Just2Pay J.S.C, an international software development company, together with its affiliates and subsidiaries (collectively “Just2Pay” or “we”), has prepared this Policy (“Policy”) to outline its online data protection practices.

This Policy explains why and what information about you will be collected by Just2Pay when you visit its websites at www.just2pay.net and relative subdomains (collectively “Websites”), and when you contact Just2Pay by sending an email, filling in the contact form or otherwise, or when you apply for a job posted on our Website.

It also describes how the information about you will be used, how you, as a data subject, can control your data, and how to get in touch with us if you need it.

This Policy also explains our use of cookies.

Please read this Policy carefully before browsing this Website. We will process your data only as described in this Policy.

Our Websites are not directed to children under the age of 16, and we do not knowingly collect personal data from children of this age group.

This Policy is an integral part of the Terms of Use of this Website. We might update this Policy in the future, so please make sure to read it from time to time.

WHAT DOES Just2Pay HAVE TO DO WITH YOUR DATA?

In light of the EU General Data Protection Regulation (“GDPR”), Just2Pay is a controller and a processor of the personal data submitted through this Website and collected in other ways.

Being a controller means that we are responsible for deciding how we hold and use personal information about you.

Just2Pay uses a third-party “Workable” for recruitment processing services. By submitting an online application for any vacancy placed on our Website you expressly submit your data, contact information, CV, and any other information you choose, and agree that it will be collected and processed by both Just2Pay and Workable. In such cases, Just2Pay stays the data controller and Workable becomes the processor of your data.

 

 

WHAT DATA ABOUT YOU DO WE COLLECT?

We only collect information about you that is necessary for us to allow you to use the Website or contact us, and only to the extent specifically provided in this Policy.

• information we obtain from you

When you contact us via email or the contact form, you provide us your name, phone number, e-mail address, communication content, and data associated with the communication.

Examples of personal data that you provide to us when applying for a vacancy are full name, e-mail, phone number, location, and any other information you choose to provide in your CV or together with it.

You might also choose to provide us with any other personal data, for example, the personal data of a candidate for work whom you want to refer.

From time to time, Just2Pay also receives personal information about individuals from third parties around the world. This may happen if you publish your CV on the Internet on some job boards, giving them the consent to use and transmit your data, if someone recommended you for potential employment, and in other similar cases.

We encourage you to review the privacy policies of any third-party websites before providing your information to them.

 

• Information we obtain from your use of our Websites

When you visit our Websites we may collect the following information about you:

information about your device(s), in particular, hardware model, version of the operating system;

information about your visits to and use of this Website, including your IP address, geographical location, browser type, and version, referral source, page views, and Website navigation paths;

cookies. For more information on the cookies being used on the Website and how you can opt-out, please visit section 7 of this Policy.

 

WHY DO WE PROCESS YOUR DATA?

We will only process your data where we have a legal basis to do so. The legal basis will depend on the reasons we have collected and the need to use your data. We may process your data because:

• You have consented to us using your data
• We need to comply with a legal obligation
• It’s in our legitimate business interests

 

More specifically, personal data submitted to us through this website and personal data we collected from you or third parties or public sources will be used for the purposes based on the legal grounds as follows:

 

1. Communications, based on Just2Pay’s legitimate interest, art. 6 para. 1 f GDPR:

if you have contacted us via this website or otherwise, we may process your data to be able to answer your questions, organize the meeting, call, zoom, or other communication. Please note that this communication may be recorded and stored by a Just2Pay representative in Just2Pay corporate system.

1. Marketing and public relations, based on your consent, art. 6 para. 1 a GDPR:

• if you are a visitor of our website, we may, by way of cookies, process your data to carry out marketing research and analyze the characteristics of this website visitors, assess the impact of our marketing communication, and adjust it to the detected tendencies, to plan our future marketing activities, to prepare analytics and profiling for business intelligence, to target our advertising.
• if you are our subscriber, you receive or would like to receive our marketing materials, we may process the personal data you provided to us to spread promotional materials, make announcements about additions and changes concerning our services, send you e-mail notifications, and send you our email newsletters.

1. Recruitment:

• Based on your consent, art. 6 para. 1 a GDPR:

if you are a potential employee, we may process your data to assist you with ongoing or future employment or cooperation with Just2Pay, to enable you to submit your resume, apply for jobs online or express your interest in relocation.

• Based on Just2Pay’s legitimate interest, art. 6 para. 1 f GDPR:

in specific cases, and only upon the client’s request, we may show your CV to a potential client for business engagement or to a current client to confirm the high level of skills of our members of staff providing the services. Also, to fulfill its compliance obligations, our client may need to check your biography more closely before providing you with access to its protected data and facilities. Therefore, we may ask you to provide more specific information, such as tax number, work permission, citizenship, criminal background, and other additional and specific background checks required by particular clients to provide you with access to clients’ systems and premises.

 

1. Business relations, based on Intellectsoft legitimate interest, art. 6 para. 1 f GDPR:

if you are a representative of our current or potential client, vendor, or business partner, we may process your data to organize the approval, processing, and signing of contracts, acts, invoices, and other contractual documentation; to promote our new products, works, and services; to confirm the high level of our works and services; to invite you to the meetings and events or organize them; to comply with economic sanctions and export control list screening, industry standards, regulators’ requirements and other requirements related to anti-corruption, fraud prevention, and anti-money laundering.

 

1. Corporate and investor relations, based on Just2Pay compliance obligations, art. 6 para. 1 c GDPR:

• if you are a current or potential director or top manager of Just2Pay, we may process your data to organize your participation in corporate meetings, events, and business trips, pay your remuneration, cover related expenses, maintain our corporate records, make obligatory public disclosures and reports, to execute auditor’s requests, to present the company and its management during the sale process and to perform other legal obligations. We also may share this information within Just2Pay, and provide some of this data to banks, notaries, payroll agencies, and legal advisors to open a corporate bank account or other accounts;
• if you are a current or potential affiliate of Just2Pay, we may process your data to organize your participation in corporate meetings and events, provide you with the meetings’ materials and our reports, support you in the execution of your rights, to make obligatory public disclosures and reports, to execute auditor’s requests and to perform other legal obligations, including anti-money laundering requirements and disclosure of beneficiaries.

1. Security, based on Just2Pay’s legitimate interest, art. 6 para. 1 f GDPR:

• if you are a visitor of this website, we may process your data to keep this website secure, prevent fraud, protect the rights and interests of Just2Pay and third parties, and protect Intellectual Property rights;
• if you are a visitor to our office, we may process your data to monitor physical access and to ensure security in our office, as well as to prevent, detect and investigate any crime, misconduct, incident, or accident.

 

HOW CAN WE USE YOUR DATA?

We may process your data by way of collecting, recording, organizing, storing, using, structuring, adapting or altering, retrieving, consulting, aligning or combining, erasing or destructing.

Also, as Just2Pay is an international group of companies, we may disclose your data by transmission, dissemination, or otherwise making it available. To the extent permitted by applicable data protection laws, your data may be transferred between various locations of Just2Pay and thus processed in Africa Economic Area and outside of it, depending on the purpose of processing.

Such transfer and processing are possible only as reasonably necessary for the purposes set out in this Policy and within the scope of the legitimate interest of Just2Pay.

We may disclose your data to some of our clients for business engagement or to confirm the high level of skills of our team members to auditors, agencies, supervisory authorities, or other external service providers on a “need-to-know basis” to perform our contractual obligations.

We may also disclose your data:

• To the extent that we are required to do so by law;
• In connection with any ongoing or prospective legal proceedings;
• To establish, exercise, or defend our legal rights, including providing information to others for fraud prevention and reducing credit risk.

 

HOW CAN YOU CONTROL YOUR DATA?

 

You, as a Data Subject, have the right to:

• Request information about whether we hold personal information about you, and, if so, what that information is and why we are holding or using it.
• Request access to your personal information. This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Object to automated decision-making, including profiling, that is not to be subject to any automated decision-making by us using your personal information or profiling of you.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it.
• Request transfer of your personal information in an electronic and structured form to you or another party. This enables you to take your data from us in an electronically useable format and to be able to transfer your data to another party in an electronically useable format.
• Withdraw consent. You have the right to withdraw your consent to the collection, processing, and transfer of your personal information for a specific purpose at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.

 

If you want to exercise any of these rights, please contact us at info@just2pay.net The request response time is one month.

 

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information or to exercise any of your other rights. This is another security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

 

Please exercise your rights wisely and note that abuse of rights may entail your liability.

 

HOW IS YOUR DATA RETAINED?

We make sure to use appropriate technical and physical security measures to protect your data which is transmitted, stored, or otherwise processed by us, from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access.

Your data is securely stored by Just2Pay on its servers and on the servers of the cloud-based database management services that Just2Pay engages in, such as Workable.

We will not retain your data for longer than it is necessary to fulfill the purpose it is being processed for. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the personal data, the purposes for which we process it, and whether we can achieve those purposes through other means. We must also consider periods for which we might need to retain personal data to meet our legal obligations or to deal with complaints, and queries, and to protect our legal rights in the event of a claim being made. When we no longer need your data, we will securely delete or destroy it.

We will retain information and documents, including electronic documents, containing personal data:

• To the extent that we are required to do so by law
• If the information is relevant to any ongoing or prospective legal proceedings, and
• To establish, exercise, or defend our legal rights, including providing information to others for fraud prevention and reducing credit risk.

WHAT ARE COOKIES AND HOW DO WE USE THEM?

When you visit the Just2Pay websites, Just2Pay may place cookies and similar analytical codes (collectively, “Cookies”) on your device, browser, or the webpage you are viewing, to personalize your experience, understand usage patterns and provide, improve, and secure the Just2Pay websites.

Cookies are simple computer files made of text. Cookies do not typically contain any information that personally identifies someone, but personal data that we store about you may be linked to the information obtained from cookies.

 

Our websites use different types of Cookies for different reasons, as follows:

• Functional cookies - These Cookies are essential to enable you to move around the Just2Pay websites and use their features. These Cookies make sure you can view the websites and properly use them. They also give you access to secured parts of the Just2Pay websites. Examples of functional cookies: SID, PHPSESSID, wp-settings-X, wp-settings-time-X, etc.
• Analytical cookies and other cookies - these Cookies help us improve all our websites, collect anonymous information about how visitors use our websites, collect information about the most visited pages and tell us whether and how many error messages were displayed. Examples of analytical cookies: 1_P JAR, _ga, _gid, etc.
• Third-party cookies - These Cookies help third parties to help track and manage the effectiveness of, for example, their websites, ads, and the number of visitors. More information about these Cookies may be available on the relevant third party’s website. Examples of third-party cookies: cookie, sb, fr, spin, wd, xs, etc.

 

Based on how long they are valid, the Cookies on the Just2Pay websites may be either persistent cookies or session cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. If you want to receive more information about the cookies we use, please contact us.

You can adjust your browser settings to delete some of our cookies or cookies set by third parties. You may also adjust your browser settings to prevent websites from setting cookies or third-party cookies altogether. If you prevent us from setting specific cookies, you may find that some functions are not available or that certain parts of the website will not load. Find out how to adjust the settings for different browsers:

• Chrome
• Firefox
• Internet Explorer
• Safari