Privacy Policy

This privacy policy ("Privacy Policy") applies to all personal information process activities undertaken by JustCarbon Holdings. JustCarbon Holdings is a data controller for personal information that processed in connection with the JustCarbon Platform, including the Site at (www.justcarbon.com) and/or any Products or Services JCH provides from time to time (collectively the “Platform”) that necessitates the collection of personal information from persons using the Platform (“users”). This policy sets out how JCH collects, uses and stores user’s personal data as well as explaining user’s rights in respect of the personal data JCH holds with regard to such users.

Users should contact JCH at (www.justcarbon.com/contact) for more information regarding the Privacy Policy.

THE INFORMATION JCH PROCESSES

JCH collects and processes various categories of personal information at the start of, and for the duration of, user’s engagement with the Platform. JCH limits the collection and processing of information to information necessary to achieve one or more legitimate purposes as identified in this Policy. JCH will only collect users’ information in line with applicable regulations and law. The information JCH collects may include: personal details, e.g. name, previous names, gender, date and place of birth; contact details, e.g. address, email address, landline and mobile numbers; information concerning user’s identity e.g. photo ID, passport information, social security number, National ID card and nationality; market research, e.g. information and opinions expressed when participating in market research; user login and subscription data; other information about user that user provides by filling in forms or by communicating with JCH, whether face-to-face, by phone, email, online, or otherwise; user’s financial and credit information and information about user’s relationship with JCH, including the products and services user’s utilizes, the channels user uses and user’s ways of interacting with JCH; information JCH uses to identify and authenticate user, e.g. user’s signature and biometric information, such as user’s voice for voice ID, or additional information that JCH receives from external sources that we need for compliance purposes; geographic information, e.g. user’s location when signing up to any products or services that are only available in certain jurisdictions; marketing and sales information, e.g. details of the services user receives and user’s preferences; cookies and similar technologies JCH uses to recognise users, remember user’s preferences and tailor the content JCH provides to users (see paragraph 3 for more information on cookies); investigations data, e.g. due diligence checks, sanctions and anti-money laundering checks, external intelligence reports, content and metadata related to relevant exchanges of information between and among individuals and/or organisations, including emails, voicemail, live chat, etc.; records of correspondence and other communications between JCH, including email, live chat, instant messages and social media communications; information that JCH requires to support any regulatory obligations, e.g. information about transaction details, detection of any suspicious and unusual activity and information about parties connected to user or these activities; information user has asked JCH to collect for user, e.g. information about user’s accounts or holdings with other companies including transaction information; information from third party providers, e.g. information that helps JCH to combat fraud or that relates to user’s social interactions (including user’s communications via social media, between individuals, organisations, prospects and other stakeholders acquired from companies that collect combined information);

COOKIES

Cookies are text files containing small amounts of information which are downloaded to user’s device when user visits a website. Cookies are useful because they allow a website to recognise user’s device, preferences and can be used to improve user’s online experience. All recent versions of popular browsers give users a level of control over cookies. A user can set user’s browser to accept or reject all, or certain, cookies. Users should be aware that some areas of the Site may not function after user has changed user’s cookie settings.

HOW JCH COLLECTS USER INFORMATION

JCH may collect user’s personal information from a variety of sources including: information user gives to JCH; information that JCH receives from third parties including third parties who provide services to user or JCH, fraud prevention or government agencies; information that JCH learns about user through JCH’s relationship with user and the way user operates user’s accounts and/or services, such as the transactions made to, from, through and/or by reference to user’s accounts; information that JCH gathers from the technology which user uses to access the Services (for example location data from user’s mobile phone, or an IP address or telephone number) and how user uses it (for example, pattern recognition); and information that JCH gather from publicly available sources, such as the press, the electoral register, company registers and online search engines.

HOW JCH WILL USE USER’S INFORMATION

JCH will only use user’s information with user’s consent to do so unless there is an otherwise lawful reason for using such information. These lawful reasons include where JCH: needs to pursue our legitimate interests; needs to process the information to carry out an agreement JCH has with user; needs to process the information to comply with a legal obligation; believes the use of user information as described is in the public interest, e.g. for the purpose of preventing or detecting crime; needs to establish, exercise or defend JCH’s legal rights; needs to use user’s information for JCH’s insurance purposes. The reasons JCH uses users’ information include to: deliver JCH products and services; carry out user’s instructions; carry out checks in relation to anti-money laundering; manage JCH’s relationship with user, including (unless user otherwise instructs) telling user about the Products and Services JCH believes may be relevant for user; understand how user uses the Products and Services; support JCH’s network operations; prevent or detect crime including fraud and financial crime, e.g. financing for terrorism and human trafficking; ensure security and business continuity; manage risk; provide DApps and other online product platforms; improve JCH’s Products and Services; analyse data to better understand user’s circumstances and preferences so JCH can improve Products and Services offered; protect JCH’s legal rights and comply with JCH’s legal obligations.

USER RIGHTS

Users have a number of rights in relation to the information that JCH hold about such users. These rights include: the right to access information JCH holds about user and to obtain information about how JCH processes it; in some circumstances, the right to withdraw user’s consent to JCH’s processing of user’s information, which user can do at any time. JCH may continue to process user’s information if JCH has another legitimate reason for doing so; in some circumstances, the right to receive certain information user has provided to JCH in an electronic format and/or request that JCH transmit it to a third party; the right to request that JCH rectify user’s information if it’s inaccurate or incomplete; in some circumstances, the right to request that JCH erases user’s information. JCH may continue to retain user’s information if JCH is entitled or required to retain it; the right to object to, and to request that JCH restrict the processing of user’s information in some circumstances. Again, there may be situations where user objects, or ask JCH to restrict, JCH’s processing of user’s information but JCH is entitled to continue processing such information and/or to refuse that request. User can exercise user’s rights by contacting JCH User also has a right to complain to the data protection regulator in the country where user lives or works.

WHO JCH MAY SHARE USER’S INFORMATION WITH

JCH will not share users’ information with anyone outside JCH except: where JCH has user’s permission; where required for user’s use of Product or Service; where JCH is required by law and by law enforcement agencies, judicial bodies, government entities, tax authorities or regulatory bodies around the world; with third parties where required by law to help recover funds that have entered user’s account as a result of a misdirected payment by such a third party; with sub-contractors engaged from time to time by JCH to undertake any KYC/AML verification process; with other participants of the Platform subject to obtaining user’s prior approval before doing so; where user has agreed for JCH to do so, or where JCH suspects funds have entered user’s account as a result of a financial crime; where permitted by law, it is necessary for JCH’s legitimate interests and it is not inconsistent with the purposes listed above.

HOW LONG DOES JCF KEEP USER INFORMATION

JCH will retain user’s personal data in accordance with applicable law and JCH’s own data storage time limits. Whilst JCH will not retain user information for longer than necessary, JCH will take the following factors into account: how long JCH needs to keep the data for in the event of any claims or litigation; guidance from government or regulatory bodies; how long JCH needs to keep the data to fulfil the original purpose for which it was collected; the nature and sensitivity of personal data; and compliance with legal obligations

HOW JCH PROTECTS USERS’ DATA

The protection and security of user’s personal data is a high priority for JCH. JCH has a dedicated team who enforce and assure good industry security practices. This enables JCH to secure and protect personal data from loss or unauthorised disclosure or damage in a consistent and appropriate manner.

HOW TO CHANGE USER’s MARKETING PREFERENCES

User will receive an email from JCH when user’s contact details are added to JCH’s contacts database. If user no longer want to receive any marketing from JCH, user should send an email to support@justcarbon.com and JCH will action such request. Please note it can take up to 72 hours for user’s request to take effect.

HOW TO MAKE A COMPLAINT

Users should direct any complaint relating to how JCH has processed user’s personal data to support@JustCarbon.com JCH will make every endeavour to resolve any query or concern user’s raise about JCH’s use of user’s personal data. Under applicable law, user may also have the right to lodge a complaint with a supervisory authority, where user work, normally live or where any alleged infringement of data protection laws has occurred.

LINKS TO OTHER WEBSITES

JCH sometimes provide users with links to other websites, but these websites are not under JCH’s control. JCH will not be liable to user for any issues arising in connection with such partys’ use of user’s information, the website content or the services offered to user by these websites. JCH recommends that users check the privacy policy and terms and conditions on each website to see how each third party will process user’s information.

TRANSFER OF DATA BETWEEN JURISDICTIONS

As an international business, personal data may be transferred to JCH’s subsidiaries and affiliates worldwide due to, for example, JCH’s shared IT systems and/or cross border working. When contracting with suppliers and/or transferring personal data to a different jurisdiction, JCH will take appropriate steps to ensure that user’s data is treated securely and the means of transfer provide adequate safeguards in accordance with applicable law.

CONTACT INFORMATION

Users should contact JCH at support@JustCarbon.com should users require any assistance or further clarification on this Privacy Policy.