Jonas Software as Data Controller
As a data controller, we will only use your personal data in compliance with applicable law. For example, under the UK GDPR, we may be required to have a legal basis for processing your personal data. The purpose for which we use and process your information and the legal basis on which we carry out each type of processing is explained in the table above(?). Note that we may process your personal data for more than one legal basis.
Updating Your Information And Opting Out
If you do not wish to provide us with your personal data and processing such data is necessary for the performance of a contract with you and to fulfil our contractual obligations to you, we may not be able to perform our obligations under the contract between us. Where you provide consent, you can withdraw your consent at any time and free of charge, but without affecting the lawfulness of processing based on consent before its withdrawal. No withdrawal of consent will be effective until we receive it and have had a reasonable period of time to act on it. You can update your details or change your privacy preferences by contacting us as provided in “Contacting Us” below.
To review, correct, update, delete, object, or otherwise limit our use of your personal data that has been provided to us, or request portability and/or details of your personal data that is held by us, please contact us using the contact information listed below in the “Contacting Us” section and clearly describe your request.
If you have registered for an account with us, you can help to ensure that your personal data is accurate and up to date by logging into your account and updating your personal data.
You may unsubscribe from marketing communications at any time by clicking the “Unsubscribe” button available at the bottom of any electronic communication we may send to you. You may also unsubscribe from any medium of communication by contacting us using the information set out in the “Contacting Us” section below.
Jonas Software As Data Processor
In certain cases, we also operate as a data processor and we collect, process, and transfer personal data on behalf of our business customers in the provision of our services and products. In these circumstances, Jonas Software is acting as a data processor and our business customers remain the data controller in respect of personal data they provide to us.
Our business customers remain the data controllers with respect to any personal data that they provide to us for our provision of services. To the extent that we are acting as data processor, we act in accordance with the instructions of such customers regarding the collection, processing, storage, deletion, and transfer of customer data, as well as other matters such as the provision of access to and rectification of personal data. We will only use such personal data for the purposes of providing the services and products for which our business customers have engaged us.
Our business customers are responsible for ensuring that these individuals’ privacy is respected, including communicating to the individuals in their own privacy policies who their personal data is being shared with and processed by. Where Jonas Software is acting as a data processor, we will refer any request from an individual for access to personal data which we hold about them to our customer. We will not usually respond directly to the request.
As a data processor, we may share personal data where instructed by our business customer. Where authorised by the business customer, we may also share personal data with third party service providers who work for us and who are subject to security and confidentiality obligations.
We will retain personal data which we process on behalf of our customers for as long as appropriate to provide services and products to our customers and in accordance with any agreement with our customers or as permitted by applicable law.
Disclosure Of Your Personal Data To Third Parties
We may share your personal data with our group companies, affiliates, subsidiaries, or contractors as appropriate to carry out the purposes for which the information was supplied or collected (i.e. to provide the services and products you have requested from us) or as otherwise provided in this policy. Personal data will also be shared with our third-party service providers and business partners who assist with the running of the Sites and our services and products (including hosting providers, email service providers and payment processing partners). Our third-party service providers and business partners are subject to security and confidentiality obligations and are only permitted to process your personal data for specified purposes and in accordance with our instructions.
In addition, we may disclose personal data about you when we believe that such use or disclosure is reasonably appropriate to: comply with any legal or regulatory obligation; enforce the terms of our agreements; establish, exercise or defend the rights of Jonas Software, our staff, customers or others; protect our rights, property, safety or vital interests, or the rights, property, safety or vital interests of our users or other third parties; and implement the purchase of all or substantially all of our assets, a merger, or other similar transaction that results in a change of control.
UK GDPR Compliance
We are committed to protecting your personal data and complying with the UK GDPR
and all other applicable UK data protection and privacy legislation. We process data lawfully, securely, and only for specified purposes, ensuring transparency and respecting your rights. You can access, rectify, or erase your data, and you have the right to object to processing (these rights are further explained below).
International Transfers
If you are based in the UK, or EEA
We may share your personal data within the Jonas group of companies. This involves transferring your data outside the European Economic Area (EEA) to Jonas’ affiliates and third-party service providers in Canada, United States, Australia, New Zealand, South Africa, and Malaysia. Canada and New Zealand have been deemed by the EU as having an adequate level of protection for personal data.
Whenever we transfer your personal data outside the EEA to the countries identified above which have not been deemed by the EU to have an adequate level of protection for personal data, and specifically to the United States, we ensure a similar degree of protection is afforded to it by using standard data protection clauses approved by the European Commission.
Security Of Your Personal Data
The security of your personal data is important to us. We follow generally accepted industry standards to protect the personal data received by us. We use commercially reasonable measures to safeguard personal data, which measures are appropriate to the type of information maintained and follow applicable laws regarding the safeguarding of any such information under our control. No method of transmission over the Internet, or method of electronic storage, can be 100% secure. Therefore, we cannot guarantee the absolute security of your personal data. The Internet by its nature is a public forum, and we encourage you to use caution when disclosing information online. Often, you are in the best situation to protect yourself online. You are responsible for protecting your username and password from third party access, and for selecting passwords that are secure.
Data Retention: How Long We Keep Your Personal Data
We will retain personal data which we process on behalf of our customers for as long as appropriate to provide services and products to our customers in accordance with any agreement in place with our customers and for other legitimate purposes. When you contact us, we may keep a record of personal data contained in your communication to help solve any issues that you might be facing. Your personal data may be retained for as long as appropriate to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirement, and for other legitimate purposes. In determining how long we will retain personal data; we will consider all relevant factors.
Your Rights
You may request from us access to, correction of, blocking of and/or deletion of your personal data in line with applicable law. You may also withdraw your consent for us to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. Where your personal data is processed by us with your consent or for the performance of a contract by automated means, we will, to the extent required by applicable law, provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format upon request.
Responding To Requests
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights) under applicable law. This is a security measure to protect personal data from being disclosed to any person who has no right to receive it. We may also contact you to ask for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. You will not have to pay a fee to access your personal data (or to exercise any of your other rights) under applicable law. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances. Also, please note that we may refuse a request for blocking and/or deletion where continued processing is necessary to comply with a legal obligation or necessary for the establishment, exercise, or defence of legal claims or for other purposes permitted by applicable law.