Januus Privacy Notice
This page describes Januus’ practices regarding the collection, use and disclosure of the information we collect from and about you when you use our Service. We take our obligations regarding your privacy seriously and have made every effort to draft this Privacy Notice in a manner that is clear and easy for you to understand.
Last updated: 21/04/2023
This Privacy Notice (“Notice”) describes how we collect, process, share and safeguard Personal Data we collect from you, or that you provide to us, in connection with the provision of any services through this Website or elsewhere (“Websites”), to provide web-based tools that enable our customers to use data to run their businesses more effectively (“Services”). We gather Personal Data that we collect about investors in an online database, that is made available to users of our Services and to our customers. This Notice also tells you about your rights and choices with respect to your Personal Data, and how you can contact us if you have any questions or concerns. In this Notice, “Personal Data” means any information relating to an identified or identifiable individual. Please read this Notice carefully.
Who we are
In this Privacy Notice, the words ‘we’, ‘our’ and ‘us’ refers to Januus. Our offices are at: 6 South Molton Street, London, London W1K 5QF, England. Unless otherwise stated, for the purposes of this Privacy Notice, we act as the data controller of your Personal Data collected and processed.
Personal Data We Collect
We collect Personal Data about you when you use our Website, Services and we may receive this directly from you or from other sources as described below.
If we hold Personal Data about you, it’s because of one or more of the following:
- You’ve created a free account to use our Services.
- Your personal data has been shared with us from data partners who have direct contact with you already, and where appropriate notice has been given for them to pass your information to us.
- We are collecting personal data from public sources, including the government, social media websites, and other web properties where your data is publicly available.
The types of Personal Data we collect about you includes:
- Email address
- Social media profiles
- Technical device information (such are your IP address or cookies)
Where do we collect your information from?
Personal Data You Provide to Us
- Account Information. If you create an account to use our Services, whether directly or via browser wallet integration, we collect Personal Data to allow you to use our Services via this account. When you sign up, you may provide us with your name, email address, password, wallet address and other account information necessary to create and maintain your account.
- Contact information and other information you choose to provide to Us. You can provide a variety of information during your interactions with us, such as through emails or other communications. When you contact us via a contact form, email, or other means, you provide us with Personal Data, such as your name and contact details, and the content of your communications.
Where applicable, we may indicate whether and why you must provide us with your Personal Data as well as the consequences of failing to do so. For example, it may be necessary for you to disclose certain Personal Data in order for us to provide the Services to you.
Information Collected via Automated Means
- Device and Usage Information: When you access and use the Website(s) and/or Services, we receive and store information about interactions with our Services, such as date/time stamps, usage information and statistics, as well as your device, including your internet protocol (IP) address, browser type, device type, device identifiers, operating system version and type.
Information We Receive from Third Parties
- Publicly Available Information. Our search technology scans the web and records publicly available information from third party websites, such as, social media sites, corporate websites and public records. This information may include your name, email address, phone, location, social profile, wallet address, profile photos, and other information.
- Other Third Parties. We may obtain Personal Data about you from third parties such as people directories, data brokers, corporate information directories and other entities. This information may include name, email, phone, work history, education, location, social profile, skills and other similar information.
How we use your Personal Data
Januus endeavours to be compliant with all the provisions of applicable data privacy and protection laws (e.g. UK / EU General Data Protection Regulation 2018 (as applicable)) as to any Personal Data in its possession.
We only use your Personal Data as described in this section if we have a valid legal ground for the collection and processing. Valid legal grounds (depending upon the applicable law) include:
- Consent. This is the case where you have consented to the use of your Personal Data.
- Contract. We need your Personal Data to provide you with our Services in order to perform our end of our contracts with you, such as to create and secure your account, or to respond to your inquiries.
- Legitimate Interest. We have a legitimate business interest in processing your Personal Data to provide the Services to our Customers in commercialising the data. These Customers include law enforcement, KYC/AML, and other uses. We only rely on legitimate interest as a legal basis when such legitimate interests are not overridden by your interests or your fundamental rights and freedoms and we ensure we comply with any request you make to exercise your rights. Individual Legitimate Interest Assessments (“LIAs”) are performed for all Customers.
- Legal Obligation. We may have a legal obligation to process your Personal Data, for example to comply with tax and accounting obligations, and we may process your Personal Data when necessary to establish, exercise, or defend legal claims. We may also process your Personal Data when necessary to protect your or another individual’s vital interests.
Who We Share Personal Data With
We may disclose Personal Data about you in the following circumstances:
- Customers and Users of the Website. We make available Personal Data such as your email, wallet address, and related data to our Customers in order to provide them with the Services. All such sharing will be covered by an LIA.
- Service Providers. We work with third parties to provide services such as hosting, maintenance, and support. These third parties may have access to or process your Personal Data as part of providing those services to us. For example:
- Cloud service providers who we rely on for data storage, disaster recovery and to perform our obligations to you;
- We use providers of business communication tools.
- Legal. Information about our users, including Personal Data, will be disclosed to law enforcement agencies, regulatory bodies, public authorities or pursuant to the exercise of legal proceedings if we are legally required to do so, or if we believe, in good faith, that such disclosure is necessary to comply with a legal obligation or request, to enforce our terms and conditions, to prevent or resolve security or technical issues, or to protect the rights, property or safety of Januus, our users, a third party, or the public.
- Change of Corporate Ownership. Information about our users, including Personal Data, may be disclosed and otherwise transferred to an acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.
- Aggregated Information. We may use and disclose aggregated or otherwise anonymized information for any purpose, unless we are prohibited from doing so under applicable law.
- Business Partners. We may share Personal Data such as name, email, phone, location, wallet address and related data with our business partners, including for the purposes of sales, marketing, recruiting and other related purposes. All such sharing will be covered by an LIA.
Your Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with the following control over your information:
- Accessing, Deleting and Correcting Your Information. You may contact us as set out in the “Contact Us“ section below to request access to, correct or delete any Personal Data that we have about you. In the case where we are required to delete some or all of your Personal Data, we cannot delete your Personal Data except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
Your Privacy Rights
You may have some of the following rights, as provided under applicable laws and subject to any limitations in such laws:
- Right to Access. the right to obtain access to the Personal Data we hold about you and to request certain information about our processing. More in particular, the right to receive an explanation of (i) why we process your Personal Data, (ii) the categories of Personal Data we have about you, (iii) who we share your Personal Data with, (iv) how long we store your Personal Data and (v) who we received your Personal Data from, if it was not collected from you directly.
- Right to Rectification. the right to correct, update or complete any Personal Data we hold about you that is inaccurate or incomplete. Please note that we may rectify or remove incomplete or inaccurate information, at any time and at our own discretion.
- Right to Erasure. You may request to have your Personal Data anonymized, erased or deleted, as appropriate. In this case, if there is no overriding legitimate interest to continue processing your Personal Data we will erase your data.
- Right to Object to Processing. the right to object to our processing of your Personal Data where we are relying on a legitimate interest.
- Right to Restrict Processing. in certain circumstances to stop us processing your Personal Data other than for storage purposes.
- Right to Portability. the right to receive, in a structured, commonly used and machine-readable format, Personal Data that we hold about you, if we process it on the basis of our contract with you, or with your consent, or to request that we transfer such Personal Data to a third party.
- Right to Withdraw Consent. You may withdraw any consent you previously provided to us regarding the processing of your Personal Data at any time and free of charge. We will apply your preferences going forward. This will not affect the lawfulness of the processing before you withdrew your consent.
- Right to Lodge a Complaint. You may lodge a complaint with a supervisory authority, including in your country of residence, place of work, or where you believe an incident took place.
You may exercise these rights by contacting us as set out in the “Contact Us“ section below. Please note that, prior to any response to the exercise of such rights, we will require you to verify your identity. In addition, we may have valid legal reasons to refuse your request and will inform you if that is the case. Note that applicable laws contain certain exceptions and limitations to each of these rights.
International Data Transfers
If you provide us with your Personal Data when using the Services and you are located within the European Economic Area (EEA), Switzerland or the UK or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your Personal Data outside of those regions to the United States for storage and processing.
If we transfer your Personal Data internationally, we will ensure that relevant safeguards are in place to afford adequate protection for your Personal Data and we will comply with applicable data protection laws, in particular by relying on an UK and/or EU Commission adequacy decision (as applicable), on contractual protections for the transfer of your Personal Data or a derogation if available. For more information about how we transfer Personal Data internationally, please contact us as set out in the “Contact Us“ section below.
Our Services are not directed to children, and we do not knowingly collect Personal Data from children under the age of 18. If you learn that a child has provided us with Personal Data in violation of this Privacy Notice, please contact us as set out in the “Contact Us“ section below.
We have implemented physical, managerial, and technical safeguards that are designed to improve the integrity of Personal Data that we collect, maintain, and otherwise process and to secure it from unauthorised access, use, alteration and disclosure. All information you provide to us is stored on our secure servers behind firewalls.
The safety and security of your information also depends on you. Where we use your wallet address for access to certain parts of our Website, you are responsible for keeping this address confidential.
The transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Website. Any transmission of Personal Data is at your own risk.
We store all Personal Data for as long as necessary to fulfil the purposes set out in this Privacy Notice, or for as long as we are required to do so for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal or regulatory obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it was collected, bearing in mind the requirements applicable to the situation and the need to delete outdated, unused information at the earliest reasonable time.
When deleting Personal Data, we will take measures to render such Personal Data irrecoverable or irreproducible, and the electronic files which contain Personal Data will be permanently deleted.
We take great care to ensure the security and privacy of any Personal Data we hold. In the event of a personal data breach with a likelihood of harm, we will immediately notify all parties whose Personal data was part of the breach.
Third Party Services
The Services may contain features or links to websites and services provided by third parties. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, and governing privacy and security, even if accessed through the Services. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the Service and we encourage you to learn about third parties’ privacy and security policies before providing them with your Personal Data.
Furthermore, we do not control the collection, use and/or sharing of your Personal Data by third parties to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way.
Changes and Updates to this Privacy Notice
We may update this Privacy Notice from time to time to reflect changes in our privacy practices. It is our policy to post any changes we make to this Privacy Notice online. The date the Privacy Notice was last revised is identified at the top of the page. Please monitor our Website and this Privacy Notice periodically to check for any changes.
If you wish to lodge a complaint about how we process your Personal Data, please contact us at [email protected]. We will endeavour to respond to your complaint as soon as possible.
In order to resolve a complaint regarding the Site or to receive further information regarding use of the Site, please contact us at:
Csyndicate Ltd (t/a Januus)
6 South Molton Street, London W1K 5QF, United Kingdom