Personal information and personal data for the purpose of this Policy is defined as ‘any sort of information or an opinion about an individual, whether true or not’, and includes all personal data about an individual, or which can be used to identify an individual either directly or indirectly (referred to collectively as “Personal Information”).
A sub-category of Personal Information is sensitive information and data. For the purposes of this Policy, sensitive information and data includes information of a particularly sensitive nature, such as information relating to an individual’s health, racial or ethnic origins, political opinions, membership of a trade union or political association, religious beliefs or affiliations, philosophical beliefs, sexual preferences, or criminal record.
If you are an EU resident, then please refer to our which explains your rights and our obligations under GDPR law.
1. What Personal Information does Jonah and Associates collect, from whom, and for what purpose?
Jonah and Associates will only collect Personal Information that is necessary for its functions and activities. We will only collect Personal Information by fair and lawful means. Jonah and Associates may collect and process Personal Information through a variety of means, including, as examples, access to Jonah and Associates sites or services, employment processes, or correspondence with Jonah and Associates representatives through purchase of goods or services or in the course of online services. Jonah and Associates collects and holds different categories of information depending on the services being provided and the jurisdiction in which those services are being provided. The following types of Personal Information may be collected:
(a) Information about Jonah and Associates’s contractors and suppliers
Jonah and Associates collects Personal Information directly from and about our contractors and suppliers. This Personal Information includes their name and contact details which allows them to be contacted. For workplace health and safety reasons, we may also collect certain Sensitive Information from contractors with consent; for example, medical information a contractor has provided us about any injuries he or she may currently suffer from.
From third parties, we may also collect feedback and information relating to our contractors and suppliers’ performance of services for Jonah and Associates. This information is collected for the purposes of monitoring our contractors and suppliers’ performance of services, and to ensure that we are able to provide the highest quality Products and Services to our customers.
(b) Information about job applicants
Applicants for a position at Jonah and Associates will be asked to supply details relevant to the job application such as name and contact details, information contained in CVs, and driver’s licence or passport information. We may also collect Personal Information from third parties related to the applicant, such as identified referees. This information is used for the purposes of determining suitability for the vacant role.
(c) Information about customers, their employees and customers
Personal Information may be collected from customers such as name and contact details, bank account, and credit card details.
All customer Personal Information collected by Jonah and Associates is used for our business functions and activities. These include:
- For billing purposes and order fulfilment
- To contact customers about our provision of services
- To maintain account details
- To provide technical support, e.g. account creation, password reset etc.
- To provide information on request about our Products and Services
- To streamline and personalise customer experience while dealing with Jonah and Associates
- To undertake customer satisfaction surveys and to tailor Jonah and Associates information, services or products in order to improve and enhance those services and products provided to our customers.
Jonah and Associates may also collect from its customers Personal Information relating to employees and customers; for example, payroll information. This Personal Information is used so that we can facilitate provision of the services our customers have requested.
Occasionally, Jonah and Associates uses aggregated Personal Information derived from use of our Products and Services to provide us with anonymous demographic and customer usage information. This information does not identify individuals. This anonymous, aggregated information is used to improve Jonah and Associates services and products.
2. Quality of Personal Information
Jonah and Associates will ensure, to the extent reasonably possible, that Personal Information collected, used or disclosed is accurate, up-to-date, complete and relevant. If Jonah and Associates becomes aware that any of the Personal Information it holds is inaccurate, it will take prompt steps to update and correct its records.
3. Data security
Jonah and Associates takes active measures to ensure the Personal Information that it holds is secure and protected from misuse, interference, loss and unauthorised access, modification or disclosure.
All Jonah and Associates ICT devices, storage and channels are subject to continuous monitoring, logging analysis, and audit. Jonah and Associates may choose to contract a third party to perform these functions.
All Personal Information is stored at secure premises using good quality security protocols.
Jonah and Associates’s security systems are regularly reviewed and updated to maintain the integrity of the Jonah and Associates security posture.
4. Access and correction of Personal Information
Subject to verification of identity, any Personal Information held about an individual may be accessed, updated or corrected by application to a Jonah and Associates privacy officer (for contact details, see section 9 below).
There is generally no fee for an individual to make a request or to be provided access to his or her Personal Information. However, depending on the complexity of the request, a reasonable processing fee may be charged in some cases.
Jonah and Associates will endeavour to respond to access and correction of Personal Information within 15 business days after a written request is received by a Jonah and Associates privacy officer.
5. Direct marketing
Jonah and Associates will only engage in direct marketing practices by the laws of the relevant country or jurisdiction. At any time, an individual or organisation may contact Jonah and Associates to request that they no longer wish to receive any marketing material or information from Jonah and Associates.
For email communications, Jonah and Associates also provide a simple opt-out (unsubscribe) mechanism that individuals can easily submit at any time.
If you feel at any stage we have incorrectly used your Personal Information for direct marketing, please contact us immediately (for contact details, see section 9 below).
6. Disclosure and retention of Personal Information
As part of providing services to a customer, Jonah and Associates may disclose Personal Information to third-party suppliers and contractors of services or retain and disclose Personal Information as authorised by law for example metadata.
Jonah and Associates may disclose some Personal Information to its affiliated entities in countries in which Jonah and Associates operate to provide services to our customers, including technical support. Such disclosure is subject to the privacy laws applicable in the jurisdiction where that affiliated entity is located. A formal intragroup agreement is in place to ensure all Personal Information is properly protected at all times for transfers within the Jonah and Associates global group.
Jonah and Associates only retain Personal Information for as long as required by applicable law or as needed for our business functions and activities. If Personal Information is no longer needed, it is then destroyed or disposed of securely.
7. International data transfers
As a provider and user of IT services, including cloud services, Jonah and Associates retain Personal Information on servers that may be located in several overseas countries.
Jonah and Associates recognise and respect the varying national laws and obligations, and their impact on cross-border data transfers when transferring or processing Personal Information outside of the country of collection for the purposes identified above. Jonah and Associates will take all reasonable steps to ensure that no person or entity breaches any relevant privacy and data protection laws using a variety of lawful data transfer mechanisms and contractual agreements for privacy and data protection.
8. Website browsing
9. Privacy issues
Due to the nature of the services that Jonah and Associates provide, in most situations, it will be impracticable for an individual to deal with us on an anonymous basis. However, Jonah and Associates will consider anonymous requests on a case-by-case basis.
If you are not satisfied with Jonah and Associates’ response, and the issue relates to a privacy concern or alleged breach by Jonah and Associates, you may complain to the relevant government authority responsible for privacy and data protection in your jurisdiction.