JUVEN GROUP

Privacy policy

1. Introduction

We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you about how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

2. Important information and who we are
Purpose of this privacy policy

This privacy policy aims to give you information on how we collect and process your personal data through your use of this website. This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements any other notices and privacy policies and is not intended to override them.

Who we are

When we refer to “we” or “us” in this privacy policy, we are referring to the companies that make up the Juven group of companies, being:

Controller

Juven Advisors LLP is the controller in the UK and responsible for your personal data. In Mauritius, each of Juven Holdings Limited and Juven Inc. are controllers and responsible for your personal data.

We have appointed a data protection officer ("DPO") in each of the UK and Mauritius, each of whom is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise any of your legal rights set out in paragraph 10 below, please contact the DPO in the UK or Mauritius (as applicable) using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices in the UK, please contact us by post addressed to the Data Protection Officer at: Juven Advisors LLP of 13A St George Street, London W1S 2FQ, United Kingdom.

If you have any questions about our privacy practices in Mauritius, please contact us by post addressed to the Data Protection Officer at: Juven Inc. of c/o Trident Trust Company (Mauritius) Limited, 5th Floor Barkly Wharf, Le Caudan Waterfront, Port Louis 11307, Mauritius.

You have the right to make a complaint at any time to the Information Commissioner's Office ("ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk) or the Data Protection Office (“DP Office”), the Mauritian supervisory authority for data protection issues(www.dataprotection.govmu.org), as applicable. We would, however, appreciate the chance to deal with your concerns before you approach the ICO or DP Office, so please contact us in the first instance.

Changes to the privacy policy

We regularly review our privacy policy and any changes we make to it in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

3. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you through a form on our website or if you send us an email (where applicable), which we have grouped together as follows:

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

4. How is your personal data collected?

We use different methods to collect data from and about you including through:

5. How we use your personal data

We use information held about you in the following ways:

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your prior consent in the event that we wish to send third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. 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.

Cookies

Our website uses “cookies” to distinguish you from other users of our website. A cookie is a small amount of data sent by our site and stored on your computer’s hard drive that our site can read and which helps us keep track of how you use our site. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. Information on deleting or controlling cookies is available at www.AboutCookies.org. Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our site.

Change of purpose

We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. Disclosures of your personal data

We may share your personal information with any member of our group and with selected third parties, including but not limited to (i)business partners, suppliers and sub-contractors, (ii) advertisers that require the information to serve relevant adverts to you and others, and (iii)analytics and search engine providers that assist us in the optimisation of our site. We may also disclose your personal information if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, to enforce or apply our terms of use and other agreements, or to protect the rights, property, or safety of our clients or others.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

7. International transfers

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”) or the United Kingdom(“UK”). It may also be processed by staff or representatives operating outside the EEA or the UK who provide services to us. Similarly in respect of Mauritius, data that we collect from you may be transferred to and stored at a destination outside of Mauritius. It may also be processed by our staff or representatives operating outside of Mauritius who provide services to us.

By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or Mauritius.

8. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. Data retention
How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

Your legal rights on data processing

You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right at any time by contacting us at Juven Advisors LLP, 13A St George Street, London W1S 2FQ, United Kingdom.

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 could 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 could 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.

10. Your legal rights  

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also 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.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

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