1. Introduction

At the JustCo Group (“JustCo”) we respect the privacy and confidentiality of the personal data of our members and others whom we interact with in the course of providing our services as well as of applicants who apply for positions with us. We are committed to implementing policies, practices and processes to safeguard the collection, use and disclosure of the personal data you provide us.

We have developed this Data Protection Notice to assist you in understanding how we collect, use, disclose, process, protect and retain your personal data that is in our possession. We will comply with all applicable laws with regards to data privacy, and where local laws are more stringent than this policy, then such laws shall prevail and JustCo shall comply with such laws.

2. How We Collect Your Personal Data

Personal data means data, whether true or not, about a customer who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.

We collect your personal data when you:

• Subscribe or purchase our services
• Use our services
• Enquire / respond to our range of services via our marketing, promotional campaigns including electronic direct mails (EDMs)
• Are referred to us by one of our members or business partners
• Provide feedback to us on our quality of service
• Visit our websites and leave behind your contact information
• Visit our locations which are being monitored by closed circuit television
• Communicate with us via emails or written correspondences

3. Types of Personal Data We Collect About You

The types of personal data we collect about you include:

• Contact information (Name, Address, Phone No., Email Address)
• Biometric information (Pictures, Video from security cameras, voice recordings)
• Payment / financial information (Bank Account No., Credit/Debit Card Name, Credit/Debit Card No., Card expiry date)
• Account information (account balance, valid subscriptions)
• Location Data
• Information on the use of our services (frequency of use of our services, location of use etc)
• Information from other organisations (your employer or other entities we believe you have authorized to provide your personal details on your behalf)

4. How We Use Your Personal Data

We use the personal data you provide us for one or more of the following purposes

• Verify your identity
• Inform you of any updates or improvements
• Manage, analyse and improve our services, business and operations to serve you better or enhance customer experience
• Respond to opinions, comments or feedback about our products or services
• Process and manage our services
• Process billing, payment and other credit-related activities
• Conduct market research, direct marketing and lead generation activities
• Conduct joint marketing with other companies and service providers
• Communicate with customers, guests, members and website visitors
• Comply with or fulfil legal obligations and regulatory requirements
• Ensure the security and safety of our users

5. Who We Disclose Your Personal Data To

We may disclose some of the personal data you provide us to our related corporations, as well as the following entities or organisations outside JustCo for one or more of the purposes set out in section 4:

• EDM / Email Service Vendors
• Payment processors and financial institutions
• Research institutions
• Advertisers / Advertising Agencies
• Event Organisers
• Our Data Processing and IT Services Providers to facilitate guest registration
• Freight / Courier Services
• HR / Payroll Processing Services and Insurance Companies
• Government Agencies

Where required to do so by law, we may disclose personal data about you to the relevant authorities or to law enforcement agencies.

6. How We Manage the Collection, Use and Disclosure of Your Personal Data

6.1 Obtaining Consent

Before we collect, use or disclose your personal data, we will notify you of the purpose why we are doing so, including via this Privacy Policy. You consent to the collection, use and disclosure of your personal data for the purposes set out in this Privacy Policy.

Under certain circumstances, we may assume deemed consent from you when you voluntarily provide your personal data for the stated purpose, e.g. when you provide your name and payment details in order to purchase services from us.

We may rely on exceptions to the need for consent under applicable for the collection, use or disclosure of your personal data under the following circumstances. for example:

• The personal data is publicly available
• The personal data is disclosed by a public agency or disclosed to a public agency
• The personal data is necessary for any investigation or proceedings
• The personal data is necessary for evaluative purposes
• The personal data is necessary to recover a debt owed by an individual to JustCo, or for JustCo to pay a debt owed to the individual
• The personal data is necessary for a business asset transaction
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6.2 Withdrawal of Consent

If you wish to withdraw consent, you should give us reasonable advance notice. We will advise you of the likely consequences of your withdrawal of consent, e.g. without your personal contact information we may not be able to inform you of future services offered by us.

Your request for withdrawal of consent can take the form of an email or letter to us, or through the “UNSUBSCRIBE” feature in an online service.

6.3 Use of Cookies

We use “cookies” to collect information about your online activity on our website. A cookie is a small text file created by the website that is stored in your computer to provide a way for the website to recognise you and keep track of your preferences. The cookie makes it convenient for you such that you do not have to retype the same information again when you revisit the website or in filling electronic forms.

Most cookies we use are “session cookies”, which will be deleted automatically from the hard disk of your computer at the end of the session.

You may choose not to accept cookies by turning off this feature in your web browser. Note that by doing so, you may not be able to use some of the features and functions in our web applications.

7. How We Ensure the Accuracy of Your Personal Data

We will take reasonable steps to ensure that the personal data we collect about you is accurate, complete, not misleading and kept up-to-date.

From time to time, we may do a data verification exercise for you to update us on any changes to the personal data we hold about you. If we are in an ongoing relationship with you, it is important that you update us of any changes to your personal data (such as a change in your mailing address).

8. How We Protect Your Personal Data

We have implemented appropriate information security and technical measures (such as data encryption, firewalls and secure network protocols) to protect the personal data we hold about you against loss; misuse; destruction; unauthorised alteration/modification, access, disclosure; or similar risks.

We have also put in place reasonable and appropriate organisational measures to maintain the confidentiality and integrity of your personal data, and will only share your data with authorised persons on a ‘need to know’ basis.

When we engage third-party data processors to process personal data on our behalf, we will ensure that they provide sufficient guarantees to us to have implemented the necessary organisational and technical security measures, and have taken reasonable steps to comply with these measures.

9. How We Retain Your Personal Data

We have a document retention policy that keeps track of the retention schedules of the personal data you provide us, in paper or electronic forms. We will not retain any of your personal data when it is no longer needed for any business or legal purposes. We will dispose of or destroy such documents containing your personal data in a proper and secure manner when the retention limit is reached.

10. How You Can Access and Make Correction to Your Personal Data

You may write in to us to find out how we have been using or disclosing your personal data. Before we accede to your request, we may need to verify your identity. We will respond to your request as soon as possible, and, where possible we will let you know and give you an estimate of how much time we require. We may also charge you a reasonable fee for the cost involved in processing your access request.

If you find that the personal data we hold about you is inaccurate, incomplete, misleading or not up-to-date you may ask us to correct the data. Where we are satisfied on reasonable grounds that a correction should be made, we will correct the data as soon as possible, or within 30 days from the date we receive your request

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11. Contacting Us

If you have any query or feedback regarding this Policy, or any complaint you have relating to how we manage your personal data, you may contact our Data Protection Officer (DPO) at: Dataprotection@JustCoGlobal.com

Any query or complaint should include, at least, the following details:

• Your full name and contact information
• Brief description of your query or complaint

We treat such queries and feedback seriously and will deal with them confidentially and within reasonable time.

12. Changes to this Data Protection Notice

We may update this Data Protection Notice from time to time. We will notify you of any changes by posting the latest Notice on our website. Please visit our website periodically to note any changes.

Changes to this Notice take effect when they are posted on our website.

Dated 1 July 2021