Privacy Policy
Power2SMS Ltd as part of the Jonas Family of Companies (“Jonas,” “we,” “us,” ”our”) are committed to protecting yourprivacy. There are various ways that you might interact with Jonas, and theinformation you provide when doing so allows us to improve our services.
This website, our related websites and any mobilesite or mobile application that link to this Privacy Policy) (collectively, the“Site”, “Sites”) are owned and operated by Power2SMS Ltd with its principalplace of business at Gladstone House, Hithercroft Road, Wallingford,Oxfordshire OX10 9BT.
Our privacy policy explains:
This Privacy Policy applies to Power2SMS Ltd andits subsidiaries and affiliates and covers our processing activities as a datacontroller.
We do not sell our services to children and theSite is not intended for or directed at children under the age of 13 years. Assuch, our Sites are designed for adult user interaction. We do notintentionally collect personally identifiable information from children underthe age of 13.
We are not required to appoint a formal dataprotection officer under data protection laws. However, we have appointed aData Protection Contact who you can reach out to about any queries you may havein relation to this Privacy Policy. If you are located in the EEA, you cancontact our representative(s) in the EEA about any data protection queries,using the contact details below.
Jonas adheres to Canadian and internationalstatutes and regulations which govern the protection of personal information.In Canada Jonas adheres to the Personal Information and Protection ofElectronic Documents Act (“PIPEDA”). In the United States, Jonas adheres tostatutes of general application and statutes of specific application such asthe Health Insurance Portability and Accountability Act (“HIPPA”) whereapplicable In Australia, Jonas complies with the Privacy Act, 1988, a federalstatute as well as with State and Territory laws pertaining to protection ofpersonal information, including the Health Records Act 2001(VIC) whereapplicable. In New Zealand, Jonas follows the Privacy Act, 1993. In Europe,Jonas adheres to i) until 25 May 2018, EU Directive 95/46/EC, as transposedinto domestic legislation of each Member State; ii) on and from 25 May 2018 theGeneral Data Protection Regulation (EU) 2016/679 ("GDPR"); iii) asand when enacted in the United Kingdom, the Data Protection Act [2018],supplementing and amending the GDPR; iv) EU Directive 2002/58/EC on privacy andelectronic communications, as transposed into domestic legislation of eachMember State; and v) any applicable decisions, guidelines, guidance notes andcodes of practice issued from time to time by courts, supervisory authoritiesand other applicable government authorities; in each case together with alllaws implementing, replacing or supplementing the same.
Contacting Us
If you have any questions about our Privacy Policyor your information, or to exercise any of your rights as described in thisPrivacy Policy or under data protection laws, you can contact us as follows:
In the EEA
Topics
Information we collect
Information you give us
We may collect or record basic personal informationwhich you voluntarily provide through completing forms on our Site, throughelectronic mail you send to us, or through other means of communication betweenyou and us. The categories of personal information you provide mayinclude:
We do not generally seek to collect sensitivepersonal information (e.g. social security or other governmental ID numbers,credit card details and account numbers, racial or ethnic origin, politicalopinions, religious or philosophical beliefs, trade-union membership; health orsex life, sexual orientation; genetic or biometric information) through ourSite and if we do we will ask for your explicit consent to our proposed use ofthat information at the time of collection. This information will be collected,stored, accessed and processed in a secure manner.
Information we collect from you
We collect, store and use information about yourvisits to the Sites and about your computer, tablet, mobile or other devicethrough which you access the Sites. This includes the following information:
Collection and Use of Employee Personal Information
We also collect personal information from ouremployees and from job applicants (human resource data) in connection withadministration of our human resources programs and functions. These programsand functions include, but are not limited to: job applications and hiringprograms, compensation and benefit programs, performance appraisals, training,access to our facilities and computer networks, employee profiles, employeedirectories, human resource recordkeeping, and other employment relatedpurposes. It is our policy to keep all past and present employee informationprivate from disclosure to third parties. There are certain business relatedexceptions and they are:
Prospective employers, government agencies,financial institutions, and residential property managers routinely contact usrequesting information on a former or current employee’s work history andsalary. All such requests of this type shall be referred to and completed on aconfidential basis by the human resources department or payroll department. Forwritten verification of employment requests, information will be provided onthe form only when it is accompanied by an employee’s signed authorization to releaseinformation. The form will be returned directly to the requesting party andfiled as part of the human resources or payroll department’s confidentialrecords.
How We Use Information
As a data controller, we will only use yourpersonal information if we have a legal basis for doing so. The purpose forwhich we use and process your information and the legal basis on which we carryout each type of processing is explained in the table below.
Note that we may process your personal data formore than one lawful ground if the data is used for several purposes. PleaseContact us if you need details about the specific legal ground we are relyingon to process your personal data where more than one ground has been set out inthe table below.
Purposes 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.
(a) Identity
(b) 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. 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.
(a) Identity
(b) Contact
(c) 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.
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) 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 and conditions and other administrative information.
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
It is in our legitimate interests to ensure that any changes to our policies and other terms are communicated to you. We 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.
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) 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.
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) 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 personaldata and processing such data is necessary for the performance of a contractwith you and to fulfil our contractual obligations to you, we may not be ableto perform our obligations under the contract between us.
Where you provide consent, you can withdraw yourconsent at any time and free of charge, but without affecting the lawfulness ofprocessing based on consent before its withdrawal. You can update your detailsor change your privacy preferences by contacting us as provided in “Contactingus” above.
Where we rely on legitimate interests as a lawfulbasis, we will carry out a balancing test to ensure that your interests, rightsand freedoms do not override our legitimate interests. If you want furtherinformation on the balancing test we have carried out, you can request thisfrom us by Contacting us.
Marketing
We strive to provide you with choices regardingcertain personal data uses, particularly around marketing and advertising.
Third-party marketing - We do not share personal data with any companyoutside the Jonas group for marketing purpose.
Opting out
You can ask us to stop sending you marketingmessages at any time following the opt-out links on any marketing message sentto you or by Contacting us at any time on 01733796323
Change of purpose
We will only use your personal information for thepurposes for which we collected it, unless we reasonably consider that we needto use it for another reason and that reason is compatible with the originalpurpose. 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 whichallows us to do so.
Power2SMS Ltd as data processor
In certain cases, we also operate as a dataprocessor and we collect and process personal information on behalf of ourbusiness customers in the provision of our services and products. In thesecircumstances, Power2SMS Ltd is acting as a data processor and our businesscustomers remain the data controller in respect of personal information theyprovide to us.
Our business customers remain the data[information] controllers with respect to any customer information that theyprovide to us for our provision of services. To the extent that we are actingas data processor, we therefore act in accordance with the instructions of suchcustomers regarding the collection, processing, storage, deletion and transferof customer information, as well as other matters such as the provision ofaccess to and rectification of customer. We will only use such personalinformation for the purposes of providing the services and products for whichour business customers have engaged us.
Our business customers are responsible for ensuringthat these individuals’ privacy is respected, including communicating to theindividuals in their own privacy policies who their personal information isbeing shared with and processed by.
As a data processor, we may share personalinformation where instructed by our business customer. Where authorized by thebusiness customer, we may also share personal information with third partyservice providers who work for us and who are subject to security andconfidentiality obligations.
Where Power2SMS Ltd is acting as a data processor,we will refer any request from an individual for access to personal informationwhich we hold about them to our customer. Wewill not respond directly to therequest.
We will retain personal information which weprocess on behalf of our customers for as long as needed to provide servicesand products to our customers and in accordance with any agreement in placewith our customers.
Disclosure Of Your Personal DataTo Third Parties
We will not sell, rent, lease or otherwise shareyour personal information other than as outlined in this Privacy Policy orwithout obtaining your consent beforehand.
Internal third parties
We may share your personal information with ourgroup companies, affiliates, subsidiaries or contractors as necessary to carryout the purposes for which the information was supplied or collected (i.e. toprovide the services and products you have requested from us).
External third parties
Personal information will also be shared with ourthird party service providers and business partners who assist with the runningof the Sites and our services and products including hosting providers, emailservice providers. Our third party service providers and business partners aresubject to security and confidentiality obligations and are only permitted toprocess your personal information for specified purposes and in accordance withour instructions.
We may also post links to third party websites as aservice to you. These third party websites are operated by companies that areoutside of our control, and your activities at those third party websites willbe governed by the policies and practices of those third parties. We encourageyou to review the privacy policies of these third parties before disclosing anyinformation, as we are not responsible for the privacy policies of thosewebsites.
In addition, we may disclose information about youwhen we believe, in good faith, that such use or disclosure is reasonablynecessary 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 havebeen deemed by the EU as having an adequate level of protection for personaldata.
Many of our external third party service providersand business partners are based outside the European Economic Area (EEA) sotheir processing of your personal data will involve a transfer of data outsidethe EEA.
Whenever we transfer your personal data outside theEEA to the countries identified above which have not been deemed by the EU tohave an adequate level of protection for personal data, and specifically to theUS, we ensure a similar degree of protection is afforded to it by usingstandard data protection clauses approved by the European Commission (aspermitted under Article 46(2)(c)) that are designed to help safeguard yourprivacy rights.
You can contact us as provided in “Contacting us”above if you want further information on the specific mechanism used by us whentransferring your personal data out of the EEA.
Security of Your Personal Data
The security of your personal information isimportant to us. We follow generally accepted industry standards to protect thepersonal information submitted to us, both during transmission and once wereceive it.
We use appropriate measures to safeguard personallyidentifiable information, which measures are appropriate to the type ofinformation maintained, and follows applicable laws regarding the safeguardingof any such information under our control. In addition, in some areas of ourSites, we may use encryption technology to enhance information privacy and helpprevent loss, misuse, or alteration of the information under our control. Wealso employ industry-standard measures and processes for detecting and respondingto 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 ofyour information. The Internet by its nature is a public forum, and weencourage you to use caution when disclosing information online. Often, you arein the best situation to protect yourself online. You are responsible forprotecting your username and password from third party access, and for selectingpasswords that are secure.
If you have any questions about security on ourSite, you can contact us as provided in “Contacting us” above.
Data Retention: How Long We KeepYour Personal Data
When you contact us, we may keep a record of yourcommunication to help solve any issues that you might be facing. Yourinformation may be retained for as long as necessary to fulfil the purposes wecollected it for, including for the purposes of satisfying any legal,accounting, or reporting requirement.
To determine the appropriate retention period forpersonal data, we consider the amount, nature, and sensitivity of the personaldata, the potential risk of harm from unauthorised use or disclosure of yourpersonal data, the purposes for which we process your personal data and whetherwe can achieve those purposes through other means, and the applicable legalrequirements.
Details of retention periods for different aspectsof your personal data are available in our retention policy which you canrequest from us by contacting us.
Your rights
Subject to certain limitations, you have rightsunder data protection laws in relation to your personal data. These rightsinclude the rights to:
Your Right To Object
Direct marketing
You have the right to object where we areprocessing your personal data for direct marketing purposes. In some cases, wemay demonstrate that we have compelling legitimate grounds to process yourinformation which override your rights and freedoms.
Where we process your information based on ourlegitimate interests.
You also have the right to object, on groundsrelating to your particular situation, at any time to processing of yourpersonal information which is based on our legitimate interests. Where youobject on this ground, we shall no longer process your personal informationunless we can demonstrate compelling legitimate grounds for the processingwhich 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 outabove, including withdrawing consent, please contact us giving us specificdetails regarding which right you choose to exercise.
No fee usually required
You will not have to pay a fee to access yourpersonal data (or to exercise any of the other rights). However, we may chargea reasonable fee if your request is clearly unfounded, repetitive or excessive.Alternatively, we may refuse to comply with your request in thesecircumstances.
What we may need from you
We may need to request specific information fromyou to help us confirm your identity and ensure your right to access yourpersonal data (or to exercise any of your other rights). This is a securitymeasure to ensure that personal data is not disclosed to any person who has noright to receive it. We may also contact you to ask you for further informationin relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests withinone month. Occasionally it may take us longer than a month if your request isparticularly complex or you have made a number of requests. In this case, wewill notify you and keep you updated.
Please direct any questions about your informationto the Data Protection Contact identified above.
Use of Cookies, IP Addresses andAggregate Information
Cookies
In order to improve the Sites, we may use smallfiles commonly known as “cookies”. Cookies are a technology that can be used tohelp personalize your use of a website. A cookie is a small amount ofdata which often includes a unique identifier that is sent to your computer ormobile phone (your “device”) from the Sites and is stored on your device’sbrowser or hard drive. The cookies we use on the Sites won't collect personallyidentifiable information about you and we won't disclose information stored in cookiesthat we place on your device to third parties.
To enable us to assess the effectiveness andusefulness of this Site, and to give you the best user experience, we collectand store information such as pages viewed by you, your domain names andsimilar information. Our Site makes use of anonymous cookies for the purposesof:
By continuing to browse the Sites, you are agreeingto our use of cookies.
If you don't want us to use cookies when you usethe Sites, you can set your browser to notify you when you receive a cookie,giving you the chance to decide whether to accept it or decline at any time.However, if you block cookies some of the features on the Sites may notfunction as a result.
You can find more information about how to domanage cookies for all the commonly used internet browsers by visiting www.allaboutcookies.org. This website willalso explain how you can delete cookies which are already stored on yourdevice.
We currently set the following cookies:
Cookies from third parties
We currently use the following third partycookies:
Third Party Cookies
Purpose
Link
Google Analytics
These cookies provide us with a visitor count and an understanding of how visitors move around and use the Sites. We can then use this information to improve navigability and the Sites generally - please see further details below]
Hubspot
These cookies are used to collect information about how visitors use our Sites and help us identify visitors when they return to our Sites. We use the information gathered by these cookies to help us improve our website functionality and content.
[For use where Google Analytics used only] [We onlyuse "Google Analytics" on the Sites. This cookie provides us with avisitor count and an understanding of how visitors move around and use theSites. We can then use this information to improve navigability and the Sitesgenerally. The cookies we use on the Sites won’t collect personallyidentifiable information about you and we won’t disclose information stored incookies that we place on your device to third parties.]
[We are obliged by Google Analytics to state thefollowing:]
[The Sites use Google Analytics, a web analyticsservice provided by Google Inc. ("Google"). Google Analyticsuses "cookies", which are text files placed on your computer, to helpthe Sites analyse how users use the Sites. The information generated by thecookie about your use of the Sites (including your IP address) will be transmittedto and stored by Google on servers in the United States. Google will usethis information for the purpose of evaluating your use of the Sites, compilingreports on website activity for website operators and providing other servicesrelating to website activity and internet usage. Google may also transferthis information to third parties where required to do so by law, or where suchthird parties process the information on Google's behalf. Google will notassociate your IP address with any other data held by Google. You mayrefuse the use of cookies by selecting the appropriate settings on yourbrowser, however please note that if you do this you may not be able to use thefull functionality of the Sites. By using the Sites, you consent to theprocessing of data about you by Google in the manner and for the purposes setout above.]
IP Addresses and Aggregate Information
An Internet Protocol (“IP”) address is associatedwith your computer’s connection to the internet. We may use your IP address tohelp diagnose problems with our server, to administer the Site and to maintaincontact with you as you navigate through the Site. Your computer’s IP addressalso may be used to provide you with information based upon your navigationthrough the Site.
Aggregate information is used to measure the visitors’ interest in, and use of,various areas of the Site and the various programs that we administer. We willrely upon aggregate information, which is information that does not identifyyou, such as statistical and navigational information. With this aggregateinformation, we may undertake statistical and other summary analyses of thevisitors’ behaviours and characteristics. Although we may share this aggregateinformation with third parties, none of this information will allow anyone toidentify you, or to determine anything else personal about you.
Links
The Sites may, from time to time, contain links toand from the websites of our business partners, advertisers and affiliates. Ifyou follow a link to any of these websites, please note that these websiteshave their own privacy policies and do not accept any responsibility orliability for these policies. Please check these policies before you submit anypersonal information to these websites.
Social Media and OnlineEngagement
We occasionally use a variety of new technologiesand social media options to communicate and interact with customers, potentialcustomers, employees and potential employees. These sites and applicationsinclude popular social networking and media sites, open source softwarecommunities and more. To better engage the public in ongoing dialog, certain ofour businesses use certain third-party platforms including, but not limited to,Facebook, Twitter and LinkedIn. Third-Party Websites and Applications (TPWA)are Web-based technologies that are not exclusively operated or controlled byus. When interacting on those websites, you may reveal certain personalinformation to us or to third parties. Other than when used by our employeesfor the purpose of responding to a specific message or request, we will notuse, share, or retain your personal information.
Complaints
For the UK: You have the right to make a complaintat 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 dataprotection laws occurred. The supervisory authority in the UK is theInformation Commissioner who may be contacted at https://ico.org.uk/concerns/or telephone: [0303 123 1113].
If we receive formal written complaints, we willfollow up with the person making the complaint. We work with the appropriateregulatory authorities to resolve any complaints that cannot be resolveddirectly. We would, however, appreciate the chance to deal with your concernsbefore you approach the ICO so please contact us in the first instance.
Changes to this Policy
We regularly review our compliance with our privacypolicy. We also adhere to several self-regulatory frameworks in addition tocomplying with applicable law.
We may change this privacy policy from time totime. If this privacy policy changes, the revised privacy policy will be postedat the “Privacy Policy” link on the Site’s home page. In the event that thechange is significant or material, we will notify you of such a change byrevising the link on the home page to read “Newly Revised Privacy Policy.”Please check the privacy policy frequently. Your continued use of the Siteconstitutes acceptance of such changes in the privacy policy, except wherefurther steps are required by applicable law. This privacy policy was lastupdated on the date set out at the end of the policy.
LAST UPDATED: 28 September 2020
