The protection of personal data, as well as compliance with privacy and data protection laws, is important to Janus Advisory and Consulting Services, a private company duly incorporated in accordance with the laws of United States (“Janus,” “Janus,” “we,” and “us”). This Privacy Policy explains the types of personal information we collect, how we use that information, who we share the information with, and also sets out how we protect that information.

All defined terms used in this Privacy Policy will have the meaning ascribed to them in the Terms of Use. Please read the following carefully to understand our views and practices regarding your personal information and how we will treat it. By continuing to use the Janus Services and Systems (as defined in the Terms of Use), you agree to the practices described in this Privacy Policy. If you do not agree with the practices described in the Privacy Policy, you should not use the Janus Services and Systems.

Who We Are

For the purposes of applicable data protection laws (including the Protection of Personal Information Act 4 of 2013 (POPI) and General Data Protection Regulation (GDPR) and any legislation or regulation which replaces POPI or the GDPR), the data controller (or responsible party), where Janus acts as controller in terms of the applicable law, Janus is situated at 4063, Breakwood Dr, Houston, Texas 77025.

Information Covered by This Privacy Policy

This Privacy Policy covers all personal information collected and used by Janus. In this Privacy Policy, “personal data” or “personal information” means information that (either in isolation or in combination with other information held by us) enables you to be identified as an individual or recognized directly or indirectly. This may include your name, e-mail address, phone number, financial and credit card information, electronic funds transfer details, personal description, physical address, photograph, and technical information for the devices you use to access the Janus Services and Systems. If you contact us for any reason, we may keep a record of that correspondence.

What Information Do We Collect From You

The scope information and it’s use as discussed below does not in any way include information that is provided to the Janus Services and Systems by the customer of which the customer is the data controller. This information is collected pursuant to performing the automated auditing functions of the Janus Services and Systems.

The scope of the information below is strictly limited to the information for which Janus acts as the data controller.

We may collect information from you from the following sources, as set out below.

Information You Give Us

You may give us information by filling in forms on the Janus Services and Systems or by corresponding with us by phone, e-mail, via our chatbot or otherwise. This includes:

• your name, e-mail address and phone number, a password to access the system, financial and credit card information, electronic funds transfer details, personal description, and photograph.
• Details of your organization, position or title, details about the physical location of your operations, and linking of your organization to other related parties.
• Other information you provide when you register to use the Janus Services and Systems, subscribe to our service when you complete surveys that we use for research purposes. However, you do not have to respond to them, participate in discussion boards or other social media functions on the Janus Services and Systems, enter a competition, promotion or survey and when you report a problem with the Janus Services and Systems.

If you contact us for any reason, we may keep a record of that correspondence.

Information We Collect About You

With regard to each of your access of our Janus Services and Systems, we may use cookies and other technologies to collect the following information automatically:

• Technical information including your IP address, your login information, browser type, and version, device identifier, location and time zone setting, browser plug-in types and versions, operating system and platform, page response times and download errors;
• Information about your access (of the Janus Services and Systems), including the websites you visit before and after accessing the Janus Services and Systems and products you viewed and searched for;
• Length of visits to individual pages, page interaction information (such as scrolling, clicks, and mouseovers) and methods used to browse away from the page; and

Information We Receive from Other Sources

We may receive information about you if you use any of the other websites we operate or the other services we provide. In this case, we will have informed you when we collected that data that it may be shared internally and combined with data collected on this Website. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). We may receive information about you from them.

Cookies and Similar Technology

Janus Services and Systems uses cookies and similar technology. A cookie is a small file of letters and numbers that our Janus Services and Systems places on your computer or other equipment that you use to access our Janus Services and Systems. These cookies allow us to distinguish you from other customers on the Janus Services and Systems.

You can read more about cookies and how to recognize them at www.aboutcookies.org.

Cookies perform many functions, such as allowing you to navigate between pages efficiently, remembering your preferences, and generally improving your experience. Cookies can further ensure that the advertising that you see online is more relevant to you and your interests.

Also, our cookies may be session cookies (temporary cookies that identify and track users within our websites, applications or services which are deleted when you close your browser or leave your session in the application or service) or persistent cookies (cookies which enable our websites, applications or services to “remember” who you are and to remember your preferences within our websites, applications or services and which will stay on your computer or device after you close your browser or leave your session in the application or service).

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

How You Can Control Cookies

Your use of the Janus Services and Systems indicates your consent to the cookies described in this Privacy Policy. Should you wish for Janus not to use cookies concerning your personal information, you are required to opt-out of cookies. Your web browser includes an option that allows you to refuse the setting of some or all cookies. However, if you do so, you may not be able to access parts of the Janus Services and Systems. It may make your browsing experience less enjoyable. Unless you have adjusted your browser setting so that it will refuse cookies, the Janus Services and Systems will issue cookies as described above when you access the Janus Services and Systems. If you would like to delete any cookies on your computer, please refer to your browser manufacturer’s instruction by clicking “help” on your browser menu.

How Do We Use Your Personal Information?

Who May Use Your Personal Information?

We may share your personal information among companies within the Janus group of companies (“Janus”), including its subsidiaries and holding companies, in order to enable you to access the Janus services, to provide you with customer support, process your payments, understand your preferences, send you information about products and services that may be of interest to you and conduct other activities described in the Privacy Policy. Such group companies may be located outside the European Economic Area (“EEA”), in which case the section “Where Janus stores your personal information” below will apply.

Our Service Providers

We use other companies, agents, and contractors (Service Providers) to perform services on our behalf or to assist with the provision of the services to you. For example, we may engage Service Providers to provide marketing, advertising communications, infrastructure and IT services to personalize and optimize its service, to process credit transactions or other payment methods, to provide customer service, to collect debts, to analyze and enhance data (including data about users interactions with the Janus service) and to process and administer consumer surveys. In the course of providing such services, these Service Providers may have access to your personal information. However, these Service Providers are contractually bound only to use personal information to perform the services that we hire them to provide. We will always use our best efforts to ensure that all the Service Providers we work with will keep your personal information secure.

Janus Partners, Subject to Your Consent

Janus selected partner organizations that may use your personal information, but only with your consent.

If you have opted in to receive offers from our selected partners by purchasing their products through our store or selecting the option to be contacted for more information, your personal information may be transmitted to the relevant partners so that they may send you their product or service offers by e-mail and/or SMS. Please note that our partners are responsible for their privacy practices.

Third Parties Permitted by Law

In certain circumstances, we may be required to disclose or share your personal information in order to comply with legal or regulatory obligations (for example, we may be required to disclose personal information to the police, judicial or administrative authorities).

We may also disclose your personal information to third parties where disclosure is both legally permissible and necessary to enforce our Terms of Use or other agreements, protect or defend the rights, property, or safety of Janus or the public.

Third Parties Connected with Business Transfers

We may transfer your personal information to third parties in connection with a reorganization, restructuring, merger, acquisition, sale, or transfer of assets, provided that the receiving party agrees to treat your personal information in a manner consistent with this Privacy Policy.

Any personal information held by us and any third party will be treated as confidential. We will not sell your personal information to third parties.

Where Janus Stores Your Personal Information

The personal information that Janus collects from you may be transferred to and stored outside of the United States of America and outside of the EEA. It may also be processed by staff operating outside of the United States of America or the EEA. They work for one of our Service Providers or us. By providing Janus with your personal information, you agree to this transfer, storing, or processing. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with the Privacy Policy and applicable data protection laws, including, where relevant, entering into EU standard contractual clauses (or equivalent measures) with the party outside the EEA receiving the personal information.

Security of Your Personal Information

Your personal information is collected via a secure web server. The communication between you and the webserver is encrypted utilizing Secure Socket Layer technology (SSL). In addition, we have security procedures in place to protect the storage and prevent unauthorized access to your personal information. As a part of our security measures, proof of your identity may be required before we disclose your personal information to you.

All supplied sensitive personal information including but not limited to your personal particulars, credit card, or electronic fund transfer details are transmitted via Secure Socket Layer (SSL) technology and then encrypted into the database of Paygate payment provider. Such information will only be accessible by the authorized personnel of such payment providers with special access rights to such systems, and such individuals are required to keep the information confidential. After a transaction has been concluded on the Janus Services and Systems, your information, such as credit card details and electronic fund transfer details will not be stored on Paygates’ servers.

We will take all steps necessary to ensure that your personal information is treated securely in accordance with this Privacy Policy. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Janus Services and Systems, you are responsible for keeping that password confidential. We ask you not to share that password with anyone.

Third-party websites and apps

Our Janus Services and Systems may contain links to and from third-party websites. Please note that if you follow a link to any of these websites, these websites will have their terms of use and privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

How Long Does Janus Keep Your Personal Information?

Your personal information is stored by us and/or our Service Providers, strictly to the extent necessary for the performance of our obligations and strictly for the time necessary to achieve the purposes for which the information is collected, in accordance with applicable data protection laws. When we no longer need to use your information, we will remove it from our systems and records and/or take steps to properly anonymize it so that you can no longer be identified from it (unless we need to keep your information to comply with legal or regulatory obligations to which it is subject).

Your Rights

You have the right to request details of the personal information that we hold about you, to ask us to stop processing your information where you have previously consented to doing so, to have your personal information corrected or deleted and not to be contacted by us if you do not wish to be.

Your Right to Information Janus Hold About You

You can request access to the information we hold about you by contacting us or using the contact details set out below. Our file of your personal information will usually be made available to you within 30 business days. However, occasionally we may not be able to give you access to the personal information we hold about you (for example, we may not be able to give you access if it would unreasonably affect someone else’s privacy or if giving you access poses a serious threat to someone’s life, health or safety). Please note that we may apply an administrative charge for providing access to your personal information in certain circumstances. Any such charge will be reasonable, and Janus will advise you of the charge and obtain your consent before providing you with access to your personal information. Please note further that if you request a copy of your data using electronic means (such as e-mail), then we may provide a copy of your personal information in electronic form unless you have requested otherwise.

You Have A Right to Have Your Personal Information Corrected or Deleted

If any of the information we hold about you is inaccurate or out of date and you have an account with us, you can sign into that account and update your personal information. If you have problems updating the personal information on your account or if you would like us to delete information, please e-mail your request to Alice@janus-acs.com, and we will consider your request as soon as possible.

Your Right to Object to Us Processing Your Personal Information

You have the right to ask us to stop processing your personal information; even where that processing is necessary for our legitimate interests (for example where the processing is necessary for the commercial objectives we pursue in the course of our business), including the profiling, we undertake to send you a personalized offer, product and recommendations, and similar content.

You also have the right to ask us to stop processing your personal information for direct marketing purposes, including any profiling that we undertake for direct marketing. We will, in any case, only send you marketing communications if you have previously agreed to this, but if you change your mind, you can easily unsubscribe from our marketing communications at any time by following the instructions on the Janus Services and Systems.

Please note that, if you have consented to receive offers from Janus partners, the Janus partners are responsible for taking into account your rights, including your right to opt-out of receiving offers from them. You may, at any time, opt-out of receiving offers from third parties by following the instructions on the Janus Services and Systems. If you have previously opted in, your personal information will cease to be transmitted to Janus partners from the time that your request is processed.

Your Right to Have Your Personal Information Transmitted to Another Organization

Where we hold personal information about you with your consent or for the performance of a contract with you, under certain circumstances, you may have the right to ask us to provide you with the personal information we hold about you in a structured, commonly used and machine-readable format and, where technically feasible, to transmit that personal information to another organization.

Making a Complaint

We would be happy to address any concerns you have directly and as the first port of call. Should you need to escalate your complaint, you have the right to complain about the relevant local data protection authority in the EEA or the United States of America if you believe that we have not complied with the applicable data protection laws.

The local data protection authority will differ depending on the country you are in.

Contacting Us

If you should have any concerns or questions about how we treat your personal information, you wish to ask us to stop processing your personal information, or you would like to request a copy of the personal information we hold about you, please contact us at alice@janus-acs.com or by registered post to 4063, Breakwood Dr, Houston 77025, Texas, United States of America.

Severability

If the Consumer Protection Act regulates this Privacy Policy 68 of 2008 (CPA) or the Electronic Communications and Transactions Act 25 of 2002 (ECTA) POPI,  PCI, California Privacy Law, HIPAA or the GDPR, it is not intended that any provision of this Privacy Policy contravene any provision of the CPA, ECTA, POPI or the GDPR. Therefore, all provisions of this Privacy Policy must be treated as being qualified, to the extent necessary, to ensure that the provisions of the CPA, ECTA POPI, PCI, California Privacy Law, HIPAA and GDPR are complied with.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time in response to changing legal, regulatory, or operational requirements. We will notify you of any such changes (including when such changes will take effect). Your continued use of our service after any such updates take effect will constitute acceptance of those changes. If you do not accept any updates to this Privacy Policy, you should stop using all Janus Services and Systems.

Version 1.1 Last updated 8 May 2020