Josys International Pte. Ltd. (“Josys”, “we”, “us”, or “our”) is in the business of providing an integrated employee IT lifecycle management solution in the cloud, for businesses to drastically simplify their employee onboarding, offboarding and management of their overall IT needs.

Josys wants you to be familiar with how we collect, use and disclose Personal Information.  This privacy policy (the “Privacy Policy”) explains how we collect, use, disclose, and safeguard your Personal Information when you:

• visit and use our website at josys.com (the “Website”), which links to this Privacy Policy;
• register with us via the Website;
• participate in our training, seminars, webinars or other events (the “Events”);
• contact us (e.g., via post or email, or via the Website);
• subscribe to our newsletter (the “Newsletter”);
• use our social media pages which link to this Privacy Policy (collectively, our “Social Media Pages”) and/or
• receive HTML-formatted email messages or other communications that we send to you that link to this Privacy Policy,
  (together, the “Offerings”).

Josys is committed to protecting the privacy of its users and this Privacy Policy is applicable to each of the Offerings.

1. PERSONAL INFORMATION COLLECTED
2. PERSONAL INFORMATION PROCESSING PURPOSES
3. DISCLOSURE OF PERSONAL INFORMATION
4. SECURITY
5. EMAIL MARKETING CHOICES
6. RIGHTS REQUESTS
7. RETENTION PERIOD
8. THIRD-PARTY SERVICES
9. THIRD-PARTY ADVERTISING
10. USE OF THE OFFERINGS BY MINORS
11. CROSS-BORDER TRANSFERS
12. SENSITIVE INFORMATION
13. UPDATES TO THIS PRIVACY POLICY
14. CONTACTING US
15. OUR AFFILIATES
16. CALIFORNIA SUPPLEMENT
17. EEA/UK SUPPLEMENT

PERSONAL INFORMATION COLLECTED

“Personal Information” is information that identifies an individual or relates to an identifiable individual. We collect the following categories of Personal Information:

We need to collect Personal Information to provide the requested Offerings to you.  If you do not provide the information requested, we may not be able to provide the Offerings.  We will note which Personal Information is required to provide the Offerings at the time of its collection.

If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Offerings, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

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PERSONAL INFORMATION PROCESSING PURPOSES

We use Personal Information for legitimate business purposes, including:

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For more information on our use of Personal Information subject to the EU or UK General Data Protection Regulation for the purposes described above, please see the “EEA/UK SUPPLEMENT” section.

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DISCLOSURE OF PERSONAL INFORMATION

We disclose Personal Information to third parties and for the purposes described below, depending on each specific jurisdiction and applicable law:

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SECURITY

We seek to use reasonable organizational, technical, and administrative measures to protect Personal Information within our organization.  Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.  If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “CONTACTING US” section below.

EMAIL MARKETING CHOICES

You have choices regarding marketing-related communications.  Where required by applicable law, we will ask for your prior opt-in consent.

If you no longer want to receive marketing-related emails from us in the future, you may opt-out by following the unsubscribe instructions in any such message or by contacting us by email at support@josys.com.

We will try to comply with your request as soon as reasonably practicable.  Please note that if you opt out of receiving email marketing from us, we may still send you important administrative messages, from which you cannot opt out.

RIGHTS REQUESTS

If you would like to request to access/review, correct, update, suppress/delete, object to, restrict or opt out of the processing of Personal Information, withdraw your consent (which will not affect the lawfulness of processing prior to the withdrawal), or if you would like to request to receive an electronic copy of your Personal Information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), please feel free to contact us via email at support@josys.com. We will respond to your request consistent with applicable law. If you are a California resident, please refer to the “CALIFORNIA SUPPLEMENT” section at the end of this Privacy Policy for more information about the requests you may make under California law.

In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information.  For your protection, we may need to verify your identity before implementing your request.  We will try to comply with your request as soon as reasonably practicable.

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion). Further, certain Personal Information may be exempt from requests pursuant to applicable data protection laws or other laws and regulations.

You may also lodge a complaint with a data protection authority for your country or region, or where an alleged infringement of applicable data protection law occurs.  A list of EEA data protection authorities is available at: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm. Information regarding the UK data protection authority is available at: https://ico.org.uk/.

RETENTION PERIOD

We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained as outlined in this Privacy Policy, unless a longer retention period is required or permitted by applicable law (e.g., for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements).  The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and provide our products, services or Offerings to you (for example, for as long as you have an account with us or keep using our products, services or Offerings);
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).

Where we are subject to a legal obligation or retention is recommended in light of our legal position, we will retain certain Personal Information even after your account has been deleted and/or we no longer provide our products, services or Offerings to you, for example:

• To cooperate with law enforcement or public, regulatory and government authorities: If we receive a preservation order or search warrant, related to your products, services or Offerings account, we will preserve Personal Information subject to such order or warrant after you delete your products, services or Offerings account;
• To comply with legal requirements: We may retain your Personal Information, such as Relationship History, and/or Transaction Information after you delete your products, services or Offerings account, as required by tax law and to comply with bookkeeping requirements; or  
• To pursue or defend a legal action: We may retain relevant Personal Information in the event of a legal claim or complaint, including regulatory investigations or legal proceedings about a claim related to your Personal Information, or if we reasonably believe there is a prospect of litigation.

In some circumstances, we will anonymize your Personal Information (so that it can no longer be associated with you) for research or statistical purposes so that we can obtain insights (e.g., into the average number of applications managed by customers using our platforms), in which case we may use this information indefinitely without further notice to you.

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THIRD-PARTY SERVICES

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties. This includes any third party operating any website or service to which the Offerings link.  The inclusion of a link on the Offerings does not imply endorsement of the linked site or service by us or by our affiliates.

The Offerings may provide functionality allowing you to make payments to us using third-party payment services with which you have created your own account.  When you use such a service to make a payment to us, your Personal Information will be collected by such third party and not by us, and will be subject to the third party’s privacy notice, rather than this Privacy Policy.  We have no control over, and are not responsible for, this third party’s collection, use, and disclosure of your Personal Information.

In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Apple, Google, Microsoft or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Website or our Social Media Pages.

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THIRD-PARTY ADVERTISING

We use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the Offerings and other websites or online services.

You may receive advertisements based on information relating to your access to and use of the Offerings and other websites or online services on any of your devices, as well as on information received from third parties.  These companies place or recognize a unique cookie on your browser (including through the use of pixel tags).  They also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop.  If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this Privacy Policy, please visit http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/#/. You may download the AppChoices at www.aboutads.info/appchoices to opt out in mobile apps.  

USE OF THE OFFERINGS BY MINORS

The Offerings are not directed to individuals under the age of 18, and we do not knowingly collect Personal Information from individuals under 18.

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CROSS-BORDER TRANSFERS

Your Personal Information may be stored and processed in any country or region where we have facilities or in which we engage service providers.  By using the Offerings, you understand that your Personal Information will be transferred to countries outside of your country or region of residence, which may have data protection rules that are different from those of your country or region.  In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries or regions may be entitled to access your Personal Information.

As required by applicable law, we implement safeguards to protect your Personal Information when we transfer it outside your country or region of residence.  For example:

• For transfers from within the UK and/or EEA to outside the UK and/or EEA, we ensure a similar degree of protection is afforded to it by ensuring that at least one of the following safeguards is implemented:
  • Adequacy Decisions: Some countries outside of the European Economic Area (the “EEA”), are recognized as providing an adequate level of data protection (the full list of these “specified countries” for the EEA is available here and for the UK is available here).
  • Adequate Measures: For transfers from the EEA, Switzerland, and/or the UK to countries not considered adequate, we have put in place adequate measures, such as standard contractual clauses adopted by the relevant authority, to protect your Personal Information.  You may obtain a copy of these measures by emailing us at support@josys.com.

• For transfers from Japan to countries not considered adequate by the Japanese government (as applicable), we have also put in place adequate measures, such as data transfer agreements containing provisions required under Japanese law, to protect your Personal Information.

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SENSITIVE INFORMATION

Unless we request it, we ask that you not disclose or send us, on or through the Offerings, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership).

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UPDATES TO THIS PRIVACY POLICY

The “LAST UPDATED” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised.  Any changes will become effective when we post the revised Privacy Policy on the Offerings.

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CONTACTING US

Josys is the company responsible for collection, use and disclosure of your Personal Information under this Privacy Policy.  If you have any questions about this Privacy Policy, please contact us at:

• Email: support@josys.com
• Address: Josys International Pte. Ltd., 600 North Bridge Road, #12-04, Singapore 188778

Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.

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OUR AFFILIATES

For purposes of this Privacy Policy, these entities are considered Josys affiliates:

• Josys, Inc.
• Josys Digital Technologies India Private Limited

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CALIFORNIA SUPPLEMENT

Pursuant to the California Consumer Privacy Act (“CCPA”), we are providing the following additional details regarding the categories of Personal Information about California residents that we collect, use, and disclose. This section supplements the information provided above in this Privacy Policy. [

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We collect and disclose to affiliates and service providers for our operational business purposes (including in the preceding 12 months) the following categories of Personal Information about California residents:

• Identifiers such as name, postal address, online/device identifier, IP address, username and password, email address, and social media account and business contact information.
• Personal information as defined in the California customer records law, such as name, signature, contact information, and other information you may share or make public on our Social Media Pages.
• Commercial information, such as Offerings transaction history, financial details, and payment information.
• Internet or other electronic network activity information, such as browsing history and interactions with our Website,  systems, and emails.
• Geolocation data, such as IP location.
• Audio, electronic, visual, and similar information, such as call recordings and CCTV footage created for safety and security purposes, and audio and video recordings of Events.
• Professional or employment-related information, such as employer name, business contact information, and role/title.
• Sensitive Personal Information. Personal Information that reveals an individual’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation.

We retain each category of Personal Information, including Sensitive Personal Information, as described above under “RETENTION PERIOD”.

We do not “sell” Personal Information, including Sensitive Personal Information, and we do not “share” Personal Information, including Sensitive Personal Information, for purposes of cross-context behavioral advertising, as defined under the CCPA. We have not engaged in such activities in the preceding 12 months. Without limiting the foregoing, we do not sell or “share” Personal Information, including Sensitive Personal Information, of minors under 16 years of age.

We collect, use, and disclose Personal Information for the purposes described above under “PERSONAL INFORMATION COLLECTED”.

We collect, use and disclose Sensitive Personal Information for purposes of performing services for our business, providing products or performing services as requested or reasonably expected by you, ensuring safety, security and integrity, countering wrong or unlawful actions, short term transient use, servicing accounts, providing customer service, verifying customer information, processing payments, activities relating to quality and safety control or product improvement, and other collection and processing that is not for the purpose of inferring characteristics about an individual. We do not use Sensitive Personal Information for additional purposes.

We collect Personal Information from a number of sources as described above under “PERSONAL INFORMATION COLLECTED”.

Individual Rights and Requests

You may request that we:

1. Disclose to you the following information:
   1. The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
   2. The business or commercial purpose for collecting Personal Information about you; and
   3. The categories of Personal Information about you that we disclosed, and the categories of third parties to whom we disclosed such Personal Information (if applicable).
2. Correct inaccuracies in your Personal Information.
3. Delete Personal Information we collected from you.
4. Provide the specific pieces of your Personal Information, including a copy in a portable format.

To make a request, please email support@josys.com or call us at +1 888-904-2349.

We will verify and respond to your request consistent with applicable law, considering the type and sensitivity of the Personal Information subject to the request. For your protection, we may need to request information such as your name, email address, mailing address, and relationship with us in order to verify your identity and protect against fraudulent requests. If you make a deletion request, we may ask you to verify your request before we delete your Personal Information.

You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.

If an agent would like to make a request on your behalf as permitted by applicable law, the agent may use the submission methods noted above. As part of our verification process, we may request that the agent provide, as applicable, proof concerning their status as an authorized agent. In addition, we may require that you verify your identity as described above or confirm that you provided the agent permission to submit the request.

De-Identified Information

Where we maintain or use de-identified information, we will continue to maintain and use that information only in a de-identified form and will not attempt to re-identify the information.

Sharing your Personal Information with Third Parties for Direct Marketing Purposes

California Civil Code Section § 1798.83 permits California residents to request certain information regarding our disclosure of their Personal Information to third parties for their direct marketing purposes. If you would like to learn more about this or to make a request to discontinue this type of sharing, please email us at t support@josys.com. We will provide a list of the categories of Personal Information disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We will respond to your request in accordance with applicable law.

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EEA/UK SUPPLEMENT

We and our service providers use Personal Information for legitimate business purposes, including:

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In addition, we process Personal Information:

• To comply with applicable law and regulations.  This may include laws outside your country of residence, which could give rise to a legal obligation requiring us to process your Personal Information, including:
  • Civil and commercial matters: where we are in receipt of a court order to disclose information for the purposes of court proceedings, such as under Regulation (EU) No 1215/2012 on jurisdiction and the recognition and enforcement of judgments in civil and commercial matters or equivalent UK law.
  • Criminal matters: to comply with requests and orders from EU and EU Member State or UK law enforcement to provide information in relation to a criminal investigation in compliance with applicable local laws, or to take steps to report information we believe is important to law enforcement where so required or advisable under applicable local laws.
  • Consumer matters: to comply with requests from competent authorities under EU or EU Member State or UK consumer protection law, such as under Directive (EU) 2019/2161 and its implementing laws in EU Member States or equivalent UK law.
  • Corporate and taxation matters: to comply with our obligations under applicable EU Member State or UK corporate and tax legislation, such as where a national tax law of an EU Member State or the UK requires collection of specific transactional Personal Information for tax purposes.
  • Regulatory matters: to respond to a request or to provide information we believe is necessary or appropriate to comply with our obligations to engage with regulators, such as when relevant EU Member State or UK data protection supervisory authorities initiate investigation under the EU or UK General Data Protection Regulation into our company.  These can include authorities outside of your country or region of residence.
  • Compliance and internal investigations: to comply with whistleblowing requirements under Directive (EU) 2019/1937 and its implementing laws in EU Member States.
  • Health and safety regulations: to comply with health and safety reporting obligations in accordance with applicable local laws, such as in relation to accidents involving members of the public on our premises.
• To cooperate with public and government authorities and law enforcement, and for other legal reasons:
  • When we respond to a request or provide information to public and government authorities (these can include authorities outside your country or region of residence);
  • When we respond to law enforcement requests and orders or provide information to law enforcement;
  • For dispute resolution purposes;
  • To enforce our terms and conditions; and
  • To protect our rights, privacy, safety, property, and/or that of our affiliates, you, or others.
• In connection with a sale or business transaction based on our legitimate interests.

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