Januus Privacy Notice

Preamble

Definitions

Introduction

The Team is committed to:

• Protecting data subjects and their data
• Safeguarding privacy
• Respecting data subjects’ wishes
• Transparency

This notice sets out the use of personal information by the Team, through its systems, procedures and on the Platform. This notice explains our practices so that data subjects can make informed decisions.

The Team uses personal information relating to three key categories of data subjects:

• Website visitors
• Employees, customers, suppliers & partners
• Those whose data has been collected for the Platform

Contact

The data controller is Csyndicate Ltd of International House, 6 South Molton St, London, United Kingdom, W1K 5QF. Csyndicate Ltd is registered as a data controller with the Information Commissioners’ Office. The registration number is ZB287801.

Feel free to contact Januus’s Data Protection Officer with any questions, comments or concerns at [email protected]

Changes to this notice

Any changes to this privacy notice will be posted here. Where this affects the consents needed from data subjects, renewed permission will be sought upon the next website visit.

Information collected & used

Employees, customers, suppliers and partners

The Team collects personal information relating to customers, suppliers, partners and their employees. This information, received from individuals and their companies includes:

• Name, address, contact details
• Job title, company
• Professional social media links if offered
• Order history and payment details
• Records of contact and correspondence
• Applications and CVs

Januus platform

The Platform collates information about individuals and cryptographic wallets, where data subjects’ data is publicly available. The data collected by the Platform will invariably include personal information. It may also include special category personal information.

Purposes & legal bases

Website visitors

The Team uses personal information relating to website visitors for the purposes of business administration, development, and promotion. This is based on the legitimate interests of the business. The Team will not use personal information for the business’s legitimate interests where an individual’s interests and rights override those business interests.

Employees, customers, suppliers & partners

The Team uses personal information relating to customers, suppliers, partners and their employees for the purposes of business administration, development, and promotion. Legal bases for this use vary according to circumstances:

• For individuals under contract, the primary basis is performance of that contract. Without the relevant personal information, it may be impossible to provide the associated services.
• In all cases usage may be based on the legitimate interests of the business or the legitimate interests of a third party such as customers.
• For employees of customers, suppliers and partners, usage may be based on the legitimate interests of the business or the legitimate interests of a third party such as customers.

The Team will not use personal information for the business’s legitimate interests where an individual’s interests and rights override those business interests.

Januus platform

The Platform uses personal information to furnish information services for its customers. This use is based on the following grounds:

• In the case of use of the Platform by a public body or law enforcement agency, for the performance of a task carried out in the public interest or official authority.
• In relation to special category personal information, to establish, exercise or defend legal claims; to prevent or detect unlawful acts; and for reasons of substantial public interest (including notification of breaches and thus limiting the availability of breached data to those with criminal intent).
• For the legitimate interests of the business and customers.

The Team will not use personal information for the business’s legitimate interests where an individual’s interests and rights override those business interests.

Legal obligations

The Team uses personal information when required to do so by law. In such cases, the legal ground is that the use of personal information is necessary to comply with a legal obligation.

Marketing

Where the Team uses personal information to market services and opportunities, this is on the basis of explicit, informed consent. Such consent may be withdrawn at any time.

Data storage and retention

The Team stores personal information within the European Economic Area, the US and the UK. Appropriate security measures are in place, including access control, encryption, and backup.

The Platform reviews its retention of data every four years. Most data is retained indefinitely since it may be used in relation to future criminal proceedings, for which no limitation period applies. Accordingly, the Team takes particular care to protect and secure this data.

Rights

Every person has the following rights:

• The right to know how information is processed – this notice fulfils that right.
• The right to access – the right to request copies of their own personal data.
• The right to rectification –the right to request that the Team correct or complete any information believed to be inaccurate or incomplete.
• The right to data portability –the right to request that the Team provides their data to them or to another organisation.
• The right to complain to the Information Commissioner’s Office regarding the use of personal information.

Every person also has the following rights, but note that these rights may be overridden by other rights and obligations, including those of the Team:

• The right to erasure –the right to request that the Team erases their personal data.
• The right to restrict processing –the right to request that the Team restricts the processing of personal data.
• The right to object to processing – the right to object to the Team’s processing of their personal data.

The team has a month to respond to requests. To exercise any of these rights, please email [email protected]

Other websites

The business’s websites contain links to other websites. This privacy policy applies only to the business’s website. When following links to other websites, refer to that website’s own privacy policy.