Privacy Policy

Uniware Systems Ltd, as part of the Jonas Family of Companies (“Jonas,” “we,” “us,” ”our”), are committed to protecting your privacy. There are various ways that you might interact with Jonas, and the information you provide when doing so allows us to improve our services.

This website, our related websites and any mobile site or mobile application that link to this Privacy Policy) (collectively, the “Site”, “Sites”) are owned and operated by Uniware Systems Ltd with its principal places of business at:

84/85 Riverside 3, Sir Thomas Longley Road, Rochester, ME2 4BH, United Kingdom


Our privacy policy explains:

us know if they object to us processing their data for this purpose. All such requests of this type shall be referred to and completed on a confidential basis by the human resources or payroll department. The reference letter will be returned directly to the requesting party and filed as part of the human resources department’s confidential records.

How We Use Information

As a data controller, we will only use your personal information if we have a legal basis for doing so. The purpose for which we use and process your information and the legal basis on which we carry out each type of processing is explained in the table below.

Note that we may process your personal data for more than one lawful ground if the data is used for several purposes. Please Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.



PURPOSE FOR WHICH WE WILL PROCESS THE INFORMATION


TYPE OF DATA


LEGAL BASIS FOR THE PROCESSING


To provide you with information and materials that you request from us.


  1. Identity

  2. Contact


It is in our legitimate interests to respond to your queries and provide any information and materials requested in order to generate and develop business.



PURPOSE FOR WHICH WE WILL PROCESS THE INFORMATION


TYPE OF DATA


LEGAL BASIS FOR THE PROCESSING



To ensure we offer an efficient service, we consider this use to be proportionate and will not be prejudicial or detrimental to you.


To personalise our services and products and the Sites to you.


  1. Identity

  2. Contact

  3. Technical


It is in our legitimate interests to improve the Site in order to enhance your experience on our Site, to facilitate system administration and better our services. We consider this use to be proportionate and will not be prejudicial or detrimental to you.


If you do not wish to receive tailored or personalised information from us based on personal information you have provided us, please contact us as provided in “Contacting Us” above.

To update you on services and products and benefits we offer.


  1. Identity

  2. Contact

  3. Profile

  4. Usage

  5. Marketing and Communications

  6. Technical


It is in our legitimate interests to market our services and products. We consider this use to be proportionate and will not be prejudicial or detrimental to you.


If you would prefer not to receive any direct marketing communications from us, you can opt-out at any time by contacting us as providing in “Contacting Us” above.

For direct marketing sent by email to new contacts (i.e. individuals who we have not previously engaged with), we need your consent to send you unsolicited direct marketing.


To send you information regarding changes to our policies, other terms


  1. Identity

  2. Contact

  3. Technical


It is in our legitimate interests to ensure that any changes to our policies and other terms are communicated to you. We



PURPOSE FOR WHICH WE WILL PROCESS THE INFORMATION


TYPE OF DATA


LEGAL BASIS FOR THE PROCESSING

and conditions and other administrative information.

  1. Usage

  2. Profile

consider this use to be necessary for our legitimate interests and will not be prejudicial or detrimental to you.


To administer our Sites including troubleshooting, data analysis, testing, research, statistical and survey purposes; To improve our Sites to ensure that consent is presented in the most effective manner for you and your computer, mobile device, or other item of hardware through which you access the Sites; and to keep our sites safe and secure.


  1. Identity

  2. Contact

  3. Technical

  4. Usage

  5. Profile


For all these categories, it is in our legitimate interests to continually monitor and improve our services and your experience of the Sites and to ensure network security. We consider this use to be necessary for our legitimate interests and will not be prejudicial or detrimental to you.


To measure or understand the effectiveness of any marketing we provide to you and others, and to deliver relevant marketing to you.


  1. Identity

  2. Contact

  3. Technical

  4. Usage

  5. Profile


It is in our legitimate interests to continually improve our offering and to develop our business. We consider this use to be necessary in order to effectively generate business and will not be prejudicial or detrimental to you.


To enforce the terms and conditions and any contracts entered into with you.



It is in our legitimate interests to enforce our terms and conditions of service. We consider this use to be necessary for our legitimate interests and proportionate.




If you do not wish to provide us with your personal data and processing such data is necessary for the performance of a contract with you and to fulfil our contractual obligations to you, we may not be able to perform our obligations under the contract between us.

Where you provide consent, you can withdraw your consent at any time and free of charge, but without affecting the lawfulness of processing based on consent before its withdrawal. You can update your details or change your privacy preferences by contacting us as provided in “Contacting us” above.

Where we rely on legitimate interests as a lawful basis, we will carry out a balancing test to ensure that your interests, rights, and freedoms do not override our legitimate interests. If you want further information on the balancing test we have carried out, you can request this from us by Contacting us.


Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Third-party marketing

We do not share personal data with any company outside the Jonas group for marketing purposes.


Opting out

You can ask us to stop sending you marketing messages at any time.


Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you in a timely manner and we will explain the legal basis which allows us to do so.


Uniware Systems Ltd as data processor

In certain cases, we also operate as a data processor and we collect and process personal information on behalf of our business customers in the provision of our services and products. In these circumstances, Uniware Systems Ltd is acting as a data processor and our business customers remain the data controller in respect of personal information they provide to us.

Our business customers remain the data [information] controllers with respect to any customer information that they provide to us for our provision of services. To the extent that we are acting as data processor, we, therefore, act in accordance with the instructions of such customers regarding the collection, processing, storage, deletion, and transfer of customer information, as well as other matters such as the provision of access to and rectification of customer. We will only use such personal information for the purposes of providing the services and products for which our business customers have engaged us.

Our business customers are responsible for ensuring that these individuals’ privacy is respected, including communicating to the individuals in their own privacy policies who their personal information is being shared with and processed by.

As a data processor, we may share personal information where instructed by our business customer. Where authorized by the business customer, we may also share personal information with third

party service providers who work for us and who are subject to security and confidentiality obligations.

Where Uniware Systems Ltd is acting as a data processor, we will refer any request from an individual for access to personal information which we hold about them to our customer. We will not respond directly to the request.

We will retain personal information which we process on behalf of our customers for as long as needed to provide services and products to our customers and in accordance with any agreement in place with our customers.


Disclosure Of Your Personal Data To Third Parties

We will not sell, rent, lease, or otherwise share your personal information other than as outlined in this Privacy Policy or without obtaining your consent beforehand.

Internal third parties

We may share your personal information with our group companies, affiliates, subsidiaries, or contractors as necessary to carry out the purposes for which the information was supplied or collected (i.e. to provide the services and products you have requested from us).

External third parties

Personal information will also be shared with our third party service providers and business partners who assist with the running of the Sites and our services and products including [hosting providers , email service providers, insert others]. Our third party service providers and business partners are subject to security and confidentiality obligations and are only permitted to process your personal information for specified purposes and in accordance with our instructions.

We may also post links to third party websites as a service to you. These third party websites are operated by companies that are outside of our control, and your activities at those third party websites will be governed by the policies and practices of those third parties. We encourage you to review the privacy policies of these third parties before disclosing any information, as we are not responsible for the privacy policies of those websites.

In addition, we may disclose information about you when we believe, in good faith, that such use or disclosure is reasonably necessary to:

International Transfers

If you are based in the EU or EEA

We share your personal data within the Jonas Group. This will involve transferring your data outside the European Economic Area (EEA) to Canada the USA, Australia, and New Zealand. Canada and New Zealand have been deemed by the EU as having an adequate level of protection for personal data.

Whenever we transfer your personal data outside the EEA to the countries identified above which have not been deemed by the EU to have an adequate level of protection for personal data, and specifically to the US, we ensure a similar degree of protection is afforded to it by using standard data protection clauses approved by the European Commission (as permitted under Article 46(2)(c)) that are designed to help safeguard your privacy rights.

You can contact us as provided in “Contacting us” above if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.


Security of Your Personal Data

The security of your personal information is important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it.

We use appropriate measures to safeguard personally identifiable information, which measures are appropriate to the type of information maintained and follows applicable laws regarding the safeguarding of any such information under our control. In addition, in some areas of our Sites, we may use encryption technology to enhance information privacy and help prevent loss , misuse, or alteration of the information under our control. We also employ industry-standard measures and processes for detecting and responding to inappropriate attempts to breach our systems.

No method of transmission over the Internet, or method of electronic storage, can be 100% secure. Therefore, we cannot guarantee the absolute security of your information. The Internet by its nature is a public forum, and we encourage you to use caution when disclosing information online. Often, you are in the best situation to protect yourself online. You are responsible for protecting your username and password from third party access, and for selecting passwords that are secure.

If you have any questions about security on our Site, you can contact us as provided in “Contacting us” above.


Data Retention: How Long We Keep Your Personal Data

When you contact us, we may keep a record of your communication to help solve any issues that you might be facing. Your information may be retained for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirement.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.


Your rights

Subject to certain limitations, you have rights under data protection laws in relation to your personal data. These rights include the rights to:

Your Right To Object

Direct marketing

You have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Where we process your information based on our legitimate interests.

You also have the right to object, on grounds relating to your particular situation, at any time to processing of your personal information which is based on our legitimate interests. Where you object on this ground, we shall no longer process your personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms or for the establishment, exercise, or defence of legal claims.


Exercising Your Rights

If you wish to exercise any of the rights set out above, including withdrawing consent, please contact us giving us specific details regarding which right you choose to exercise.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Please direct any questions about your information to the Data Protection Contact identified above.


Use of Cookies, IP Addresses and Aggregate Information

Cookies

In order to improve the Sites, we may use small files commonly known as “cookies”. Cookies are a technology that can be used to help personalize your use of a website. A cookie is a small amount of data which often includes a unique identifier that is sent to your computer or mobile phone (your

“device”) from the Sites and is stored on your device’s browser or hard drive. The cookies we use on

the Sites won’t collect personally identifiable information about you, and we won’t disclose

information stored in cookies that we place on your device to third parties.

To enable us to assess the effectiveness and usefulness of this Site, and to give you the best user experience, we collect and store information such as pages viewed by you, your domain names and similar information. Our Site makes use of anonymous cookies for the purposes of:

at: http://www.linkedin.com/static?key=privacy_policy

Complaints

For the UK: You have the right to make a complaint at any time with a supervisory authority, in particular in the EU (or EEA) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: [0303 123 1113].

If we receive formal written complaints, we will follow up with the person making the complaint. We work with the appropriate regulatory authorities to resolve any complaints that cannot be resolved directly. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Customers in the UK can also make contact by phone on 01634 292840 or by email: David.jones@vestasoftwaregroup.com


Changes to this Policy

We regularly review our compliance with our privacy policy. We also adhere to several self- regulatory frameworks in addition to complying with applicable law.

We may change this privacy policy from time to time. If this privacy policy changes, the revised

privacy policy will be posted at the “Privacy Policy” link on the Site’s home page. In the event that the change is significant or material, we will notify you of such a change by revising the link on the home page to read “Newly Revised Privacy Policy.” Please check the privacy policy frequently. Your

continued use of the Site constitutes acceptance of such changes in the privacy policy, except where further steps are required by applicable law. This privacy policy was last updated on the date set out at the end of the policy.

LAST UPDATED: 9 August 2021