This Policy sets out the obligations of Myjoju Limited, a company registered in S.A.R. Hong Kong under company registration number 3031670, whose registered office is at Unit D, 11/F World Trust Tower, 50 Stanley Street, Central, S.A.R. Hong Kong (“the Company”) regarding data privacy and the rights of Staff and Customers (“data subjects”) in respect of their personal data under Data Privacy Law.

“Data Privacy Law” means all legislation and regulations in force from time to time regulating the use of personal data and the privacy of electronic communications including, but not limited to, the retained EU law version of the General Data Privacy Regulation ((EU) 2016/679) (the “UK GDPR”), as it forms part of the law of England and Wales, Scotland, and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018, the Data Privacy Act 2018, the Privacy and Electronic Communications Regulations 2003 as amended, and any successor legislation..

This Policy sets the Company’s obligations regarding the collection, processing, transfer, storage, and disposal of personal data. The procedures and principles set out herein must be followed at all times by the Company, its employees, agents, contractors, or other parties working on behalf of the Company.

“consent” means the consent of the data subject which must be a freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which they, by a statement or by a clear affirmative action, signify their agreement to the processing of personal data relating to them;

“data controller” means the natural or legal person or organisation which, alone or jointly with others, determines the purposes and means of the processing of personal data. For the purposes of this Policy, the Company is the data controller of all personal data relating to Staff and Customers used in our business for our commercial purposes;

“data processor” means a natural or legal person or organisation which processes personal data on behalf of a data controller;

“data subject” means a living, identified, or identifiable natural person about whom the Company holds personal data;

“EEA” means the European Economic Area, consisting of all EU Member States, Iceland, Liechtenstein, and Norway;

“personal data” means any information relating to a data subject who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that data subject;

“personal data breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored, or otherwise processed;

“processing” means any operation or set of operations performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

“pseudonymisation” means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data is not attributed to an identified or identifiable natural person; and

“special category personal data” means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sexual life, sexual orientation, biometric, or genetic data.

“third party systems” means any system, software or API in use that is not created or facilitated by the myjoju organisation. These are the following third party systems in use: AWS, Digital Ocean, OpenAI API.

3.1 The Company is committed not only to the letter of the law, but also to the spirit of the law and places high importance on the correct, lawful, and fair handling of all personal data, respecting the legal rights, privacy, and trust of all individuals with whom it deals.

3.2 The Company’s Data Privacy Officer (“DPO”) is Kristi Sweitzer, Unit D, 11/F World Trust Tower, 50 Stanley Street, Central, S.A.R. Hong Kong. The DPO is responsible for administering this Policy and for developing and implementing any applicable related policies, procedures, and/or guidelines.

3.3 All Managers are responsible for ensuring that all employees, agents, contractors, or other parties working on behalf of the Company comply with this Policy and, where applicable, must implement such practices, processes, controls, and training as are reasonably necessary to ensure such compliance.

3.4 Any questions relating to this Policy or to Data Privacy Law should be referred to the Data Privacy Officer. In particular, the Data Privacy Officer should always be consulted in the following cases:

a) if there is any uncertainty relating to the lawful basis on which personal data is to be collected, held, and/or processed;

b) if consent is being relied upon in order to collect, hold, and/or process personal data;

c) if there is any uncertainty relating to the retention period for any particular type(s) of personal data;

d) if any new or amended privacy notices or similar privacy-related documentation are required;

e) if any assistance is required in dealing with the exercise of a data subject’s rights (including, but not limited to, the handling of subject access requests);

f) if a personal data breach (suspected or actual) has occurred;

g) if there is any uncertainty relating to security measures (whether technical or organisational) required to protect personal data;

h) if personal data is to be shared with third parties (whether such third parties are acting as data controllers or data processors);

i) if personal data is to be transferred outside of the country where the customer resides and there are questions relating to the legal basis on which to do so;

j) when any significant new processing activity is to be carried out, or significant changes are to be made to existing processing activities, which will require a Data Privacy Impact Assessment;

k) when personal data is to be used for purposes different to those for which it was originally collected;

l) if any automated processing, including profiling or automated decision-making, is to be carried out; or

m) if any assistance is required in complying with the law applicable to direct marketing.

This Policy aims to ensure compliance with Data Privacy Law. The UK GDPR sets out the following principles with which any party handling personal data must comply. Data controllers are responsible for, and must be able to demonstrate, such compliance. All personal data must be:

4.1. processed lawfully, fairly, and in a transparent manner in relation to the data subject;

4.2. collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes. Further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;

4.3. adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed;

4.4. accurate and, where necessary, kept up to date. Every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, is erased, or rectified without delay;

4.5. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. Personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, subject to implementation of the appropriate technical and organisational measures required by the UK GDPR in order to safeguard the rights and freedoms of the data subject;

4.6. processed in a manner that ensures appropriate security of the personal data, including Privacy against unauthorised or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organisational measures.

When handling data through Third Party Systems, we prioritise the privacy and security of user information. Data transmitted through a third party API is securely encrypted and treated in accordance with the specific API privacy policies. The third party system provides secure authentication and user management services, ensuring that user data is protected and only accessible to authorised individuals for the purposes outlined in this Data Privacy Policy. The Owners and Creators of "myjoju" take no responsibility or liability for what happens to the data when it's in the Third Party systems, but we will ensure the security of the data being transferred.

The Data Privacy Policy could be subject to change periodically to reflect changes in legal requirements, industry standards, and app functionalities as it develops. Changes to the Data Privacy Policy will be communicated to users through a prominent notice (“push notification”) within the app or via email, providing a summary of the modifications and a link to the updated policy. Users will be encouraged to review the updated Data Privacy Policy to understand how their personal information is collected, used, and protected.

The UK GDPR sets out the following key rights applicable to data subjects:

5.1. the right to be informed;

5.2. the right of access;

5.3. the right to rectification;

5.4. the right to erasure (also known as the ‘right to be forgotten’);

5.5. the right to restrict processing;

5.6. the right to data portability;

5.7. the right to object; and

5.8. rights with respect to automated decision-making and profiling.

6.1. Data Privacy Law seeks to ensure that personal data is processed lawfully, fairly, and transparently, without adversely affecting the rights of the data subject. Specifically, the processing of personal data shall be lawful if at least one of the following applies:

a) the data subject has given consent to the processing of their personal data for one or more specific purposes;

b) the processing is necessary for the performance of a contract to which the data subject is a party, or in order to take steps at the request of the data subject prior to entering into a contract;

c) the processing is necessary for compliance with a legal obligation to which the data controller is subject;

d) the processing is necessary to protect the vital interests of the data subject or of another natural person;

e) the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller; or

f) the processing is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require Privacy of personal data, in particular where the data subject is a child.

6.2. If the personal data in question is special category personal data (also known as “sensitive personal data”), at least one of the following conditions must be met:

a) the data subject has given their explicit consent to the processing of such data for one or more specified purposes (unless the law prohibits them from doing so);

b) the processing is necessary for the purpose of carrying out the obligations and exercising specific rights of the data controller or of the data subject in the field of employment, social security, and social Privacy law (insofar as it is authorised by law or a collective agreement pursuant to law which provides for appropriate safeguards for the fundamental rights and interests of the data subject);

c) the processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent;

d) the data controller is a foundation, association, or other non-profit body with a political, philosophical, religious, or trade union aim, and the processing is carried out in the course of its legitimate activities, provided that the processing relates solely to the members or former members of that body or to persons who have regular contact with it in connection with its purposes and that the personal data is not disclosed outside the body without the consent of the data subjects;

e) the processing relates to personal data which is manifestly made public by the data subject;

f) the processing is necessary for the conduct of legal claims or whenever courts are acting in their judicial capacity;

g) the processing is necessary for substantial public interest reasons, on the basis of law which shall be proportionate to the aim pursued, shall respect the essence of the right to data Privacy, and shall provide for suitable and specific measures to safeguard the fundamental rights and interests of the data subject;

h) the processing is necessary for the purposes of preventative or occupational medicine, for the assessment of the working capacity of an employee, for medical diagnosis, for the provision of health or social care or treatment, or the management of health or social care systems or services on the basis of law or pursuant to a contract with a health professional, subject to the conditions and safeguards referred to in Article 9(3) of the UK GDPR;

i) the processing is necessary for public interest reasons in the area of public health, for example, protecting against serious cross-border threats to health or ensuring high standards of quality and safety of health care and of medicinal products or medical devices, on the basis of law which provides for suitable and specific measures to safeguard the rights and freedoms of the data subject (in particular, professional secrecy); or

j) the processing is necessary for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes in accordance with Article 89(1) of the UK GDPR (as supplemented by section 19 of the Data Privacy Act 2018) based on law which shall be proportionate to the aim pursued, respect the essence of the right to data Privacy, and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject.

If consent is relied upon as the lawful basis for collecting, holding, and/or processing personal data, the following shall apply:

7.1. Consent is a clear indication by the data subject that they agree to the processing of their personal data. Such a clear indication may take the form of a statement or a positive action. Silence, pre-ticked boxes, or inactivity are unlikely to amount to consent.

7.2. Where consent is given in a document which includes other matters, the section dealing with consent must be kept clearly separate from such other matters.

7.3. Data subjects are free to withdraw consent at any time and it must be made easy for them to do so. If a data subject withdraws consent, their request must be honoured promptly.

7.4. If personal data is to be processed for a different purpose that is incompatible with the purpose or purposes for which that personal data was originally collected that was not disclosed to the data subject when they first provided their consent, consent to the new purpose or purposes may need to be obtained from the data subject.

7.5. If special category personal data is processed, the Company shall normally rely on a lawful basis other than explicit consent. If explicit consent is relied upon, the data subject in question must be issued with a suitable privacy notice in order to capture their consent.

7.6. In all cases where consent is relied upon as the lawful basis for collecting, holding, and/or processing personal data, records must be kept of all consents obtained in order to ensure that the Company can demonstrate its compliance with consent requirements.

7.7. We do not knowingly collect personal information from individuals under the age of 18. We will take reasonable measures to enforce this age restriction, including asking for and storing information about the individual's date of birth

8.1. The Company collects and processes the personal data set out in Part 22 of this Policy.

This includes:

a) personal and medical test results data collected directly from data subjects;

8.2. The Company only collects, processes, and holds personal data for the specific purposes set out in Part 22 of this Policy (or for other purposes expressly permitted by Data Privacy Law).

8.3. Data subjects must be kept informed at all times of the purpose or purposes for which the Company uses their personal data. Please refer to Part 15 for more information on keeping data subjects informed.

9.1. The Company will only collect and process personal data for and to the extent necessary for the specific purpose or purposes of which data subjects have been informed (or will be informed) as under Part 8, above, and as set out in Part 22, below.

9.2. Employees, agents, contractors, or other parties working on behalf of the Company may collect personal data only to the extent required for the performance of their job duties and only in accordance with this Policy. Excessive personal data must not be collected.

9.3.. Employees, agents, contractors, or other parties working on behalf of the Company may process personal data only when the performance of their job duties requires it. Personal data held by the Company cannot be processed for any unrelated reasons.

10.1. The Company shall ensure that all personal data collected, processed, and held by it is kept accurate and up-to-date. This includes, but is not limited to, the rectification of personal data at the request of a data subject, as set out in Part 17, below.

10.2. The accuracy of personal data shall be checked when it is collected and at regular intervals thereafter. If any personal data is found to be inaccurate or out-of-date, all reasonable steps will be taken without delay to amend or erase that data, as appropriate.

11.1. The Company shall not keep personal data for any longer than is necessary in light of the purpose or purposes for which that personal data was originally collected, held, and processed.

11.2. When personal data is no longer required or the data subject requests erasure all reasonable steps will be taken to erase or otherwise dispose of it without delay.

11.3. Unless specified otherwise, all personal and sensitive data will be erased after 7 years.

11.4. If a user wishes to delete or access their personal data from our systems, they can submit a deletion request by contacting our support team by visiting the “myjoju” website and going to the “Support” page. We ask our users to include the following information in their request:

● Full name and email address associated with the users account.

● Clear statement expressing the users desire to access or delete their data.

11.5. Upon receiving a valid deletion request, we will take the following actions:

● Verify the identity and ownership of the account associated with the request.

● Review and assess the data to be deleted to ensure compliance with legal obligations.

● Remove and delete all identifiable personal data associated with the account within a reasonable time frame.

● Anonymise or aggregate any non-personal data that may be retained for analytical or statistical purposes.

We will acknowledge receipt of each data deletion request and keep the user informed about the progress. Please note that some residual data may remain in our backups or archives for a limited period. However, this data will not be accessible or used for any purpose other than system restoration.

11.6. We may update this Data Deletion Policy from time to time to reflect changes in our practices or legal requirements. The updated policy will be made available on our website.

12.1.. The Company shall ensure that all personal data collected, held, and processed is kept secure and protected against unauthorised or unlawful processing and against accidental loss, destruction, or damage. Further details of the technical and organisational measures which shall be taken are provided in Parts 25 to 30 of this Policy.

12.2. All technical and organisational measures taken to protect personal data shall be regularly reviewed and evaluated to ensure their ongoing effectiveness and the continued security of personal data.

12.3. Data security must be maintained at all times by protecting the confidentiality, integrity, and availability of all personal data as follows:

a) only those with a genuine need to access and use personal data and who are authorised to do so may access and use it;

b) personal data must be accurate and suitable for the purpose or purposes for which it is collected, held, and processed; and

c) authorised users must always be able to access the personal data as required for the authorised purpose or purposes.

13.1. The Data Privacy Officer is responsible for administering this Policy and for developing and implementing any applicable related policies, procedures, and/or guidelines.

13.2. The Company shall follow a privacy by design approach at all times when collecting, holding, and processing personal data. Data Privacy Impact Assessments shall be conducted if any processing presents a significant risk to the rights and freedoms of data subjects (please refer to Part 14 for further information).

13.3. All employees, agents, contractors, or other parties working on behalf of the Company shall be given access to this Policy, and all other applicable Company policies.

14.1. The Company shall carry out Data Privacy Impact Assessments for any and all new projects and/or new uses of personal data which involve the use of new technologies and where the processing involved is likely to result in a high risk to the rights and freedoms of data subjects.

14.2. The principles of privacy by design should be followed at all times when collecting, holding, and processing personal data. The following factors should be taken into consideration:

a) the nature, scope, context, and purpose or purposes of the collection, holding, and processing;

b) the state of the art of all relevant technical and organisational measures to be taken;

c) the cost of implementing such measures; and

d) the risks posed to data subjects and to the Company, including their likelihood and severity.

14.3. Data Privacy Impact Assessments shall be overseen by the Data Privacy Officer and shall address the following:

a) the type(s) of personal data that will be collected, held, and processed;

b) the purpose(s) for which personal data is to be used;

c) the Company’s objectives;

d) how personal data is to be used;

e) the parties (internal and/or external) who are to be consulted;

f) the necessity and proportionality of the data processing with respect to the purpose(s) for which it is being processed;

g) risks posed to data subjects;

h) risks posed both within and to the Company; and

i) proposed measures to minimise and handle identified risks.

15.1. The Company shall provide the information set out in Part 15.2 to every data subject:

a) where personal data is collected directly from data subjects, those data subjects will be informed of its purpose at the time of collection; and

b) where personal data is obtained from a third party, the relevant data subjects will be informed of its purpose:

1. if the personal data is used to communicate with the data subject, when the first communication is made; or

2. if the personal data is to be transferred to another party, before that transfer is made; or

3. as soon as reasonably possible and in any event not more than one month after the personal data is obtained.

15.2. Data Subjects will have access to this Policy before giving consent in which the following information is provided:

a) details of the Company including, but not limited to, contact details, and the names and contact details of any applicable representatives and its Data Privacy Officer;

b) the purpose(s) for which the personal data is being collected and will be processed (as detailed in Part 22 of this Policy) and the lawful basis justifying that collection and processing;

c) where applicable, the legitimate interests upon which the Company is justifying its collection and processing of the personal data;

d) where the personal data is not obtained directly from the data subject, the categories of personal data collected and processed;

e) details of applicable data retention periods;

f) details of the data subject’s rights under the UK GDPR;

g) details of the data subject’s right to withdraw their consent to the Company’s processing of their personal data at any time;

h) details of the data subject’s right to complain to the Information Commissioner’s Office;

i) where the personal data is not obtained directly from the data subject, details about the source of that personal data;

j) where applicable, details of any legal or contractual requirement or obligation necessitating the collection and processing of the personal data and details of any consequences of failing to provide it; and

k) details of any automated decision-making or profiling that will take place using the personal data, including information on how decisions will be made, the significance of those decisions, and any consequences.

16.1.. Data subjects may make subject access requests (“SARs”) at any time to find out more about the personal data which the Company holds about them, what it is doing with that personal data, and why.

16.2. Employees wishing to make a SAR should do so using a Subject Access Request Form, sending the form to the Company’s DPO Kristi Sweitzer by email kristi@myjoju.com.

16.3. Responses to SARs must normally be made within one month of receipt, however, this may be extended by up to two months if the SAR is complex and/or numerous requests are made. If such additional time is required, the data subject shall be informed.

16.4. All SARs received shall be handled by the Company’s Data Privacy Officer and in accordance with the Company’s Data Subject Access Request Policy & Procedure.

16.5. The Company does not charge a fee for the handling of normal SARs. The Company reserves the right to charge reasonable fees for additional copies of information that has already been supplied to a data subject, and for requests that are manifestly unfounded or excessive, particularly where such requests are repetitive.

17.1. Data subjects have the right to require the Company to rectify any of their personal data that is inaccurate or incomplete.

17.2. The Company shall rectify the personal data in question, and inform the data subject of that rectification, within one month of the data subject informing the Company of the issue. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the data subject shall be informed.

17.3. In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of any rectification that must be made to that personal data.

18.1. Data subjects have the right to request that the Company erases the personal data it holds about them in the following circumstances:

a) it is no longer necessary for the Company to hold that personal data with respect to the purpose(s) for which it was originally collected or processed;

b) the data subject wishes to withdraw their consent to the Company holding and processing their personal data;

c) the data subject objects to the Company holding and processing their personal data (and there is no overriding legitimate interest to allow the Company to continue doing so) (see Part 20 of this Policy for further details concerning the right to object);

d) the personal data has been processed unlawfully;

e) the personal data needs to be erased in order for the Company to comply with a particular legal obligation.

18.2. Unless the Company has reasonable grounds to refuse to erase personal data, all requests for erasure shall be complied with, and the data subject informed of the erasure, within one month of receipt of the data subject’s request. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the data subject shall be informed.

18.3. In the event that any personal data that is to be erased in response to a data subject’s request has been disclosed to third parties, those parties shall be informed of the erasure (unless it is impossible or would require disproportionate effort to do so).

19.1. Data subjects may request that the Company ceases processing the personal data it holds about them. If a data subject makes such a request, the Company shall retain only the amount of personal data concerning that data subject (if any) that is necessary to ensure that the personal data in question is not processed further.

19.2. In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of the applicable restrictions on processing it (unless it is impossible or would require disproportionate effort to do so).

20.1. Data subjects have the right to object to the Company processing their personal data based on legitimate interests, for direct marketing (including profiling).

20.2. Where a data subject objects to the Company processing their personal data based on its legitimate interests, the Company shall cease such processing immediately, unless it can be demonstrated that the Company’s legitimate grounds for such processing override the data subject’s interests, rights, and freedoms, or that the processing is necessary for the conduct of legal claims.

20.3. Where a data subject objects to the Company processing their personal data for direct marketing purposes, the Company shall cease such processing promptly.

20.4. Where a data subject objects to the Company processing their personal data for scientific and/or historical research and statistics purposes, the data subject must, under the UK GDPR, demonstrate grounds relating to his or her particular situation. The Company is not required to comply if the research is necessary for the performance of a task carried out for reasons of public interest.

21.1. The Company is subject to certain rules and regulations when marketing its products and services.

21.2. The prior consent of data subjects is required for electronic direct marketing including email, text messaging, and automated telephone calls subject to the following limited exception:

a) The Company may send marketing text messages or emails to a customer provided that that customer’s contact details have been obtained in the course of a sale, the marketing relates to similar products or services, and the customer in question has been given the opportunity to opt-out of marketing when their details were first collected and in every subsequent communication from the Company.

21.3. The right to object to direct marketing shall be explicitly offered to data subjects in a clear and intelligible manner and must be kept separate from other information in order to preserve its clarity.

21.4. If a data subject objects to direct marketing, their request must be complied with promptly. A limited amount of personal data may be retained in such circumstances to the extent required to ensure that the data subject’s marketing preferences continue to be complied with.

The following personal data is collected, held, and processed by the Company (for details of data retention, please refer to Part 11):

Staff Information:

Names, Addresses, Email Address, Next of Kin Contact Details, Bank details, HR records, Holiday and pay history

This information is required for ensuring our Employees safety and to ensure they are paid.

User Information:

(Personal and Sensitive Personal Data) Name, Email address, Date of birth,

Age, Weight, Height, CKD Level, CKD Targets, Sex, Ethnicity, Nationality, Diet Preference, Allergies, Eating habits and nutrient intake information.

Medical test results based on the users input.

These include:

General health (BMI, Blood pressure, etc.)

CKD markers

Nutrients and vitamins

Cardiovascular markers

Diabetic markers

This information is required for the correct and accurate functioning of the app and to ensure the user receives all features available and their data is correctly processed in a suitable location. Medical test results are only collected directly from the data subject for the purpose of tracking the progression of it’s chronic kidney disease.

The Company shall ensure that the following measures are taken with respect to all communications and other transfers involving personal data:

23.1. All emails containing personal data must be encrypted during transit;

23.2. Personal data may be transmitted over secure networks only; transmission over unsecured networks is not permitted in any circumstances;

The Company shall ensure that the following measures are taken with respect to the storage of personal data:

24.1. All electronic copies of personal data should be stored securely using passwords and data encryption;

24.2. All personal data stored electronically should be backed up daily into a separate system. Data should be able to be restored to any point within the previous seven days. All backups should be encrypted;

24.3. No personal data should be stored on any mobile device (including, but not limited to, laptops, tablets, and smartphones), whether such device belongs to the Company or otherwise without the formal written approval of Kristi Sweitzer, DPO, kristi@myjoju.com and, in the event of such approval, strictly in accordance with all instructions and limitations described at the time the approval is given, and for no longer than is absolutely necessary;

24.4. No personal data should be transferred to any device personally belonging to an employee, agent, contractor, or other party working on behalf of the Company and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of the Company where the party in question has agreed to comply fully with the letter and spirit of this Policy and of the applicable Data Privacy Law (which may include demonstrating to the Company that all suitable technical and organisational measures have been taken);

When any personal data is to be erased or otherwise disposed of for any reason (including where copies have been made and are no longer needed), it should be securely deleted and disposed of. For further information on the deletion and disposal of personal data, please refer to Part 11.

The Company shall ensure that the following measures are taken with respect to the use of personal data:

26.1. Personal data may be accessed formally by an employee, agent, contractor, or other party working on behalf of the the Company if such access is necessary for the purpose of their assigned work at the Company, such as a software engineer, without the need for formal access from Kristi Sweitzer, DPO, kristi@myjoju.com;

26.2. No personal data may be shared informally and if an employee, agent, contractor, or other party working on behalf of the Company requires access to any personal data that they do not already have access to, such access should be formally requested from Kristi Sweitzer, DPO, kristi@myjoju.com;

26.3. No personal data may be transferred to any employee, agent, contractor, or other party, whether such parties are working on behalf of the Company or not, without the authorisation of Kristi Sweitzer, DPO, kristi@myjoju.com;

26.4. Personal data must be handled with care at all times and should not be left unattended or on view to unauthorised employees, agents, contractors, or other parties at any time;

26.5. If personal data is being viewed on a computer screen and the computer in question is to be left unattended for any period of time, the user must lock the computer and screen before leaving it;

26.6. Where personal data held by the Company is used for marketing purposes, it shall be the responsibility of the Marketing Manager or DPO to ensure that the appropriate consent is obtained and that no data subjects have opted out, whether directly or via a third-party service;

The Company shall ensure that the following measures are taken with respect to IT and information security:

27.1. All passwords used to protect personal data shall comply with the guidance given by the NCSC UK (ncsc.gov.uk). All software used by the Company is designed to require such passwords.;

27.2. Passwords may be shared between employees, agents, contractors, or other parties working on behalf of the Company, irrespective of seniority or department via the Company’s chosen password manager. If a password is forgotten, it must be reset using the applicable method. IT staff do not have blanket access to all passwords.

27.3. Multifactor Authentication will be used on systems that store personal or sensitive information when available.

27.4. As our passwords do not expire, if you suspect that any of your passwords have been compromised you should report this immediately and reset the affected password.

27.5. You must not use the same password for work as you do for home.

The Company shall ensure that the following measures are taken with respect to the collection, holding, and processing of personal data:

28.1. All employees, agents, contractors, or other parties working on behalf of the Company shall be made fully aware of both their individual responsibilities and the Company’s responsibilities under UK GDPR and under this Policy, and shall be provided with a copy of this Policy;

28.2. Only employees, agents, contractors, or other parties working on behalf of the Company that need access to, and use of, personal data in order to carry out their assigned duties correctly shall have access to personal data held by the Company (see Part 26.1);

28.3. All sharing of personal data shall comply with the information provided to the relevant data subjects and, if required, the consent of such data subjects shall be obtained prior to the sharing of their personal data;

28.4. All employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be required and encouraged to exercise care, caution, and discretion when discussing work-related matters that relate to personal data, whether in the workplace or otherwise;

28.5. Methods of collecting, holding, and processing personal data shall be regularly evaluated and reviewed;

28.6. All personal data held by the Company shall be reviewed periodically, as set out in Part 11;

28.7. The performance of those employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be regularly evaluated and reviewed;

28.8. All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be bound to do so in accordance with the principles of UK GDPR and this Policy by contract;

28.9. All agents, contractors, or other parties working on behalf of the Company handling personal data must ensure that any and all of their employees who are involved in the processing of personal data are held to the same conditions as those relevant employees of the Company arising out of this Policy and UK GDPR;

28.10. Where any agent, contractor or other party working on behalf of the Company handling personal data fails in their obligations under this Policy that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure;

29.1. All personal data breaches must be reported immediately to the Company’s Data Privacy Officer.

29.2. If an employee, agent, contractor, or other party working on behalf of the Company becomes aware of or suspects that a personal data breach has occurred, they must not attempt to investigate it themselves. Any and all evidence relating to the personal data breach in question should be carefully retained.

29.3. If a personal data breach occurs and that breach is likely to result in a risk to the rights and freedoms of data subjects (e.g. financial loss, breach of confidentiality, discrimination, reputational damage, or other significant social or economic damage), the Data Privacy Officer must ensure that the relevant authorities are informed of the breach without delay, and in any event, within 72 hours after having become aware of it, depending on the location of the data where the breach occurred (e.g. Information Commissioner’s Office in the UK).

29.4. In the event that a personal data breach is likely to result in a high risk (that is, a higher risk than that described under Part 29.3) to the rights and freedoms of data subjects, the Data Privacy Officer must ensure that all affected data subjects are informed of the breach directly and without undue delay.

29.5. Data breach notifications shall include the following information:

29.a. The categories and approximate number of data subjects concerned;

29.b. The categories and approximate number of personal data records concerned;

29.c. The name and contact details of the Company’s data Privacy officer (or other contact point where more information can be obtained);

29.d. The likely consequences of the breach;

29.e. Details of the measures taken, or proposed to be taken, by the Company to address the breach including, where appropriate, measures to mitigate its possible adverse effects.