PRIVACY POLICY

INTRODUCTION

Juberi is committed to data security and the fair and transparent processing of personal data. This privacy policy (Policy) sets out how we will treat the personal data which you provide to us in compliance with applicable data protection law, in particular the General Data Protection Regulation (EU) 2016/679 (GDPR). Please read this Policy carefully as it contains important information on who we are, how and why we collect, store, use and share personal data, your rights in relation to your personal data, how to contact us and supervisory authorities in the event that you would like to report a concern about the way in which we process your data.

WHO ARE WE?

Our registered address is: Finsgate, 5-7 Cranwood Street, London, EC1V 9EE. For the purposes of the GDPR, Juberi is the ‘controller’ of the personal data you provide to us. The Privacy and Compliance manager for Juberi is Mark Grindrod. You may contact him by sending an email to hello@juberi.com. Juberi owns and operates; https://juberi.com (Website). This Policy, together with our Website terms of use and any other documents referred to in them, sets out the basis on which Juberi processes personal data.

WHAT DATA DO WE COLLECT IF YOU ARE A CUSTOMER OR POTENTIAL CUSTOMER WITH JUBERI?

We may collect and process the following data:

  • Company name, address, email and phone number
  • Position within company structure
  • Full name, business email
  • IP address
  • Geographical location
  • Browser type
  • Device type
  • Operating system
  • Browsing data, such as access times
  • Navigation history

HOW DO WE COLLECT INFORMATION ABOUT YOU?

If you:

  • Complete a form on our Website;
  • Complete a survey;
  • Correspond with us by phone, email, or in writing;
  • Report a problem;
  • Sign up to receive our communications;
  • Create an account with us;
  • Speak to us at an event;
  • Enter into a contract with us to receive products and/or services,
  • Related social media locations

If you visit our Website, we may automatically collect the following information:

  • Technical information, including the internet protocol (IP) address used to connect your computer to the Internet, login information, browser type and version, time zone setting, browser plugin types and versions, operating system and platform;
  • Information about your visit to our Website such as the products and/or services you searched for and view, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouseovers), and methods used to browse away from the page.

INFORMATION WE RECEIVE FROM OTHER SOURCES

We may also receive information about you if you use any of the other websites we operate or the other services we provide in partnership with third parties. We may also receive information about you from your centre, or employer when they register to receive products and/or services from us.

INFORMATION ABOUT OTHER PEOPLE

If you provide information to us about any person other than yourself, such as your advisers or your suppliers, you must ensure that they understand how their information will be used and that they have given their permission for you to disclose it to us and for you to allow us, and our outsourced service providers, to use it.

HOW DO WE USE YOUR PERSONAL DATA?

When we ask you to supply us with personal data we will make it clear whether the personal data we are asking for must be supplied so that we can provide the products and services to you, or whether the supply of any personal data we ask for is optional. Contract performance: We may use your personal data to fulfil a contract, or take steps linked to a contract:

  • To provide the products and/or services to you;
  • To communicate with you in relation to the provision of the contracted products and services including assessment.
  • To provide you with administrative support such as account creation, security, and responding to issues; and
  • Provide you with industry information, surveys, information about our awards and events, offers and promotions, related to the products and/or services.

Legitimate interests: Where this is necessary for purposes that are in our, or third parties, legitimate interests. These interests are:

  • Providing you with newsletters, surveys, information about our awards and events, offers, and related to products and services offered by Juberi  which may be of interest to you;
  • Communicating with you in relation to any issues, complaints, or disputes;
  • Improving the quality of experience when you interact with our products and/or services, including testing the performance and customer experience of our Website;
  • Performing analytics on sales/marketing data, determining the effectiveness of promotional campaigns.

NOTE: you have the right to object to the processing of your personal data on the basis of legitimate interests as set out below, under the heading Your rights.
Consent: Where you have given your express consent to receive marketing communications, we may use your personal data to:

  • Send you newsletters, surveys, information about our awards, events, offers, and promotions, related to products and services offered by Juberi which may be of interest to you;
  • To develop, improve, and deliver marketing and advertising for products and services offered by Juberi

Where required by law: We may also process your personal data if required by law, including responding to requests by government or law enforcement authorities, or for the prevention of crime or fraud.

WHO DO WE SHARE YOUR PERSONAL DATA WITH?

We take all reasonable steps to ensure that our staff protect your personal data and are aware of their information security obligations. We limit access to your personal data to those who have a genuine business need to know it. We may also share your personal data with trusted third parties including:

  • Legal and other professional advisers, consultants, and professional experts;
  • Service providers contracted to us in connection with provision of the products and services such as providers of IT services, and customer relationship management services; and
  • Analytics and search engine providers that assist us in the improvement and optimisation of our Website.

We will ensure there is a contract in place with the categories of recipients listed above which include obligations in relation to the confidentiality, security, and lawful processing of any personal data shared with them. Where a third-party recipient is located outside the European Economic Area, we will ensure that the transfer of personal data will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission where the data protection authority does not believe that the third country has adequate data protection laws. We will share personal data with law enforcement or other authorities if required by applicable law.

HOW LONG WILL YOU KEEP YOUR PERSONAL DATA?

Where there is a contract between us, we will retain your personal data for the duration of the contract, and upon expiry, securely archive the information, to ensure we are able to comply with any contractual, legal, audit and other regulatory requirements, or any orders from competent courts or authorities. Where you have consented to marketing communications, you may change your preferences or unsubscribe from marketing communications at any time by clicking the unsubscribe link in an email from us, visiting our website or emailing hello@juberi.com

WHERE DO WE STORE YOUR PERSONAL DATA AND HOW IS IT PROTECTED?

We take reasonable steps to protect your personal data from loss or destruction. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so. Where you have a username or password (or other identification information) which enables you to access certain services or parts of our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our Website; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.

YOUR RIGHTS

Under the GDPR, you have various rights with respect to our use of your personal data:

Right to Access
You have the right to request a copy of the personal data that we hold about you by contacting us at the email or postal address given below. Please include with your request information that will enable us to verify your identity. We will respond with 30 days of request. Please note that there are exceptions to this right. We may be unable to make all information available to you if, for example, making the information available to you would reveal personal data about another person, if we are legally prevented from disclosing such information or if your request is manifestly unfounded or excessive.

Right to rectification
We aim to keep your personal data accurate and complete. We encourage you to contact us using the contact details provided below to let us know if any of your personal data is not accurate or changes so that we can keep your personal data up-to-date.

Right to erasure
You have the right to request the deletion of your personal data where, for example, the personal data are no longer necessary for the purposes for which they were collected, where you withdraw your consent to processing, where there is no overriding legitimate interest for us to continue to process your personal data, or your personal data has been unlawfully processed. If you would like to request that your personal data is erased, please contact us using the contact details provided below.

Right to object
In certain circumstances, you have the right to object to the processing of your personal data where, for example, your personal data is being processed on the basis of legitimate interests and there is no overriding legitimate interest for us to continue to process your personal data, or if your data is being processed for direct marketing purposes. If you would like to object to the processing of your personal data, please contact us using the contact details provided below.

Right to restrict processing
In certain circumstances, you have the right to request that we restrict the further processing of your personal data. This right arises where, for example, you have contested the accuracy of the personal data we hold about you and we are verifying the information, you have objected to processing based on legitimate interests and we are considering whether there are any overriding legitimate interests, or the processing is unlawful and you elect that processing is restricted rather than deleted. Please contact us using the contact details provided below.

Right to data portability
In certain circumstances, you have the right to request that some of your personal data is provided to you, or to another data controller, in a commonly used, machine-readable format. This right arises where you have provided your personal data to us, the processing is based on consent or the performance of a contract, and processing is carried out by automated means. If you would like to request that your personal data is ported to you, please contact us using the contact details provided below. Please note that the GDPR sets out exceptions to these rights. If we are unable to comply with your request due to an exception we will explain this to you in our response.

CONTACT

If you would like to contact us about this Policy, our use of your personal data, or about exercising any of your rights, please contact us by email at hello@juberi.com or by writing to us at: Privacy and Compliance Manager, Finsgate, 5-7 Cranwood Street, London, EC1V 9EE.

CONCERNS

If you believe that your data protection rights may have been breached, and we have been unable to resolve your concern, you may lodge a complaint the applicable supervisory authority or to seek a remedy through the courts. Please visit https://ico.org.uk/concerns/ for more information on how to report a concern to the UK Information Commissioner’s Office. Privacy Policy Version 1.0, 7th September 2018

HOW WE USE COOKIES

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system. Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

PHPSESSID

This is an essential temporary cookie used to store data about your visit and any choices you make or data you enter. This cookie is deleted when you close your browser.

STATCOUNTER – Unique/Returning Cookie (is_unique)

This holds data on your visits to our website. We solely use it to determine whether you are a first-time or returning visitor on each website and to estimate your accumulated unique visits per site. No personal information is stored in the cookie.

Duration: 5 years

Set by: statcounter.com

Note: This method is being phased out (2016) in favour of 1st party cookies:

STATCOUNTER – 1st Party Visitor Cookie (sc_is_visitor_unique)

This cookie is set by www.juberi.com. When it is first set, a random id is generated and stored in the cookie in order to avoid counting you as a visitor more than once (e.g. if you are on a mobile device and your IP address changes while you browse). Similarly to the is_unique cookie, this cookie also stores a count of your returning visits.

Duration: 2 years

Set by: www.juberi.com

Introduced: 2014, in widespread use: mid 2016

Find out more about statcounter.com cookies on their website here – https://statcounter.com/about/cookies/  including how to ‘opt-out’

LINKS TO OTHER WEBSITES

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.