JTMM Website Privacy Policy
Tianshi GMBH(registered address:Georg-Wilhelm-str.3 10711 Berlin,Germany) is pleased about your visit to our website as well as your interest in our company and our services. We take the protection of your personal data seriously and we want you to feel comfortable visiting our website.
This Website Privacy Policy informs the users of www.jtmm.ru,（Hereinafter referred to as JTMM) and of any subpages of this website (collectively "Website") how we, as controller within the meaning of the General Data Protection Regulation ("GDPR"), collect and process the personal data and other information of such users in connection with their usage of the Website.
1. Name and contact details of the controller
JTMM is cooperated by Tianshi GMBH(registered address:Georg-Wilhelm-str.3 10711 Berlin,Germany) as the controller for the personal data processed via the Website. You may contact Tianshi GMBH(registered address:Georg-Wilhelm-str.3 10711 Berlin,Germany) by email or phone, and the exact contact information you can refer to the document <contact us> at the bottom of the website page.
You may use the Website as an unregistered user without actively providing us with any of your personal data. Our Website collects a range of general data and other information each time a data subject accesses it. The general data and information thus collected are stored in our server's log files. Data collected may include
1. the type and version of the browser used,
2. the accessing system's operating system,
3. the website from which the accessing system reaches our Website (referrers),
4. the subsites accessed by an accessing system,
5. the date and time at which our Website is accessed,
6. the IP address,
7. the accessing system's internet service provider,
8. language,
9. session information (such as download errors and page response times), and
10. any other data and information that may be needed in the event of attacks on our IT system.
This information is needed to
1. display the contents of our Website correctly,
2. optimize the content of our Website, and
3. ensure the long-term operational reliability of our IT systems and website technology.
Therefore, we collect this personal data for statistical purposes (e.g. to determine loading speed of the Website or number of visitors) and to improve both data protection and data security on the Website (e.g. to remedy faults in the operation of our Website or investigate security incidents). The aim is to ensure that the personal data we process enjoys the highest possible protection. The personal data in our server's log files is stored entirely separately from any other personal data of the data subject. These purposes also serve as the basis for our legitimate interest in processing your personal data on the basis of Art. 6(1) lit. f) GDPR. For additional information on the assessment of our legitimate interest, please contact us by email or phone.
We will use this general data or this information to draw conclusions about how you use our website.
Any data collected will be erased once it is no longer needed for its original purpose. Where data is collected to provide access to the Website, erasure will occur as soon as the specific session has come to an end.
For data saved in log files, erasure will occur after a maximum of one month. Anonymized data may be stored for longer. In this case, the user's IP address will either be erased or modified to ensure that it can no longer be linked back to the accessing user.
If the data is needed to prosecute a criminal offense, it will be erased once this process has been completed, and in compliance with any legally mandated storage periods.
There is no legal or contractual requirement to provide this data. However, both the collection of website access data and the storage of data in log files are essential to the normal functioning of the Website.
There may be disadvantages to not providing personal data. For instance, failure to provide this data may result in you not being able to access or use our services (e.g. you may be unable to access the Website). However, failure to provide this data will not result in any adverse legal consequences for you.
We offer you the possibility of registering on our Website to use different services.
When you register on our Website, you need to provide us with, at a minimum, your title, name, password, and email address (used to verify your registration). To verify your email address, we will send you a verification link. You also may be prompted to answer several security questions or select other security access keys or credentials issued to you that may be used to enable access to your account on our Website.
You can optionally add your mobile phone number, gender, birthday, payment details, invoicing and delivery address and hobbies to your account.
The aforementioned personal data will not be transferred to third parties, unless you use the following features:
You can choose to use the social login functionality that enables you to register and login instantly by logging in with your social media account from Facebook or Instagram.
Should you make use of the social login functionality, then be advised that some of the information from your social media account, which may include personal data, may be transferred to your profile on our Website. The first time you register on our Website, you may also be able to decide, with varying degrees of granularity, what data to share with us, depending on the options provided by each social media provider. Details of access and what may be transferred will be viewable during the authorization process.
The table below lists all the fields that will be shared between us and the social media provider if you give us permission and the field is not empty in your profile.
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|
|
|
|
User Id |
Yes |
Yes |
|
First Name |
Yes |
Yes |
|
Last Name |
Yes |
Yes |
|
|
Yes |
|
|
Gender |
Yes |
|
|
Birthday |
Yes |
No |
|
Profile Picture |
Yes |
Yes |
|
Location |
No |
No |
The registration and login functions serve to provide online functions in an area accessible only to registered users. We process such personal data for purposes of account administration, answering your queries or information requests, providing products or services that you buy from the seller and improving our Website according to usage patterns,
Your supplementary account information will help us provide you with personalized product recommendations and a better shopping experience.
The legal basis for the processing of data for registration on our Website and use of our Services is the performance of a contract pursuant to Art. 6(1) lit. b) GDPR.
The legal basis for providing additional data and using the facial recognition or social login features is your explicit consent, Art. 6 (1) lit a) GDPR.
Personal data collected and processed during the registration process to fulfill a contract or to carry out pre-contractual measures will be deleted as soon as it is no longer necessary for the execution of the contract. Even after the termination of the contract, it may be required to store your personal data to comply with contractual or legal obligations (e.g. tax retention obligations).
For security reasons and support requests, the log files for login are stored for a maximum of thirty days and then deleted. We will delete your IP-address at the latest after seven days.
The data you have additionally entered in your account will be deleted concurrently with the deletion of your account.
As a registered user, you may cancel your user account at any time and you may update the personal data stored about you at any time.
The minimum information required for the registration of the account on our Website is contractually required to make the account available.
However, there is no other legal or contractual obligation to provide further data. If optional data is not provided, some functions of the Website might not be available to you (e.g. personalization features). However, a failure to provide this optional data shall not result in adverse legal consequences for you.
JTMM provide all support surrounding product orders, repairs and returns.
Our website contains links to other external websites or videos. This is intended to make our website more user-friendly and enables us to provide relevant information. All external links are marked using a standard symbol, e.g. Clicking on a video link on our website will take you to an external website (e.g. Youtube). Any such videos will play exclusively on the external website and any processing of your personal data will take place on this external website.
External websites are operated independently of our web presence. If we provide links to the websites of other organizations, the processing of personal data by these organizations shall not be covered by this Website Privacy Policy. Linked pages will have their own data protection notices. We advise you to check these carefully when visiting a linked website. If you visit linked websites which are neither operated by us nor under our control, we shall not be liable for the content or use of such websites, or for the data protection provisions implemented by these websites.
You can find us on Facebook, YouTube and Instagram. Our social media accounts help us to provide you with more multimedia-based information. They also enable us to communicate with you and exchange ideas on a range of important issues. Together with the social media providers, we use our social media sites to collect and process personal information on our users. The aim of this Website Privacy Policy is to inform you of the nature of the personal data we collect via our social media sites, and the way in which we process such data.
With respect to our social media accounts, we are joint controllers with the relevant social media platform provider for the collection of your data and its processing on our social media accounts (Art. 26 GDPR). Art. 6 (1) lit. f) GDPR shall serve as the legal basis for this processing, which is necessary for the pursuit of our legitimate interests of engaging in public relations activities, providing you with JTMM-related information and entering into direct communication with you. For any additional processing carried out by these social media platforms, the platform provider shall act as the sole controller under the GDPR.
With regard to our page, which we provide via the social media provider's platform, the provider grants us access to the following categories of data:
· Web analytics data which provides information on the use of our social media sites. The web analytics data visible to us does not permit us to analyze the behavior of individual users. We can only view aggregated data (including data on numbers of visits, likes, followers, country of origin, age group, gender) which provides information on our audience and the manner in which visitors use our social media site. The individual user data used to produce this web analytics data is not transfer to us.
· We can adjust our social media accounts settings to target our account or individual items published on the social media platform to a specific audience. Adjusting general parameters (e.g. age group, language, region and interests) enables us to target our content to specific groups. The data provided to us by the social media platform providers does not enable us to contact or identify individual persons.
· If you contact us directly via the social media platform or interact with us in any other way that involves knowingly transmitting personal data (e.g. by establishing a direct link with our social media site), we shall store and process this personal data in line with the purposes for which you transmitted it.
· We will only process this data for the purpose of providing targeted notifications regarding content on our social media account and in order to better understand and optimize the way in which our social media account is used.
· Following a breach of our netiquette rules, we will store the username of the user in breach and the comments which have been blocked or deleted. These are stored solely for the purpose of serving as evidence in potential legal disputes arising within the permitted time period.
Please see the information below regarding other purposes of processing and the categories of data concerned. This is provided separately for each of the social media platforms used.
The Facebook social media platform is provided by Facebook Inc., 1601 S. California Ave. Palo Alto, CA 94304, USA, and operated within the EU by Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland (jointly referred to as “Facebook”). You will find us on Facebook under Tiens E-Commerce. Our username is @tiensecommerce. Please note that we have accepted Facebook’s Page Insights Controller Addendum.
If you visit our Facebook account, Facebook will collect, store and process your personal data in line with Facebook’s Data Policy. The Facebook Data Policy is available here: http://www.facebook.com/about/privacy.
While we also carry out some data processing, this processing shall not exceed the scope of the limited data sets described above.
Facebook’s ‘EU-US Privacy Shield’ certification https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active and the use of Standard Contractual Clauses serve as a guarantee for compliance with EU data protection provisions, even where data processing occurs in the USA. We will provide an update on the adequacy safeguard as soon as Facebook provides an alternative to the Privacy Shield.
Our YouTube account is provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland ("Google"). You will find us under the username [INSERT USERNAME].
A visit to our YouTube profile will result in Google, as the provider of the service, storing and processing your personal data in line with Google Data Policy. The Data Policy is available here: http://www.google.com/intl/de/policies/privacy.
While we also carry out some data processing, this processing shall not exceed the scope of the limited data sets described above
The processing of your personal data will be performed not only by Google Ireland Limited, but also by Google LLC. in the United States.
Our Instagram account is provided by Facebook Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”). The relevant link used on our website can be identified by the Instagram camera icon. You will find us under the username [INSERT USERNAME].
A visit to our Instagram profile will result in Facebook, as the provider of the service, storing and processing your personal data in line with Facebook’s Data Policy. The Instagram Data Policy is available here. https://help.instagram.com/519522125107875.
While we also carry out some data processing, this processing shall not exceed the scope of the limited data sets described above
The processing of your personal data will be performed not only by Facebook Ireland Limited, but also by Facebook Inc. in the United States. Facebook’s ‘EU-US Privacy Shield’ certification https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active and the use of Standard Contractual Clauses serve as a guarantee for compliance with EU data protection provisions, even where data processing occurs in the USA. We will provide an update on the adequacy safeguard as soon as Facebook provides an alternative to the Privacy Shield.
We have integrated social media plugins ("Plugin") in our Website from social media providers such as Facebook, YouTube and Instagram. Plugins provide an easy way of sharing content with other people via social media providers. The most common way is a Share or Like button.
In order to ensure data protection on our website, we only use these Plugins in conjunction with the so-called "Shariff" solution. This solution prevents the Plugins integrated on our website from transferring data to the respective social media provider immediately upon you visiting the Website.
Only when you activate the respective Plugin by clicking the corresponding button will a direct connection to the provider's server be established. As soon as you activate the Plugin, the respective provider receives the information that you have visited our site, together with your IP address.
When you visit our Websites, the Plugins are deactivated, i.e. no data is transferred to the social media provider. If you want to like our page or visit our fanpage on the social media platform, click on the respective Plugin. Your browser will only establish a direct connection to the social media platform servers once you click on this Plugin. When you visit our social media account, the social media provider will receive a notification that your browser has accessed the relevant page from our web presence, even if you do not have a social media profile or are not currently logged in to the social media platform. This information (including your IP address) will be transferred directly from your browser to the social media platform, where it will be stored.
If you have a social media account on the social media platform and are logged in when you activate the Plugin, the social media provider can associate your visit to our websites with your social media account. If you want to avoid this, please log out of the social media platform before activating the Plugin. A social media provider cannot associate a visit to other websites until you have activated an existing Plugin.
When you activate a Plugin, the social media provider transfers the content that becomes available directly to your browser, which integrates it into our Websites. In this situation, data transfers can also take place that are initiated and controlled by the respective social media provider.
Before you activate the Plugin on our Website we will ask for your consent, Art. 6 (1) lit. a) GDPR. You can revoke this consent at any time with effect for the future. Kindly note that JTMM and the social media provider are joint controllers for embedding the Plugins in our Website and transferring your personal data to the social media platform. All subsequent data processing activities are provided by the social media provider as sole controller, unless you visit our social media account.
Further information provided by Facebook on how to use the corresponding Plugin and the corresponding social media platform is available at: https://developers.facebook.com/docs/plugins/faqs. Further information from Facebook about its data use guidelines can be found at: http://www.facebook.com/about/privacy.
Further information for YouTube provided by Google on the use of this Plugin and the corresponding social media platform can be found at: https://support.google.com/analytics/answer/6209874?hl=en. Further information provided by Google on the use of user data (privacy policy) can be found at: http://www.google.com/intl/de/policies/privacy.
Further information for Instagram (operated by Facebook) on how to use this Plugin and the corresponding social media platform can be found at https://developers.facebook.com/docs/instagram/oembed. Further information from Instagram about the use of user data can be found at: https://help.instagram.com/519522125107875.
You have the ability to submit your own content to our Website (e.g. product reviews, comments). To publish your own content on our Website, you have to register on our Website. If you submit a comment or review on products or services, we process the personal data that you voluntarily enter in the context of the comment or review and establish a link to your customer account.
The interactions on our services serve the purpose of making our website more customer-friendly and provide you with the option to post your experience with the purchased products. The legal basis for the processing of data for publishing content on our Website is the performance of a contract pursuant to Art. 6 (1) lit. b) GDPR. In addition, when publishing your own content, our Terms of Use apply.
The aforementioned personal data will be deleted as soon as it is no longer required for the purpose of its collection. This is the case in the context of the product review and comment function if the respective product or service is no longer available and, at the latest 3 years after submission of your post..
The provision of your personal data is not required by a statutory or contractual obligation, but it helps other users to understand and evaluate our products. If you do not provide the personal data required for the product review or comment function, we will not be able to publish your content.
On our website you will find our contact information (e.g. contact form, telephone number, email address) which you may use to contact us quickly via electronic means and to communicate directly with us. Where you contact us, the following personal data transmitted by you will be processed to facilitate the communication: name, gender (salutation), title, email address, telephone number and your inquiry.
If you call our customer service, we may use your account details to verify your identity. We will process the personal data you tell us regarding your inquiry in our systems.
You can also use our customer service robot to resolve questions and problems. In this case we process your account data. In addition, we pseudonymize and store your interaction to improve the service of the customer service robot.
The processing of the personal data collected via the contact form, e-mail or telephone is used solely to process the inquiry and to communicate with you.
The legal basis for the processing of your personal data within the framework of your contacting us is our legitimate interest based on Art. 6 (1) lit f) GDPR. Our legitimate interest is the communication of our company with you as the inquirer. When you interact with the customer service robot, we process your data on the basis of our legitimate interest pursuant to Art. 6 (1) lit. f) GDPR. Our legitimate interest is the ability to offer you excellent communication with the customer service robot and to further improve this service.
If the inquiry is aimed at the conclusion of a contract or related to an existing contract with us, Art. 6 (1) lit. b) GDPR is the legal basis for the associated data processing.
The data described above will be deleted as soon as it is no longer required for the purpose for which it was collected. We will delete the personal data sent to us via e-mail, the contact form or telephone when the relevant inquiry has been resolved.
There is no legal or contractual requirement to provide personal data. If you fail to provide your data, we will be unable to hold (or continue) our conversation with you.
In order to enable you to quickly find the right product, we process your search requests and save your keywords.
Furthermore, you have the ability to find products by uploading photos. You can also find products on our Website by scanning the barcode of the products with our scan feature. For this purpose we save and process metadata contained in the photos. In particular, this data contains your device information.
You also have the ability to search via Voice Commands. In order to support this feature, we process your voice recordings. Furthermore, we use your voice recordings to improve our natural language processing algorithm.
Your search requests for the purpose of product search are processed on the basis of the performance of a contract or in order to take steps at the request of the data subject prior to entering into a contract pursuant to Art. 6 (1) lit. b) GDPR.
The storage of your search history and keywords is based on our legitimate interest pursuant to Art. 6 (1) lit. f) GDPR to make our website more user-friendly and to improve our search algorithm.
The processing of your images and your voice recordings is based on your consent pursuant to Art. 6 (1) lit. a) GDPR. You have the right to withdraw your consent at any time.
The personal data described above will be deleted as soon as it is no longer required for the purpose for which it was collected. With regard to processing and storing your search history and keywords, we will store them for the duration of the agreement. After termination of the agreement, we will anonymize the data.
Your pictures and voice recordings will only be processed until you withdraw your consent.
Our Website uses cookies. Cookies are text files which are sent to a computer via a web browser and stored. When a website is accessed, a cookie that is placed on a device will send information to the party that has placed the cookie. Cookies are extremely common and used on a number of websites. Many cookies contain a ‘cookie ID’. This is a unique identifier consisting of a string of characters which websites and servers can associate with the browser on which the cookie was stored. This allows websites and servers to distinguish the data subject’s browser from other browsers which store different cookies. It also allows them to recognize and identify a particular browser’s unique cookie ID during the same or subsequent visits.
There are the following types of Cookies (and similar technologies):
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Type of Cookie |
Explanation |
Personal Data Processed by Cookie |
Example |
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Necessary |
These cookies are essential for the operation of our Website. They make it possible for you to browse and use our Website. These cookies also allow our Website to remember the choices you make (such as your username, language or the region you are in) or enable website users to use the shopping cart. |
These Cookies may be needed to ensure the full functionality of our website. For instance, cookies can tell us that you have logged into our website. The information these cookies collect may include personal data that you have disclosed, such as your username.
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PHPSESSID |
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Marketing |
These marketing cookies are used to deliver content that is more relevant to you and your interests. They may be used to deliver targeted advertising or to limit the number of times you see an advertisement. They also help us measure the effectiveness of advertising campaigns on the Website or third party websites. We may use these cookies to remember websites you have visited and we may share this information with other parties, including advertisers. |
These cookies usually track website users via their IP address so may collect some personal data about you. |
Facebook Pixel Demandware Emarsys |
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Plugins |
Plugins create a connection between the server of a website where a Plugin is placed and the server of the social media provider (e.g. Facebook or Twitter) which is embedded on the Website. By doing this, data may be shared between the website and the social media provider. Plugins also use Cookies which are used to present you tailored advertisements and content on the relevant social media platform. |
By using Social Plugins, your personal data (e.g. IP-address and Cookie-ID) will be transferred to and processed by the social media provider. |
Facebook Share Button |
There are other technologies that perform a similar function to cookies. Clear GIFs (also known as Web Beacons) are typically transparent, very small graphic images (usually 1 pixel x 1 pixel) that are placed on a website. These may be included on our services provided via our Website. They typically work in conjunction with cookies to identify our users and track user behavior.
When visiting our Website, we will ask you for your consent to use cookies that require your consent. We also provide the option to customize your cookie settings on our Website. By checking the "Cookies" button, you can choose which cookie you want to activate for our Website and which you want to deactivate.
Furthermore, your web browser may provide you options enabling you to control cookies. For more detailed information about how to disable or administer your cookie settings in your web browser, please refer to the following sites (depending on which browser you are using):
• Safari: http://help.apple.com/safari/mac/8.0/#/sfri11471
• Google Chrome: https://support.google.com/chrome/answer/95647?hl=en
• Internet Explorer: https://support.microsoft.com/de-de/help/17442/windows-internet-explorer-delete-manage-cookies
• Firefox: https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop
You can withdraw your consent to allow for cookies, change your browser settings, and delete the cookies already stored on your computer at any time. Please note that if you delete, or choose not to accept, cookies, you may not be able to utilize the features of the services provided via our Website to their fullest potential.
The following table lists the types of cookies used on our website.
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Name |
Explanation |
Opt out |
|
|
We use the "Share-Button" from Facebook, a service of Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA. The button is recognizable as it features the Facebook logo. When clicking the "Share Button", a connection is established between your web browser and the Facebook servers. Facebook receives and stores data (including your IP address). By doing this, Facebook recognizes which subpage of the Website you visited. The relevant information is transmitted to Facebook in the USA and stored there. If you are logged in to Facebook at the same time, the forwarded data can also be assigned to your Facebook account. Facebook may share information internally, within its group or with third parties. Information collected in the European Economic Area ("EEA") may, for example, be transferred to countries outside the EEA. Facebook claims to use standard contractual clauses approved by the European Commission, takes other actions under EU law, and seeks your approval to legitimize data transfers from the EEA to the US and other countries. Please find an overview of all Facebook-Plugins here: https://developers.facebook.com/docs/plugins/?locale=en_US |
You can control how Facebook uses your data to show you ads as described here: |
Only necessary cookies and performance cookies are necessary to operate the website (e.g. shopping cart) and will be processed on the basis of our legitimate interest pursuant to Art. 6 (1) lit. f) GDPR. Without these cookies, we cannot operate the Website. The legal basis for the processing of your personal data for all other types of cookies is your consent pursuant to Art. 6 (1) lit. a) GDPR.
We process your personal data as part of your application procedure. This includes all data that you make available to us in the course of the application process. We do not plan to process special categories of personal data. If you make such data available to us, our processing will also include this data.
If you would like to be included in the candidate pool, we will store the following personal data in order to consider you in future matching job offers. You have usually submitted this data to us as part of your application: [Please adjust/add to list]
· Your resume;
· your cover letter;
· your period of notice;
· your salary request;
· your motivation to change;
· your desired position;
· whether you are mobile;
· when you were accepted into the candidate pool;
· which departments are suitable for you; and
· Your professional seniority.
We process your personal data to carry out an application procedure. Your personal data will be processed exclusively for this purpose. The legal basis for this data processing is sec. 26 para. 1 German Federal Data Protection Act.
If you give us your consent, we will also process your personal data in order to store your data in a candidate pool. This serves the purpose of being able to consider you in further application procedures and to contact you in case of suitable job offers. This data processing is only carried out on the basis of your express consent in accordance with Art. 6 (1) lit. a) DSGVO.
We delete the personal data you have provided no later than six months after we have rejected your application or you have revoked your consent to be included in the candidate pool.
The provision of your personal data is necessary in order to carry out the application procedure with you or to conclude an employment contract with you. You are not obliged to provide us with personal data. If you do not provide us with the personal data required to carry out the application process, we may not be able to consider you as an applicant in the application process.
Your granting or refusal to grant your consent for data processing regarding the candidate pool has no effect on the chances of success of an application with us.
Where we transfer your personal data to service providers and other third parties, this will be done in compliance with the applicable data protection laws.
JTMM engages a service provider, acting as a processor, in order to provide for IT hosting support. This service provider may have access to your personal data to the extent necessary to provide such services. The servers are located in Frankfurt, Germany.
Furthermore, JTMM may transfer your personal data to a group entity in Singapore (MayaJune E-Commerce PTE.LTD.,10 Anson Road No. 13-15, International Plaza, Singapore(079903)), which acts as a processor for purposes of assisting JTMM with the operation of information systems for the management and analysis of customer relationships and interactions, website maintenance and related general IT support.
These service providers process personal data subject to our instructions and are obliged to adhere to strict contractual terms which limit the processing of personal data. According to these terms, processing of personal data is only permitted where this is necessary to deliver the services which are performed on our behalf or to comply with legal requirements.
By way of entering into appropriate data transfer agreements based on Standard Contractual Clauses (2010/87/EU), which are accessible, or taking other measures to provide an adequate level of data protection, we have established that MayaJune E-Commerce PTE.LTD. provides an adequate level of data protection (Art. 46 (2) GDPR).
JTMM and its data processors transfer personal data to law enforcement agencies, governmental authorities, legal counsel, external consultants, or business partners:
· where required to do so by law,
· where required to do so by court order,
· if we believe that this disclosure is necessary or appropriate in order to prevent physical harm or financial loss, or if the disclosure forms part of an investigation into suspected or actual fraudulent or illegal activities.
In case of a corporate merger and acquisition, personal data will be transferred to the third parties being involved in the merger and acquisition in accordance with applicable law.
When using service providers, third parties and cookies, personal data may be transferred and processed by recipients in countries outside the European Union ("EU"), Iceland, Liechtenstein and Norway (European Economic Area), in particular the US, and Singapore.
We entered into appropriate data transfer agreements based on the Standard Contractual Clauses, which are accessible, or taking other measures to provide an adequate level of data protection, in order to create an appropriate level of protection in accordance with the legal requirements.
For more information, please contact us via email or phone.
15. RIGHTS OF THE DATA SUBJECT
If any of your personal data are subject to processing, this makes you a data subject under the GDPR, meaning you are entitled to assert your ‘rights of the data subject’. You have the following rights vis-à-vis the controller (us) regarding the processing of your personal data:
· Right to withdraw consent for personal data processing (Art. 7 (3) GDPR),
· Right to access (Art. 15 GDPR),
· Right to rectification (Art. 16 GDPR),
· Right to erasure (‘right to be forgotten’) (Art. 17 GDPR),
· Right to restriction of processing (Art. 18 GDPR),
· Right to data portability (Art. 20 GDPR),
· Right to object (Art. 21 GDPR), and
· Right to lodge a complaint with a supervisory authority (Art. 77 GDPR).
15.1 Right to withdraw consent for personal data processing
Where the processing of your personal data is based on your consent, you have the right to withdraw your consent for any future processing at any time. This withdrawal of consent shall not affect the lawfulness of any processing which was performed based on this consent before its withdrawal. The withdrawal of consent process is described in the consent statement itself. Alternatively, you may withdraw your consent by sending an email to us.
15.2 Right to obtain confirmation
You have the right to request confirmation from JTMM as to whether or not any of your personal data are being processed.
You have the right to obtain from the data controller at any time, and without having to make a payment, information about any personal data being held on you, and to be furnished with a copy of any such information. European law also mandates that you have the right to access to the following information:
· the purposes of processing,
· the categories of personal data being processed,
· the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations,
· where possible, the planned duration for which the personal data will be stored, or, if this is not possible, the criteria used to determine that period,
· the existence of a right to request from the controller rectification or erasure of personal data concerning you, or the restriction of processing of such personal data by the controller, or the right to object to such processing,
· the existence of a right to lodge a complaint with a supervisory authority,
· where the personal data are not collected from the data subject, any available information as to their source,
· the existence of automated decision-making, including profiling as per Article 22(1) and (4) of the GDPR and – at least in those cases – meaningful information about the logic involved as well as the significance and the envisaged consequences of such processing on the data subject,
· Whether personal data has been transferred to a third country - where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.
This right to access can be restricted insofar as it is likely to render impossible or seriously impair the achievement of research or statistical purposes and such restrictions are necessary for the fulfillment of these research or statistical purposes.
You have the right to request the prompt rectification of inaccurate personal data concerning you. Furthermore, and taking into account the purposes of the processing, you have the right to have incomplete personal data completed – including by means of a supplementary statement.
15.5 Right to erasure (‘right to be forgotten’)
You have the right to request from JTMM the prompt erasure of any personal data on you, provided one of the following reasons apply, and provided there is no need for the processing of these data:
· The personal data are no longer necessary for the purposes for which they were collected or otherwise processed,
· You withdraw the consent on which the processing was based pursuant to Art. 6 (1) a) GDPR, or Art. 9 (2) GDPR, and where there is no other legal ground for the processing,
· You object to the processing pursuant to Art. 21 (1) GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21 (2) GDPR,
· The personal data have been unlawfully processed,
· The personal data must be erased for compliance with a legal obligation in Union or Member State law to which JTMM is subject,
· The personal data were collected in relation to the offer of information society services referred to in Art. 8 (1) GDPR.
Provided one of the above-mentioned grounds for erasure apply and you wish to arrange for the erasure of personal data stored by JTMM, you may do so at any time by contacting a member of staff of JTMM. The member of staff of JTMM will then ensure that this request for erasure is promptly complied with.
The right to erasure shall not apply where processing is necessary:
· For exercising the right to freedom of expression and information,
· For compliance with a legal obligation which requires processing by Union or Member State law to which JTMM is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in JTMM,
· For reasons of public interest in the area of public health in accordance with Art. 9 (2) lit. h) and i) and Art. 9 (3) GDPR,
· For archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Art. 89 (1) GDPR insofar as the right referred to in paragraph (a) is likely to render impossible or seriously impair the achievement of the objectives of that processing, or
· For the establishment, exercise or defense of legal claims.
15.6 Right to restriction of processing
You have the right to request from JTMM the restriction of processing where one of the following applies:
· The accuracy of the personal data is contested by you, for a period enabling JTMM to verify the accuracy of the personal data
· The processing is unlawful, and you oppose the erasure of the personal data and requests the restriction of their use instead,
· JTMM no longer needs the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defense of legal claims, and
· You have objected to the processing pursuant to Art. 21 (1) GDPR, and verification as to whether the legitimate grounds of JTMM override those of you remains outstanding.
Where processing has been restricted, such personal data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise or defense of legal claims, or for the protections of rights of another natural or legal person, or for reasons of important public interest of the Union or of a Member State.
If the restriction of processing was obtained pursuant to the above, you shall be informed by JTMM before the restriction of processing is lifted.
This right to restriction of processing can be limited insofar as it is likely to render impossible or seriously impair the achievement of research or statistical purposes, and such restrictions are necessary for the fulfillment of these research or statistical purposes.
If you have invoked your right to obtain from JTMM the rectification or erasure of personal data or restriction of processing, the controller shall have an obligation to communicate any rectification or erasure of personal data or restriction of processing to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort.
You also have the right to request that the controller notify you of those recipients.
You have the right to receive personal data which you, as the data subject, provided to JTMM, in a structured, commonly used and machine-readable format. You shall also have the right to transmit those data to another controller without hindrance from JTMM to which the personal data has been made available, provided the processing is based on consent pursuant to Art. 6 (1) lit. a) GDPR or Art. 9 (2) lit. a) GDPR, or on a contract pursuant to Art. 6 (1) lit. b) GDPR, and the processing is carried out by automated means, unless 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 controller.
In exercising your right to data portability pursuant to Art. 20 (1) GDPR, you shall also have the right to have your personal data transferred directly from one controller to another, provided this is technically feasible and does not affect the rights and freedoms of others.
The right to data portability shall not apply to the processing of personal data necessary for the performance of a task carried out in the public interest.
You shall have the right, on grounds relating to your particular situation, to object, at any time, to the processing of your personal data which is based on Art. 6 (1) lit. e) or f) GDPR, including profiling based on those provisions.
In the case of an objection being lodged, we shall no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which overrides your interests, rights and freedoms, or if processing is for the establishment, exercise or defense of legal claims.
A data subject wishing to avail themselves of their right to object may do so at any time by contacting the member of staff of JTMM. In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, you may also exercise your right to object by automated means using technical specifications.
Your right to object can be restricted insofar as it is likely to render impossible or seriously impair the achievement of research or statistical purposes and such restrictions are necessary for the fulfillment of these research or statistical purposes.
You shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning your person or similarly affects you in a significant way, provided the decision:
· is not necessary for the entering into or performance of a contract between yourself and JTMM, or
· is authorized by Union or Member State law to which JTMM is subject, and which also lays down suitable measures to safeguard your rights, freedoms and legitimate interests, or
· is based on your explicit consent.
However, these decisions must not be based on specific categories of personal data as referred to in Art. 9 (1) GDPR, unless Art. 9 (2) lit. a) or g) GDPR applies and suitable measures have been implemented to safeguard your rights, freedoms and legitimate interests.
If the decision
· is necessary for the entering into or performance of a contract between yourself and JTMM, or
· is based on your explicit consent,
JTMM shall implement suitable measures to safeguard your rights and freedoms and legitimate interests. This shall include, at a minimum, the right to obtain human intervention on JTMM's part, to express its point of view and to contest the decision.
Irrespective of any other administrative or judicial remedies, you have the right to complain to a supervisory authority, in particular in the member state of your place of residence, of work, or of the place of the alleged breach if you are of the view that the processing of your personal data by us breaches the GDPR.
Our Website Privacy Policy may be amended from time to time in order to reflect potential changes to our data protection procedures. We shall publish any significant amendments to our Website Privacy Policy in clearly visible form on this website or send them to you via email (if you are an account user). The latest amendment date shall be displayed at the beginning of the Website Privacy Policy.