is achieved. Thereafter, Personal Data will be destroyed in accordance with our data retention policy or applicable laws. | Payment Information |
Envoy | For registration and processing of guest visits | From the date of consent until the purpose of collection and usage is achieved. Thereafter, Personal Data will be destroyed in accordance with our data retention policy or applicable laws. | Contact Information |
SurveyMonkey | For conducting and processing surveys | From the date of consent until the purpose of collection and usage is achieved. Thereafter, Personal Data will be destroyed in accordance with our data retention policy or applicable laws. | Contact Information |
MailChimp | For EDM services | From the date of consent until the purpose of collection and usage is achieved. Thereafter, Personal Data will be destroyed in accordance with our data retention policy or applicable laws. | Contact Information |
AWS RDS | Database | From the date of consent until the purpose of collection and usage is achieved. Thereafter, Personal Data will be destroyed in accordance with our data retention policy or applicable laws. | All items set out in section 3 |
Microsoft Sql Server | PowerBi | From the date of consent until the purpose of collection and usage is achieved. Thereafter, Personal Data will be destroyed in accordance with our data retention policy or applicable laws. | All items set out in section 3 |
Zendesk | To provide help desk assistance | Only on request | Contact Information |
6. Entrustment, Transfer to Other Countries
We may entrust, store, or provide (including making relevant inquiries) your personal data to third parties overseas in order fulfil our services to you. Your personal data, therefore, may be subject to privacy laws that are different from those in your country. In such instances we shall ensure that the transfer of your personal data is carried out in accordance with applicable privacy laws and, in particular, that appropriate contractual, technical, and organizational measures are in place to protect your data.
In the event we provide your personal data to the third parties overseas, your separate consent will always be requested.
Overseas Entrustment
Name of third party | Personal data transferred | Purpose of transfer | Country | Date of the transfer and methods | Period of use and retention |
Amazon Web Services, Inc | Items listed in section 3 | Data storage and file-sharing | Singapore | Transmission over the network at the time of the service | From the date of transmission over the network until the purpose of collection and usage is achieved |
Overseas Provision
Name of third party | Personal data transferred | Purpose of transfer | Country | Date of the transfer and methods | Period of use and retention |
All related companies of JustCo | Items listed in section 3 | Purposes listed in section 4 | Singapore | Transmission over the network at the time of the service | From the date of transmission over the network until the purpose of collection and usage is achieved. |
7. How We Manage the Collection, Use and Disclosure of Your Personal Data
7.1 Obtaining Consent
Before we collect, use or disclose your personal data, we will notify you of the purpose why we are doing so. We will obtain written confirmation from you on your expressed consent. We will not collect more personal data than is necessary for the stated purpose. We will seek fresh consent from you if the original purpose for the collection, use or disclosure of your personal data has changed.
Under certain circumstances, we may assume deemed consent from you when you voluntarily provide your personal data for the stated purpose, e.g. when you apply for a job with us using our job application forms.
We may rely on exceptions to the need for consent under applicable for the collection, use or disclosure of your personal data under the following circumstances. for example:
7.2 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.
7.3 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 how you interact with online content and ads, to assess the performance of our website and to personalise the content and ads that you see to 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.
8. 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).
9. 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.
10. How We Retain and Delete 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 (i.e. period of retention), or once the purpose of the personal data has been achieved and is no longer necessary.
The process and method of destruction are as follows:
11. How You Can Access and Make Correction to Your Personal Data
You or your legal representative may request at any time to view, correct/delete, suspend the processing of, and withdraw consent to your personal data. Additionally, you may write in to us to find out how we have been using or disclosing (by means of provision or entrustment to the third parties) your personal data. 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 to the extent permitted by the applicable law for the cost involved in processing your access request.
If you find that the personal data we hold about you is inaccurate, incomplete, misleading or not up-to-date you may ask us to correct the data. Where we are satisfied on reasonable grounds that a correction should be made, we will correct the data as soon as possible, or within 10 days from the date we receive your request.
12. Contacting Us
If you have any query or feedback regarding this Policy, or any complaint you have relating to how we manage your personal data, you may contact our Data Protection Officer (DPO) at: [email protected]
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.
You may make queries to the following organizations to make reports or consultations on other privacy infringements. The following organizations are independent organizations from JustCo, which you may utilize if you are not satisfied with the way we have handled your personal data related complaints or need further assistance:
13. Changes to this Data Protection Notice
We may update this Data Protection Notice from time to time. We will notify you of any changes by posting the latest Notice on our website. Please visit our website periodically to note any changes.
Changes to this Notice take effect when they are posted on our website, and the effective date will be written on the updated version of this Notice.
You can also access the previous Notice via a link below:
14. Link
We may display advertisements from third parties and other content that links to third-party websites and/or applications. We cannot control or be held responsible for third parties’ privacy practices and content. If you click on a third-party advertisement or link, please understand that any personal data you provide or is collected will not be covered by this Notice. Please read their privacy policies to find out how they collect and process your personal data.
15. Children
Our service is not directed to those under the age of 19 years, including children under the age of 14 years. Our service is also not offered to children whose age makes it illegal to process their personal data or requires parental consent for the processing of their personal data under applicable local law.
We do not knowingly collect personal data from children under 14 years or under the applicable age limit (the “Age Limit”). If you are under the Age Limit, please do not use our service, and do not provide any personal data to us.
If you are a parent of a child under the Age Limit and become aware that your child has provided personal data to us, please contact our DPO, and you may request exercise of your applicable rights to view, correct/delete, suspend the processing of, and withdraw consent to your personal data.
In the event that we find out that we have collected personal data from children under 14 years, we will take appropriate measures to delete such personal data.
Updated 27 July 2021
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