This Privacy Policy applies to the services, website(s) provided, mobile application(s) (“Platforms”) provided and/or the business conducted, by Silcs Solutions Limited trading as JOOS, a company incorporated in England and Wales with company number 11676869 and whose registered office is at CC413, Cocoa Studios, The Biscuit Factory, 100 Drummond Road, SE16 4DG. (collectively and individually referred to as “JOOS”, “we”, “our”, “us”) who is the controller and responsible for your personal data.

 

We have appointed a data protection officer “DPO” who is responsible for overseeing questions in relation to this Policy. If you have any questions about this Policy, including any requests to exercise your legal rights, please contact the DPO at legal@joos.app

 

What do we collect?

This Policy explains the way we use the information collected about you.

Unless otherwise defined in this Policy, terms used herein will have the same meaning with those defined in the Joos Terms of Use and Service Agreement.

“Personal data” is data that can be used to identify a natural person. During your access and use of our Platforms and services, we collect personal data such as:

(a) your name, gender, date of birth, nationality, telephone number, e-mail address, contact address, identification number and other related information;

(b) your financial information (e.g. credit card numbers and bank account information);

(c) personal data of other individuals (e.g. if you use our services to share content with other individuals, or invite them to use our Platforms or services); and

(d) other information that we are required or authorised to collect under any applicable law to authenticate, identify, or to verify any data that you have provided.

(e) transactional information based on your activities with us (e.g. services you purchased and content you generated, your device type, identity and other unique identifiers);

(f) device or software information (e.g. configuration information on your mobile devices, web browsers or other applications or platforms used to access our Platforms);

(g) geo-locational information;

(h) IP addresses, browsing information (e.g. search history) and other browsing-related data in connection to your use of our Platforms and services;

(i) information about your access to and usage of other mobile applications and software through our Platforms and services; 

(j) information about your use of your user account to access into other third-party websites, applications or services; and

(k) other publicly available personal data, including any which you have shared via a public platform (such as a Twitter feed or public Facebook page).

We do not collect any Special Categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

We want to inform you that whenever you use our Service, in a case of an error in the app we collect data and information (through third party products) on your phone called Log Data. This Log Data may include information such as your device Internet Protocol (“IP”) address, device name, operating system version, the configuration of the app when utilizing our Service, the time and date of your use of the Service, and other statistics.

We may also collect personal data and information where required or permitted by any applicable law.

We may also collect personal data and information from you when you submit an enquiry, feedback or email through our websites or other communication channels.

If you provide or allow the collection of personal data of anyone other than yourself, you warrant that you have informed him/her of the purposes for which we require his/her personal data and that he/she has consented to your disclosure of his/her personal data to us for those purposes.

 

How we use personal data collected and our legal grounds for processing your information

We collect and use the personal data received from you for the purposes listed below and any other related or associated purposes.

 

Service-related purposes. 

We collect and use your personal data for the purposes of providing you with the services (on the basis that it is necessary for us to do so for the performance of our contract or if it is in our legitimate interest to do so), such as:

(a)providing you with the services that you have requested;

(b)To improve our service;

(c)Allow us to manage our service’

(d)authenticating, operating and maintaining your user account;

(e)developing, operating and improving our Platform, products, services and content;

(f)to provide you with personalised services based on how you access and use our Platform and services;

(g)to send you important notices and announcements such as services- related information, modification to terms, rules and software upgrading; and

(h)to respond to your feedback.

 

Business purposes.

We may also collect and use your personal data for purposes connected or relevant to our business (if it is in our legitimate interests to do so or pursuant to any legal obligation we are subject to), such as:

(a) complying with our legal obligations and requirements;

(b) enforcing obligations owed to us, and contractual terms and conditions;

(c) accounting, risk management and record keeping;

(d) carrying out research, planning and statistical analysis;

(e) to prevent, detect, process and investigate fraudulent or other illegal activities, or mitigate the risk of occurrence of the aforementioned events;

(f) staff training; and

(g) any other reasonable purposes related to the aforesaid.

 

Additional purposes.

If you have consented, we may collect and use your personal data for additional purposes such as:

(a) inviting you to promote our Platforms and services on social media platforms;

(b) informing you of our latest activities, special offers and promotions;

(c) informing you of other third-party products and/or services that you may be interested in;

(d) inviting you to participate in polls and questionnaire surveys that may be conducted by us and/or third parties; and

(e) publicising your feedback about us and/or our services on our marketing materials (including but not limited to newspapers, social media channels, etc.).

 

Contacting you.

When using your personal data to contact you for the above purposes, we may contact you via regular mail, e-mail, SMS, telephone, push notifications (on your devices) or other means. You may determine the type and manner of information that you will receive from us by adjusting your communication preferences on our Platforms or your device.

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

We will only use your data for the purpose it was collected. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

 

Cookies

Cookies are files with small amount of data that is commonly used an anonymous unique identifier. These are sent to your browser from the website that you visit and are stored on your device’s internal memory.

Our service does not use “cookies” explicitly. However, we may use third party code and libraries that use “cookies” to collection information and to improve their services. You have the option to either accept or refuse these cookies and know when a cookie is being sent to your device. If you choose to refuse our cookies, you may not be able to use some portions of our service.

 

Disclosure of Personal data, Disclosure to service providers.

We may disclose your personal data with third parties such as:

(a) our service providers and data processors that provide services to us (e.g. accounting, hosting and maintenance services, data analytics services, e-mail message services, delivery services, payment transactions services, marketing, etc.); and

(b) our consultants and professional advisors (e.g. accountants, lawyers, auditors).

 

Disclosure for corporate transactions.

We and our affiliates may be engaged in business asset transactions e.g. mergers, acquisitions and transfer of assets. In such circumstances, we may transfer and/or disclose your personal data to facilitate the completion of the transactions.

 

Other permitted disclosure.

We may disclose your personal data as required or permitted by law, e.g. to regulatory authorities, statutory bodies or public agencies to comply with their requirements, policies and directives.

We want to inform users that these third parties have access to your Personal data. The reason is to perform the tasks assigned to them on our behalf. However, they are obligated not to disclose or use the information for any other purpose. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We will not transfer personal data relating to you to a country which is outside the European Economic Area (EEA) unless:

(a) the country or recipient is covered by an adequacy decision of the Commission under GDPR Article 45;

(b) appropriate safeguards have been put in place which meet the requirements of GDPR Article 46 (for example using the European Commission’s Standard Model Clauses for transfers of personal data outside the EEA); or

(c) one of the derogations for specific situations under GDPR Article 49 is applicable to the transfer. These include (in summary):

●the transfer is necessary to perform, or to form, a contract to which we are a party:

owith you; or

owith a third party where the contract is in your interests;

●the transfer is necessary for the establishment, exercise or defence of legal claims;

●you have provided your explicit consent to the transfer; or

●the transfer is of a limited nature, and is necessary for the purpose of our compelling legitimate interests.

 

Retention and protection of personal data 

We will retain your personal data for so long as we need the personal data for to fulfil the purpose we collected it for, and for our business and legal purposes. We will dispose of or delete such information if it is no longer necessary for us to retain your personal data.

We will take reasonable precautions to safeguard your personal data to prevent the loss, improper use, or unauthorised disclosure of your personal data. However, we cannot be held responsible for any safety or security breach (e.g. hacking) that is beyond our control.

When you use our Platforms and services, you may choose to share and upload your personal data to be publicly available to other users. We are not responsible for protecting and may not be able to remove from our Platforms any personal data that you have made publicly available. Please carefully consider any content that you share, upload, release or communicate through our Platforms and services.

Unless we are required or permitted by law to hold on to your personal data for a specific retention period, we may retain your data for up to 6 years. In some circumstances you can ask us to delete your data (see your rights below for further information).

 

About integrating third-party SDKs

Joos currently integrates third-party SDKs in order to collect users' usage behavior of APP features, including: the number of times users click function buttons in a certain period of time, and the path behavior of users entering key pages.

This collection will not compromise the user's privacy in any way. This will be used exclusively to optimise the app functionability to improve the user experience.

 

Your rights

What information do we collect?

Your provision of personal data to us is voluntary. If you choose not to provide us with your personal data, it may not be possible for us to provide you with access to our Platforms or the services that you require.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Where we need to collect data by law, or in order to provide you with our services, and you fail to provide such data when requested, we may be unable to provide you with our services and we may have to cancel your right to use our services. 

You may (in certain circumstances):

(a) access your personal data through your user account;

(b) make corrections to your personal data through your user account;

(c) request the erasure of your personal data;

(d) withdraw consent for our use and disclosure of your personal data by closing your user account;

(e) choose whether to participate in our personalised promotional scheme and other promotional schemes that we may offer from time to time;

(f) object to processing of your personal data;

(g) request the transfer of your personal data; and

(h) request a restriction of processing your personal data.

We may charge you a reasonable fee for responding to your requests for access to your personal data or information about the ways in which we have (or may have) used your personal data if such a request if complex, unfounded or repetitive and such a fee is reasonable in the circumstances. If a fee is to be charged, we will inform you of the amount beforehand and will respond to your request once payment is received.

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). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you 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 could 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.

 

Security

We value your trust in providing us your Personal data, thus we are striving to use commercially acceptable means of protecting it. But remember that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

 

Links to Other Sites

This Service may contain links to other sites. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by us. Therefore, we strongly advise you to review the Privacy Policy of these websites. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

 

Use of third party payment providers (Apple Pay or Google Pay)

When you use our app to make a payment using Apple pay, Google Pay or any other permitted third party payment provider (Providers), we will not collect and store any information from you relating to these financial transactions.

When you use a Provider for payment, you may be asked to input bank card information, or other payment details, but the app will not store any personal financial data, and no such personal data will be shared with third parties by us.

 

Changes to This Privacy Policy

We may update and amend this Policy from time to time. The updated Policy will take effect immediately when it is published on our Platforms. The updated Policy will supersede earlier versions of our privacy policy and will apply to personal data provided to us previously. If you do not agree with our updated Policy, please immediately cease your access and use of our Platforms and services. You are deemed to have read and understood the updated Policy if you continue to access and use our Platforms and services after the updated Policy takes effect.

 

Contact Us

If you have any concerns on how we handle your personal data, wish to make any requests in relation to your personal data, or have any queries in relation to this Policy, please contact our Data Protection Officer at legal@joos.app. You also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office. Please see further information at www.ico.org.uk.