Privacy Policy
Company registration details
Juru Limited, a
company registered in England under the number 09677085 ("we",
"us", "our")
Registered office: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, UK
We, are dedicated to respect your
privacy and admit your need for
appropriate security and management of any personal information ("personal
data") you share with us. Juru has developed this notice so that you are able to see and
understand how much we take care about your personal data.
Juru seeks to
comply with all applicable laws around the world that are designed to protect
privacy of personal data, based on this notice as a standard. Notwithstanding
the fact that juridical requirements differ from country to country, the
principles set out in this notice are adhered by Juru. However, in connection
with the above, your personal data might be transferred from your country to
countries outside of the European Economic Area (EEA) that may not always require
a high level of protection for your personal data.
This notice is applicable to those who use our website, as well as to
those individuals that use/complete/take part in any filling in database,
software, questionnaire, survey, our services, any agreement or other document
that brings to this notice via hyperlink.
This notice is about the way how we collect
and manage personal data we hold about people visiting our website (https://juru.org/) or otherwise interacting with
us directly, as set out below is described in this notice.
Contact us
Any questions
regarding your personal data and how we use it, or/and any question or issues
regarding this notice might be directed to info@juru.org.
Alternatively, you can contact us by telephone at +44 207 859 4028 or +44
207 691 9406.
You also have the right to contact a privacy and data protection
regulator in the country, state or province where you are located, in case if
you want to make complaint about how we use your data.
Terminology used
The General Data Protection Regulation (Regulation (EU) 2016/679)
("GDPR") is the governing law of our data processing activities. For
the purpose of the GDPR, we are the 'Data Controller' of all personal data
received by us as set out in this notice, since how your personal data handling
is ultimately determined by us or our sub-contractors, who would be our 'Data
Processors'.
You are a "Data Subject" if we handle your personal data.
Which means under the GDPR you have certain rights with regard to how your
personal data is processed, which are set out in this notice.
Any
information that can be used to identify you is 'Personal data', it includes
your name, e-mail address, IP address, or any other data that could reveal your
physical, physiological, generic, mental, economic, cultural or social
identity.
'Special category data' means any sensitive information about you and
it includes race or ethnicity you belong to, religious or philosophical
beliefs, sex life, sexual orientation, political opinions, trade union
membership, information about your health and genetic and biometric data.
Acceptance
By using our website, you hereby accept our Privacy Policy and agree
to its terms.
Your personal data that we may collect
The personal data that we collect may include (but is not limited to):
1.
Your name.
2.
Your e-mail
address and contact information.
3.
Your
internet protocol address or other online identifiers.
4.
Location
data.
5.
Genetic
identity factors.
6.
Pseudonymous
data.
7.
Event attendance
and dietary requirements.
How your personal data is collected
If you contact us (by telephone, e-mail, instant messenger or voice
over IP) your personal data will be collected by us
and it will be processed in accordance with the processes outlined in this
notice, inclusively with our Privacy Principles and the basis for processing
your personal data. This may include negotiations with you in relation to the
demand for our services or a contract agreement that we may enter into with
you.
If any video meetings are held with you (whether audio or video) we
may record such conversations and, in such cases, your personal data which may
be recorded as part of meeting will be stored. This will be saved by us as
communication data, in accordance with this privacy notice.
We may collect personal data:
·
based on
your usage of our website (https://juru.org/), it may include forms submitted
through the website or otherwise through the use of cookies, as set out later
in this notice;
·
through
questionnaires, forms, surveys or other documents that hyperlink to this notice and thus you provide your personal data directly to you;
·
from your
usage of CCTV which may be in operation at our offices, or those offices where
we provide our services. We intend to use any personal data collected from use
of CCTV for the purposes of ensuring the safety and security of our staff or
the offices where we provide our services and any people coming onto our
offices. If there are no issues to address, then such footage shall be kept for
no longer than we believe is reasonably necessary. Such footage shall be kept
for no longer than we believe is reasonably necessary, if there are no issues
to address.
The use of your
personal data
This notice is to report about what can be expected when we collect
your personal data. Your personal data will be processed only if we have a
legal basis for doing so, as outlined in this notice or as notified to you at
the time we collect your personal data, and for the purposes for which it was
collected for. You will get a notification prior to initiating the process of usage of
your personal data for unrelated purpose in case we need to launch this process and all relevant legal basis allowing us to initiate
this will be explained. Please take into consideration that your personal data
might be collected/processed/used without any notification or your knowledge
where it is permitted by law.
We may share your personal data according to our principles on transferring
the data to the third parties as it is outlined later on this notice, including
(but not limited to) the following:
·
law
enforcement organizations, appropriate regulators, or any other third party for
whom we are under the duty to disclose your personal information;
·
third
parties with whom we agree on
selling, transferring, or merging our business or our assets;
·
our
third-party suppliers to, inclusive (for example) insurance agents, brokers,
auditors and our IT providers;
·
in case of
sharing your personal data with any other third parties mentioned in this
section, we will take all necessary steps to protect your personal data;
·
We may use your
special category data for the purposes of monitoring and producing anonymous
reports on an anonymised basis, including for the purposes of our reporting on
equality, diversity and inclusion. However, we shall ask your consent and
permission for such processing.
Personal data processing basis
We do not have any authorized permits to process your personal data
unless we have a legal basis for doing so. Thus, there are four legal grounds
on which we rely if we need to process your personal data. That legal bases are
listed below for your knowledge:
1. “Legitimate interest”- we have a legitimate interest to process your personal data, when we want to contact you because you have sent a general query to us or if we are already in communication with you about this or similar issues. General query means when you raise issues with regard to your IP address, any information collected via “Cookies”, website navigation or organization, or any other similar issue. We might need to contact you on the basis of legitimate interest in order to inform you about our new services or other updates that may be of interest to you as part of our marketing campaigns.
2. “Necessary for performing a contract” – we base our actions with regard to your personal data processing on this when we are in a contract with you or about to enter into a contract. In such cases, we may use your personal data, in order to provide you with pre-contract details or to complete the contract.
3. “Consent” – if there is no legitimate or contract necessity, we may process your personal data after you provide your consent. You may be asked to tick a box (or similar) to confirm that you have provided your consent to process your personal data where we set out specific circumstances about where and how we wish to process your data. Should you have any questions about the specific circumstances or you want to withdraw your consent, please contact us at info@juru.org.
4.
“Compliance
with a legal obligation” – we will process your personal data if doing so is
required by law. Hence, we will process your personal data to comply with a common
law or statutory obligation, and if we would not otherwise be able to comply
with legal obligations without such processing.
We will only market our services on the basis of legitimate interest
we mentioned above. Your workplace may also be identified and provided with
marketing campaigns from our side. We will rely on legitimate interest as our
legal basis for processing your personal data and getting in touch with your
organization trough your contact records. Nevertheless, we will not market our
business nor we will contact you, if you chose to unsubscribe from receiving
marketing communication. We will balance our marketing activities against your
rights as a data subject, and if have no legitimate interest to market to you,
then we will ask for your permission to do so.
Our Privacy Principles
1.
Data use
notice
Your personal data is used in accordance with this notice, or notice
provided to you while collecting your personal data if there is the intended
processing need.
2.
When your
personal data is not provided
There might be restrictions for certain services that require our
communication with you, when you choose not to provide your personal data we
request. However, you can still visit Juru’s website and use basic services
that do not ask for personal data.
When you chose to have connection with Juru -contractual or other
business relationship- the Company will keep contacting you in connection with
that business relationship, according to this notice and any other contractual
terms agreed.
3.
Updating
your data
We want to maintain accurate and up-to-date personal data, and for
this reason there is a mean for you to contact us if you need to uprate or
correct your information. Please, send your personal data corrections and
updates to info@juru.org so that we can incorporate the change to your
personal data.
4.
Third party
data processors
Third party data processors provide certain services for us that may
involve the use of your personal data. In order to provide us with programmes,
information, products or services related to maintain effective website and mailing
lists, service provider may need to posses your personal data. Before we
provide your personal data, such Data Processors sign a written agreement with
us about the basis on which they use your personal data. This helps us to
protect your personal data.
5.
Internal
and external transfers
Juru has operating offices in the UK and Uzbekistan. To provide you
with our services or information you need, we may transfer your personal data
to our office outside of EEA – Tashkent, Uzbekistan. However, we consider this
to be an internal transfer, therefore, your personal data will adequately be
handled under GDPR in both offices.
Moreover, we may also send your personal data to organizations/people
outside of the EEA for one of the legal bases for processing your personal data
as mentioned above. In such cases, we ensure that there are adequate safeguards
in compliance with applicable law. The safeguards (including Articles 44 to 50
of the GDPR) put a set of rules and play regulatory role in checking whether
those countries or international organizations to which your personal data will
be transferred have an adequate level of protection to protect and process your
personal data.
6.
Retaining
your personal data
This notice cannot exactly set out the longevity of retaining your
personal data, since it is just a general notice that informs about the
personal data collected for various reasons. Nevertheless, the following factors are on
which we base our decisions about how long we retain your personal data:
·
In case if
there is contract between you and the Company - we maintain your personal data
for the lengths of the contract and for about 15 years after completion so that
to deal with any post-contract procedures.
·
In case if
there is communication with us – we keep your personal data for as long as it
is needed for us to conclude the relevant correspondence with you.
·
In case if
we think you will contact back us again in the near future or we think we
should to contact you again, if there is still the legal base for this, we
retain your personal data for no longer than it is necessary in relation to
that legal ground.
7.
Decisions
taken automatically
There are different technologies that may be used for an automated
decision making using your personal data to make a specific decision. Your
consent will be obtained before the use of your personal data for such purposes
and you will be notified about the introduction of such technologies.
8.
Your rights
as a Data Subject
You have the following rights in relation to your personal data:
·
The right
to be informed – about the various purposes and the types of your personal
information used;
·
The right
of access – you have the right to access to copies and get confirmation of the
processing of your personal data that are being processed by us;
·
The right
to rectification – you have the right to change your personal data that we hold
on you, if you think it is incorrect or incomplete;
·
The right
to erasure (or the right to be forgotten) – you have the right to ask us about
the erosion of your personal data, forever;
·
The right
to limit processing – you have the right to ask us to stop processing of your
personal information for any reason;
·
The right
to data portability – you have the right to ask us to send your personal data
to someone else. We ensure that this transfer will not damage or affect your
personal data in any ways;
·
The right
to withdraw your permission – if we have relied on your permission to process
your personal data, we will stop processing and using it on your withdrawal of
such permission. However, please note that if we have other legal basis to
process your data except for your consent, we may continue doing so even if you
have withdrawn your permission.
·
Rights with
regard to an automated decision making and profiling – you have the right to
know about the automated decision making or profiling we use. Your consent will
be asked if either of these are used to reach a decision that influence you. As
with any consent from your side, you can cancel it at any time.
If you want to exercise your rights, please contact us at info@juru.org. Moreover, if you are not sure about our use and
processing your personal data on relevant grounds, you can file a complaint
with your local data protection authority. You will not incur any fees to
access your personal data or to exercise any of your other rights. However, if
your request is considered obviously repetitive, excessive or ungrounded, you
will be charged a reasonable fee. All legitimate access requests will be
responded within one-month time. If your request is complex or you addressed
several requests at a time, it may take us longer that a month.
9.
Children's
privacy
Our website has not been organized to attract children. Therefore, we
do not wish to collect personal data from those who are under 16 years old. There might be some occasional collection of personal
data in relation to children as part of our service offering, or in respect of
our personnel arrangements. When we want to collect or process children’s
personal data and rely on the consent to do so, we will obtain permission from
their parents/guardians of the child before doing so.
Photographs, video and audio recordings
Photography, video and audio recordings for various reasons
When someone attends or participates in conferences, events,
workshops, receptions, training sessions, podcasts, stakeholder engagement
events and exhibitions organised by us and/or by our partners, we (and/or our
partners) may take photographs and/or record videos. It is likely that personal
identifiable data will be made publicly available and transferred globally (by
us and/or by our partners), as a result.
Photographs and videos of children
We may take photos and record videos of children through our Corporate
Social Responsibility activities. In such cases, we will provide release forms for
parents to get their permission for photos and recording videos. Events with
participation of children may take place in schools, communities, exhibitions,
stakeholder engagement events, regional or local government offices, training
and surveys.
The use of photograph, videos and audio recordings
We use your personal data, including photograph, video and audio recordings
for a variety of purposes, including (but not limited to):
·
Organizing
website and html recap emails
·
Social
media (the Company profiles in LinkedIn and Facebook)
·
Generate
reports and marketing materials
·
Conducting
presentations to stakeholders
·
Communication
within company, creating PR materials, promotions
·
Producing
brochures, event displays, infographics
·
Preparation
of bid proposals or relevant tender documents – for visualizing of the certain
description material
·
Analysing
and getting statistical data
Retaining photos/videos/audio recordings
Your photos, videos or audio recordings will be kept for no more than seven
years from time that any data are recorded and stored.
Your rights in relation to photo/video/audio use
Our Privacy Policy section sets out your rights in relation to your
personal data that we hold on and this also applies to the use of
photos/videos/audios that may identify you. In case if you have objection to
having your photo/video to be taken and used, please let us know before the
relevant event or talk to organizers on the day of the event.
Visitors to our websites
Standard internet log information and details of visitors’ behaviour
patterns are collected when you visit this website. This is done in order to
quantify the number of users/visitors of this website and to better customize
our services for your convenience. There is no intended attempt to find out the
identities of visitors of our website. When we wish to gather personally
identifiable information through this website, we will let the users know about
it and the purposes for which the data is collected.
By using our website, you hereby consent to our Privacy Policy and
agree to its terms. If these terms change, we will notify you about it.
We take no responsibility for the privacy practices of any websites
other than our own that may be provided as a reference in various sections of
this website.
There are risks of using the Internet: Even if we acquire best
practices to provide protection and safety for your personal data, we do not
guarantee the security of information that you send to us or any other website.
You should take a sole responsibility for confidentiality of your personal data
including account information and passwords.
Information we collect
When we ask you for your personal information, we make the reasons for
the collection of your data clear to you. However, when you contact us
directly, you may be asked to provide additional information: name, email,
address, phone number, subject of your message, or any other information required
to contact with us – to send an email.
Use of cookies by us
Like any other website, https://www.juru.org/ uses 'cookies'. These cookies
are used to store information including visitors' preferences, and the pages on
the website that the visitor accessed or visited. The information is used to
optimize the users' experience by customizing our web page content based on
visitors' browser type and/or other information. For more general information
on cookies that we use in this website, please read Disclaimer. You may
want to visit www.allaboutcookies.org, in order
to find more about cookies, what cookies have been set and how to manage and/or
delete them. Most of the browsers may be set to notify about cookies used.
Please note that if you want to delete or block your cookies, you will have to
provide your personal data again so that to access certain services and/or
parts in this website.
Cookies allow to track visitors’ internet domain and
host names, browser software and operating system types, protocol addresses,
clickstream patterns and date/times of access. By this, cookies help to improve
website services, and thus we can better satisfy the needs of visitors. Please
do not hesitate to contact us at info@juru.org if you have any questions on this.
Changes to this notice
If we decide to make changes in this notice, it will be announced on our website. We may also email you about the changes if they are considerable; we will also obtain your consent to the change if doing so is required by law.
References:
https://www.privacy-regulation.eu/en/article-44-general-principle-for-transfers-GDPR.htm
