Privacy Policy

1.0 OUR CORE
BELIEFS REGARDING USER PRIVACY AND DATA PROTECTION

  • User privacy and data
    protection are human rights
  • We have a duty of care
    to the people within our data
  • Data is a liability,
    it should only be collected and processed when absolutely necessary
  • We loathe spam as much
    as you do!
  • We will never sell,
    rent or otherwise distribute or make public your personal information

2.0 RELEVANT
LEGISLATION

Along with our business and
internal computer systems, this website is designed to comply with the following
national and international legislation with regards to data protection and user
privacy:

This site’s compliance with
the above legislation, all of which are stringent in nature, means that this
site is likely compliant with the data protection and user privacy legislation
set out by many other countries and territories as well. If you are unsure
about whether this site is compliant with your own country of residences’
specific data protection and user privacy legislation you should contact our
data protection officer (details of whom can be found in section 9.0) for
clarification.

3.0 PERSONAL
INFORMATION THAT THIS WEBSITE COLLECTS AND WHY WE COLLECT IT

This
website collects and uses personal information for the following reasons:

3.1 Site
visitation tracking

Like most websites, this site
uses Google Analytics (GA) to track user interaction. We use this data to
determine the number of people using our site, to better understand how they
find and use our web pages and to see their journey through the website.

Although GA records data such
as your geographical location, device, internet browser and operating system,
none of this information personally identifies you to us. GA also records your
computer’s IP address which could be used to personally identify you but Google
do not grant us access to this. We consider Google to be a third party data
processor (see section 6.0 below).

GA makes use of cookies,
details of which can be found on Google’s developer guides. FYI our website uses
the analytics.js implementation of GA.

Disabling cookies on your
internet browser will stop GA from tracking any part of your visit to pages
within this website.

In addition to Google
Analytics, this website may collect* information (held in the public
domain) attributed to the IP address of the computer or device that is being
used to access it. The information is supplied to us from Whoisvisiting.com. Whoisvisiting.com is a
service offered by Whoisdata Limited. The Whoisvisiting system does not use your IP address to identify
you, the individual, in any way
. No cookies are used by the
Whoisvisiting system.

* The Whoisvisiting system
will only lookup information when a static IP address is being used. Differences between a static and dynamic IP address.

More information about how
Whoisvisiting uses IP addresses
.

3.2 Our blog

Should you choose to add a
comment to any posts that we have published on our blog, the name and e-mail address
you enter with your comment will be saved to this website’s database, along
with your computer’s IP address and the time and date that you submitted the
comment. This information is only used to identify you as a contributor to the
comment section of the respective blog post and is not passed on to any of the
third party data processors detailed below. Only your name will be shown on the
public-facing website although if the supplied e-mail address is linked to a Gravatar account, your Gravatar photo
will also be displayed.

Your comment and its
associated personal data will remain on this site until we see fit to either 1.) remove the comment or 2.) remove the blog post. Should you wish
to have the comment and its associated personal data deleted, please e-mail us
here
 using
the e-mail address that you commented with.

If you are under 16 years of
age you MUST obtain parental
consent before posting a comment on our blog.

NOTE: You should avoid entering personally identifiable information to
the actual comment field of any blog post comments that you submit on this
website.

3.3 Contact
forms and email links

Should you choose to contact us using
the contact form on our website, none of the data that you supply will be
stored by this website or passed to / be processed by any of the third party
data processors defined in section 6.0. Instead the data will be collated into
an e-mail and sent to us over the Simple Mail Transfer Protocol (SMTP). Our SMTP servers are protected by TLS (sometimes known as SSL) meaning that
the e-mail content is encrypted using SHA-2, 256-bit cryptography before being
sent across the internet. The e-mail content is then decrypted by our local
computers and devices.

3.4 Email
newsletter

If you choose to join our
e-mail newsletter, the e-mail address that you submit to us will be forwarded
to MailChimp who provide us with e-mail
marketing services. We consider MailChimp to be a third party data processor
(see section 6.0 below). The e-mail address that you submit will not be stored
within this website’s own database or in any of our internal computer systems.

Your e-mail address will
remain within MailChimp’s database for as long as we continue to use
MailChimp’s services for e-mail marketing or until you specifically request
removal from the list. You can do this by unsubscribing using the unsubscribe
links contained in any e-mail newsletters that we send you or by requesting
removal via e-mail
. When requesting removal via e-mail, please send your e-mail to
us using the e-mail account that is subscribed to the mailing list.

If you are under 16 years of
age you MUST obtain parental consent before joining
our email newsletter.

While your e-mail address
remains within the MailChimp database, you will receive periodic (approximately
once a month) newsletter-style e-mails from us.

4.0 HOW WE
STORE YOUR PERSONAL INFORMATION

As detailed in section 3.2
above, if you submit a comment to a blog post published on this website some
personal information will be stored within this website’s database. This is
currently the only occasion where personal data will be stored on this website.
This data is currently stored in an identifiable fashion; a limitation of the
content management system that this website is built on (WordPress). In the
near future we aim to change the storage of this data to a pseudonymous
fashion meaning that the data would require additional processing using a
separately stored ‘key’ before it could be used to identify an individual.

Pseudonymisation is a recent
requirement of the GDPR which many web application developers are currently
working to fully implement. We are committed to keeping it as a high
priority and will implement it on this website as soon as we are able to.

5.0 ABOUT THIS
WEBSITE’S SERVER

This website is hosted by Tsohost within a secure UK based data centre.

6.0 OUR THIRD
PARTY DATA PROCESSORS

We use a number of third
parties to process personal data on our behalf. These third parties have been
carefully chosen and all of them comply with the legislation set out in section
2.0. All 4 of these third parties are based in the USA and are EU-U.S Privacy Shield compliant.

7.0 DATA
BREACHES

We will report any unlawful data breach of this website’s
database or the database(s) of any of our third party data processors to any
and all relevant persons and authorities within 72 hours of the breach if
it is apparent that personal data stored in an identifiable manner has
been stolen.

8.0 DATA
CONTROLLER

The data controller of this
website is: Javaani Ltd, a company registered in England and Wales with company
number 11805649.

Whose registered office is:
Brookside Wexham Street,
Wexham,
Slough,
Berkshire,
United Kingdom,
SL3 6NX

9.0 DATA
PROTECTION OFFICER

Mr. Gurwinder Pal
Operations Director, Javaani Ltd
E-mail: info@javaani.com

10.0 CHANGES TO
OUR PRIVACY POLICY

This privacy policy may change from time to time inline with
legislation or industry developments. We will not explicitly inform our clients
or website users of these changes. Instead, we recommend that you check this
page occasionally for any policy changes. Specific policy changes and updates
are mentioned in the change log below.

10.1 Change log

25/06/2019

  • Privacy policy
    instigated
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