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Privacy Policy

From October 1 2018

 

About this Privacy Policy

This privacy policy explains how and why we collect personal information and how we use that information. When we do so we are regulated under applicable local data protection laws including in the European Union (“EU”) the General Data Protection Regulation (“GDPR”) where we are responsible as ‘controller’ of that personal information. We may also provide you with additional information at the time we collect your personal information where we feel it would be helpful to provide relevant and timely information.

 

Who we are

JETHRO LIMITED (registered office, 1st floor, 26 Fouberts Place, London W1F 7PP, United Kingdom) referred to as “JETHRO” or “we” or “our”.

For the purposes of EU law, Jethro Limited is the data controller and has appointed Paul Babs as Data Protection Officer in email: moreinfo@jethroltd.com, Tel.:+44(0)20 3142 7009.

 

Personal Information we may collect:

We collect personal information through your interactions with us, such as when you contact us or when you provide your details through our online registration forms, when you use our services and products, when you use our websites and online services or when you visit our offices. We may also receive personal information about you from third party sources.

 

Personal Information you give us:

  • You may give us information by filling in forms on one of our websites or portals (including www.jethroltd.com or when you register for our events), or by contacting us by phone, email or otherwise or when we meet at a conference or event or through other marketing activities. This includes information you provide when you register to use our website(s) or one of our portals, participate in any discussion board or other social media function on our websites.
  • The personal information you give us may include your name, address, job title, email address, LinkedIn, Twitter or other social media ID and phone number(s).
  • If you register to attend one of our events, we may need to ask you for the following additional information where we are arranging transport, accommodation and/or hospitality for you: passport/identity card details, date of birth, nationality/citizenship, dietary requirements, room requirements, dates of travel, emergency contacts.

 

Information you give us when you use our services including product support:

  • Product and Services Usage data (e.g. product version number)
  • Troubleshooting and help data
  • Error Reports and Performance Data
  • We do not usually require or request personal information of your clients/end customers when we provide you with support services for our products and request that you do not provide such information to us.

 

Personal Information you give us about others:

  • If you give us personal information on behalf of someone else you confirm that you have given them the information set out in this notice, that they have given you permission to act on their behalf and for us to use their information as set out in this notice.

 

Personal Information about you we collect or receive from third party sources:

  • We may receive information about you from one of your work colleagues or other personnel in your company or business.
  • We may collect information about your personal or professional interests that you have made available on social media platforms you use such LinkedIn and Twitter.
  • We are working closely with third parties who may share your personal information with us
  • We may also receive information about you from other third parties we have engaged such as business associates, subcontractors, analytics providers, platform providers and search information providers.

 

Technical Information we collect when you use our websites:

  • We collect the internet protocol (“IP”) address used to connect your computer to the internet, your login information, browser type and version. JETHRO uses your IP address to help diagnose problems with our server and/or to administer our site(s). This informs us of which parts of our site users are visiting.
  • Information about your visit, including the url clickstream to, through and from our site, including date and time; pages you viewed, page response times, download errors, length of visits, page interaction information.
  • JETHRO or third-party software, widgets and apps downloaded from the site (downloads) may provide JETHRO with information about the device type, network connectivity, location of the device running a download, information about when a download is launched, individual session lengths for downloads, or why a download may not be working.
  • We do not usually link IP addresses to any other personally identifiable information, so a user’s session will be tracked, but the user will be anonymous, However, if you click on a link to our website in a marketing email we have sent you, we will be able to link your IP address to you and will track your response to understand the effectiveness of our marketing campaigns and which products and services are of interest to you. This helps us to avoid sending you information which is not relevant or of interest to you.

 

 

 

 

Cookies:

  • We use cookies (small text files placed on your computer) and similar technologies when you visit our websites. For further information about cookies generally visit allaboutcookies.org.

 

Information collected when you visit our offices:

  • We and/or our Landlords may collect your name and time of entry and exit. Images of you may also be recorded via CCTV if our building has security cameras. This information may be monitored by JETHRO and/or our Landlords’ facilities and security functions for safety and security purposes.

 

Special Categories of data:

  • We do not normally need to collect special categories of data/sensitive personal data. Sensitive personal data includes information about racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic data, biometric data in order to uniquely identify a person or data concerning health or mental health, sexual orientation, criminal records. We request that you do not provide this information to us unless we specifically request this and you consent to processing of such data by us.

 

Non-Personal information:

  • We also collect non-personal information or may anonymize personal information in order to make it non-personal. JETHRO may collect, store, use and transfer and disclose non-personal information for any purpose.

 

Uses made of the information and legal basis for this use:

We use information you provided us as required to carry out our obligations under contracts between us, to communicate with you in order to provide you with information about our products and services, to enable us to operate our business and to pursue our legitimate interests where these are not outweighed by your applicable data protection rights and to comply with applicable laws and/or to protect our legal rights. We may combine the information we received from other sources with information you give us and information we collect about you. We may use this information and the combined information for the purposes we set out above.

 

As required to establish and carry out contractual obligations:

  • As required to establish and to carry out our obligations arising from any contracts entered into between you and us and provide you with the information, products and services that you have contracted to receive from us, including but not limited to:
  • To process an order from you;
  • To carry out our rights and obligations arising from such order;
  • To update you on progress of an order;
  • To issue and pursue invoices;
  • To provide after sales support; and
  • To provide you with services under the contract.

 

To enable our business and pursue our legitimate interest

  • As required to enable our business and pursue our legitimate interests, in particular:
  • To facilitate and personalize our interactions with you and to invite you to events which may of interest;
  • To provide you with information about other products and services we offer that are similar to those that you have already purchased or enquired about;
  • To provide you or permit selected third parties to provide you with information about products and services which we feel may be of interest to you;
  • To notify you about changes to our services and products;
  • To invite you to participate in surveys;
  • To understand client requirements, perform analysis and comparisons and to obtain your views on our products, services and websites;
  • To develop and test products and services;
  • To improve our websites and ensure that their content is presented in the most effective manner for you and for your computer;
  • To administer our websites and inform internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • To allow you to participate in interactive features of our service and websites when you choose to do;
  • To keep our websites safe and secure;
  • In relation to JETHRO events, we may use your name in any social media/app/event materials for the event which is available to registered delegates; and
  • Photos and video from JETHRO events may be distributed to participants and used in promotion material for future events. We will request your permission, where this is required by applicable law or we think it is appropriate.

 

 

To comply with applicable laws and protect our legal rights

As required to comply with applicable laws and to protect our legal rights, including but not limited to:

  • to comply with our obligations under applicable laws (such as export controls and sanctions, anti-money laundering and anti-bribery and corruption laws).
  • use in connection with legal claims,
  • compliance, regulatory investigative purposes (including disclosure of such information in connection with legal process or litigation); and
  • other ethics and compliance reporting.

 

Disclosure of your information

We may provide your information by electronic or other means to processors, including:

  • To third party processors outside of JETHRO (some of whom may also be based outside the EEA) including:
  • business partners;
  • subcontractors for the performance of any contract or request or service we are supplying to you;
  • Our suppliers including:
    • platform and Database hosting providers (Oracle, Microsoft, Hetzner), BI/CRM (Tableau) and other technology providers (Google);
    • analytics and search engine providers to assist us in the improvement and optimization of our website, although ordinarily only technical information is shared;
    • digital agencies, event organizers, PR agencies, marketing services providers, survey providers;
    • hotels, conference/event management providers, destination management providers.
  • with social media providers (such as LinkedIn, Google+ and Twitter) from time to time, to enable us to provide marketing materials/targeted adverts to you that you have agreed to receive through your privacy settings on those sites;
  • our auditors and other professional advisors where they need access to such information;
  • in connection with an acquisition, transfer or merger with another company;
  • To third parties where required by law, court order or regulation.

 

Transfer of your information outside the EEA

Where information is transferred outside the UK, and the EEA and where this is to a JETHRO supplier, business partner, subcontractor or other entity in a country that is not subject to an adequacy decision by the EU Commission, your information will be adequately protected by the EU Commission approved standard contractual clauses, an appropriate Privacy Shield certification or a vendor’s Processor Binding Corporate Rules (as permitted under the GDPR).

 

Retention of your personal information

JETHRO will keep this information for the duration of our business relationship and to the extent permitted or required under applicable law, after termination of the business relationship. Laws may require JETHRO to hold certain information for specified periods. In other cases, JETHRO may retain data for an appropriate period after the business relationship ends to comply with its legal obligations, to meet regulatory requirements or to protect itself from legal claims. In relation to other personal information collected, JETHRO requires this to be deleted as soon as the purpose for which it was collected ceases, or the information is no longer needed for that purpose.

 

How we protect your personal information

We will use appropriate technical and organizational security measures which are designed to prevent personal information from being accidentally lost or accessed or used in an unauthorized way. We limit access to your personal information to those who have a genuine business need to do so. Our personnel are subject to a duty of confidentiality and required to undertake training on how to handle personal information in an appropriate manner. Where we use third parties to provide services and process personal information on our behalf we require them to use personal information we share with them only in accordance with our instructions and not for other purposes. We will comply with any notification obligations in the event of a breach.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, you should be aware that the security of your information transmitted to and from you via the internet cannot be guaranteed and any such transmission by you is at your own risk.

 

Password protection

Where we have given you or you have chosen a password or access code which enables you to access certain parts of our website, this will be unique to you and you are responsible for keeping this password confidential. If you are prompted to create or update your password, you should create a strong password and never share your login details with anyone. If you suspect your password may have been compromised, you must tell us immediately by contacting the administrator of the relevant service and change your password using the reset/forgotten password function.

 

Third party websites

Our websites may from time to time contain links to and from the websites of our JETHRO Partners and other business associates. Please note that these websites are not operated by JETHRO and have their own privacy policies. Social media features used on our website such as ‘like’ buttons may enable the providers of those features to collect information about you and are subject to the privacy policies published on the website of the company which provides the feature. We do not accept any responsibility or liability for these third-party websites or their privacy policies. Please check these policies before you submit any personal information to these websites or use their features.

 

Whether information has to be provided by you and if so why

Where we require personal information to comply with legal or contractual obligations, then we need to process this information; if such data is not provided, we will not be able to manage the business relationship or meet contractual or legal obligations placed on us. In other cases, provision of requested personal information is optional. However, if you do not provide that personal information we may be prevented from providing you with relevant information about our products and services. Technical information may be collected automatically if you visit our websites.

 

Your Data Protection Rights

Where applicable, you may have certain rights under the GDPR or local legislation in the EEA including the right to ask us for a copy to see or update the personal information held about you as well as obtain supporting explanatory materials. You may ask us to make any necessary changes to your data ensure it is accurate and up to date or ask us to restrict the processing of the data transfer it to other organizations at your request in certain circumstances. You may also have rights to object to some processing and where we have asked for your consent to process your data, to withdraw your consent. Where we process your data because we have a legitimate interest in doing so, you may also have the right to object to this. These rights may be limited in some situations – for example, where we can demonstrate that we have a legal requirement to process your data. Where applicable, you may have similar rights in your country under local legislation to access and correct/update your data.

If you wish to exercise any of these rights you can get in touch with us at Jethro Limited, 1st floor 26 Fouberts Place, London W1F 7PP, United Kingdom, or by email moreinfo@jethroltd.com, marked for the attention of Legal Webmaster.

 

How to complain

We hope that we can satisfy queries you may have about the way we process your information. If you have any concerns, you can get in touch with Jethro Limited, 1st floor 26 Fouberts Place, London W1F 7PP, United Kingdom, or by email moreinfo@jethroltd.com, marked for the attention of Legal Webmaster.

If you have unresolved concerns, you may also complain to the relevant supervisory authority (if applicable) in the country where you work, normally live or where any alleged infringement of data protection laws occurred.

Changes to our Privacy Policy

Any changes we make to our Privacy Policy will be posted on this page. Please check back from time to time to see any updates or changes to the policy. We will update the date at the top of this page when we make updates or changes and may place a banner on our website if we make material changes. If we consider it appropriate, we will also notify you that we have updated our privacy policy through other communications channels, such as by email.

 

How to Contact Us

Please make use of the Contact Us section on the website. You may also if you wish to exercise any of your legal rights, write to us at Jethro Limited, 1st floor 26 Fouberts Place, London W1F 7PP, United Kingdow, or by email moreinfo@jethroltd.com, marked for the attention of Legal Webmaster.
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