At the JustCo Group (“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.
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.
We collect your personal data when you:
- Enquire / respond to our range of services via our marketing, promotional campaigns including electronic direct mails (EDMs)
Enrol as our members
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
Communicate with us via emails or written correspondences
Submit your CV and job application form to us in response to our recruitment advertisements
Submit your CV to recruitment firms or job portals, which are in turn forwarded to or retrieved by us
3. Types of Personal Data We Collect About You
The types of personal data we collect about you include:
- Contact information (Name, Address, Phone No., Email Address)
- Personal details (Name, NRIC No./FIN No./Passport No., Gender, Date of Birth, Country of Birth, Country of Residence, Citizenship, Nationality, Race/Ethnicity), where applicable
- Payment / financial information (Bank Account No., Credit/Debit Card Name, Credit/Debit Card No., Card expiry date)
- For Job Application, personal details (Name, NRIC No./FIN No./Passport No., Gender, Date of Birth, Race/Ethnicity, Citizenship, Nationality, Marital Status, Family background, Religion, Languages spoken or written, Household/Personal Income), educational and professional qualifications (Highest education level, Qualifications, Schools Attended, Academic transcripts, Membership of professional bodies, Certifications), and professional / work experience (Job title, Occupation, Employment history, Employment pass status, Work experience, Curriculum Vitae)
4. How We Use Your Personal Data
We use the personal data you provide us for one or more of the following purposes
- 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
- Process employee related activities
- Process employment passes of clients with the relevant government agencies
- Process job applications, recruitment and selection
- Comply with or fulfil legal obligations and regulatory requirements
5. Who We Disclose Your Personal Data To
We disclose some of the personal data you provide us to the following entities or organisations outside JustCo in order to fulfil our services to you:
- EDM / Email Service Vendors
- Event Organisers
- Our Data Processing and IT Services Providers to facilitate guest registration
- Freight / Courier Services
- HR / Payroll Processing Services and Insurance Companies
- Government Agencies
Where required to do so by law, we may disclose personal data about you to the relevant authorities or to law enforcement agencies.
6. How We Manage the Collection, Use and Disclosure of Your Personal Data
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. 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:
- The personal data is publicly available
- The personal data is disclosed by a public agency or disclosed to a public agency
- The personal data is necessary for any investigation or proceedings
- The personal data is necessary for evaluative purposes (e.g. determining the suitability of a job applicant for the job applied for)
- The personal data 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 the purpose of managing or terminating an employment relationship
- 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.
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 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 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 30 days from the date we receive your request.
11. 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: 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.
12. 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.