Effective Date: 29/09/2024

1. Introduction

Welcome to Just Verify. Just Verify (“we”, “us”, or “our”) is committed to protecting the privacy and security of your personal information. This Privacy Policy explains how we collect, use, disclose, and protect your information when you use our platform, services, and website (collectively, the “Services”). By using our Services, you agree to the collection and use of information in accordance with this policy.

This Privacy Policy includes provisions specific to various jurisdictions, such as the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA), and other international privacy regulations.

For more details on our services and obligations, please review our Terms of Service.

2. Definitions

• “Personal Information”: Any information that relates to an identified or identifiable individual, including but not limited to name, contact details, professional information, and financial data.

• “Processing”: Any operation performed on personal information, such as collection, recording, organization, storage, alteration, retrieval, use, disclosure, or deletion.

• “Service Providers”: Third-party companies or individuals engaged by Just Verify to perform certain services on our behalf, such as payment processing, cloud storage, or marketing assistance.

• “Data Controller”: The entity that determines the purposes and means of processing personal information.

• “Data Processor”: The entity that processes personal information on behalf of the Data Controller.

• “Data Subject”: An individual whose personal information is being processed.

• “Supervisory Authority”: An independent public authority established by a member state of the European Union to monitor compliance with the GDPR.

• “Sensitive Data”: Personal information that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, health data, or data concerning a person’s sexual orientation.

3. Legal Basis for Processing Personal Information (GDPR Compliance)

If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, we process your personal information based on the following legal grounds:

• Consent: We may process your personal information if you have given us specific consent to use your data for a particular purpose, such as receiving newsletters or marketing communications.

• Contractual Necessity: We process personal information as necessary to fulfill our contracts, such as providing Services to Subscribers or engaging Talent.

• Legitimate Interests: We may process personal information for our legitimate business interests, such as improving our Services, enhancing user experience, and ensuring the security of our platform.

• Legal Obligations: We may process your personal information to comply with legal and regulatory obligations.

4. How We Use Collected Information

We use the collected information for the following purposes:

• To Provide and Improve Our Services: Personalize your experience, process transactions, and manage your account.

• To Communicate With You: Send you updates, newsletters, promotional content, and other information related to our Services.

• To Facilitate Talent Engagement: Evaluate and manage applications, onboard new Talent, and assign projects based on expertise.

• To Ensure Compliance and Security: Monitor for fraudulent activities, ensure compliance with our Terms of Service, and protect the security of our platform and users.

• For Research and Development: Improve our Services by conducting research and analyzing trends, user behavior, and preferences.

• To Analyze User Interactions: Use tools such as Google Analytics to understand how users interact with our platform and identify areas for improvement.

5. Data Sharing and Disclosure

We do not sell or share your personal information with third parties for their marketing purposes. However, we may share your information in the following situations:

• Service Providers: We may share information with third-party service providers who assist us in operating our Services, such as payment processors, cloud hosting providers, and email communication services. These providers are bound by confidentiality agreements and are only permitted to use your information for the purposes specified by Just Verify.

• Business Transfers: In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity as part of the transaction.

• Legal Compliance: We may disclose your information if required to do so by law or in response to valid legal requests, such as subpoenas, court orders, or government investigations.

• With Your Consent: We may share your information for other purposes with your consent.

6. Data Protection Officer (DPO)

Just Verify has appointed a Data Protection Officer (DPO) to oversee our data protection practices and ensure compliance with GDPR and other applicable data privacy regulations. If you have any questions or concerns about this Privacy Policy or our data practices, please contact our DPO at:

Email: contact@justverify.ai

7. California Consumer Privacy Act (CCPA) Compliance

If you are a resident of California, you have the following rights under the California Consumer Privacy Act (CCPA):

• Right to Know: You have the right to request information about the categories and specific pieces of personal information we have collected about you, as well as the purposes for which we collect, use, or share that information.

• Right to Delete: You have the right to request the deletion of your personal information, subject to certain exceptions.

• Right to Opt-Out: You have the right to opt-out of the sale of your personal information. Just Verify does not sell personal information.

• Right to Non-Discrimination: You have the right not to receive discriminatory treatment for exercising your rights under the CCPA.

If you would like to exercise any of these rights, please contact us at contact@justverify.ai.

8. Data Subject Rights Request Procedures

To exercise your rights under applicable data protection laws, such as GDPR or CCPA, please submit a request to contact@justverify.ai with the following information:

• Subject Line: Data Subject Rights Request (full name)

• Your full name, email address, and account information (if applicable).

• A description of your request (e.g., data access, deletion, or correction).

• Proof of identity (e.g., a government-issued ID) to verify your identity.

We will respond to your request within a reasonable timeframe, typically within 30 days. We may require additional information to verify your identity and process your request.

9. International Data Transfers

Your personal information may be transferred to and processed in countries outside of your country of residence, including the United States, where our servers and central database are located. When transferring data internationally, we implement appropriate safeguards, such as Standard Contractual Clauses (SCCs) or other legal mechanisms, to ensure that your personal information is protected in accordance with applicable data protection laws.

10. Cookie Consent Management

We use cookies and similar tracking technologies to enhance your experience on our website. Cookies are small data files stored on your device that help us recognize you and remember your preferences.

10.1 Types of Cookies We Use

• Essential Cookies: Necessary for the basic functionality of our website.

• Performance and Analytics Cookies: Help us analyze how users interact with our site and improve performance. We use tools such as Google Analytics to track and understand user behavior.

• Advertising and Marketing Cookies: Used to show you relevant ads and measure the effectiveness of our marketing campaigns.

10.2 Cookie Consent

For visitors from jurisdictions where cookie consent is required (e.g., the EU), we provide a cookie consent management tool that allows you to manage your cookie preferences. You can modify your cookie settings at any time through this tool or through your browser settings.

11. Policy for Handling Sensitive Data

We may collect sensitive personal data only if you provide such data voluntarily or if it is necessary for providing our Services. Sensitive personal data may include information related to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health data, or data concerning sexual orientation.

When we collect sensitive data, we will include a separate consent mechanism, such as a checkbox on forms, where you can explicitly provide consent for us to process this information. Such data will be handled with additional safeguards and security measures to ensure its confidentiality and integrity.

12. AI Compliance and Scope of Services

Just Verify does not currently develop, deploy, or provide AI systems or models. Our services are focused on advisory, consulting, and think tank activities involving human-to-human collaboration and expertise-sharing. While we engage with AI-related topics, we do so to advise our Subscribers on best practices, compliance, and strategic considerations.

We may partner with third-party AI tool providers or AI system developers to offer Subscribers access to AI tools or systems that they can utilize in conjunction with our advisory services. However, these partnerships will be governed by separate agreements, and we will ensure that any AI tools or systems provided are compliant with applicable laws, including the European Union’s AI Act and other related regulations.

Just Verify may also utilize AI for internal purposes as part of our think tank activities or to optimize our own processes and systems, including verification procedures, data analysis, and research support. Any internal use of AI will be carefully managed to align with our commitment to data privacy, security, and compliance with applicable regulations.

13. Data Breach Notification

In the event of a data breach that may result in a risk to your rights and freedoms, we will notify you and the relevant Supervisory Authority without undue delay and in accordance with applicable data protection laws. We will provide information on the nature of the breach, the likely consequences, and the measures taken or proposed to address it.

14. Privacy Policy Acknowledgment

By using our Services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with the terms outlined herein, please discontinue use of our Services.

15. Accessibility Considerations

We are committed to ensuring that our Privacy Policy is accessible to all users. If you have difficulty accessing any part of this policy or require it in an alternative format, please contact us at contact@justverify.ai, and we will accommodate your needs as best as possible. Alternatively, you can use the Google Translate tool on our website to convert the Privacy Policy into your native language.

16. International Data Protection Compliance

Just Verify strives to comply with all applicable data protection laws globally, including the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA), and other relevant privacy regulations in regions where our services are accessible. If you are located in a jurisdiction with specific data protection laws and would like to exercise your data rights, you can submit a request to contact@justverify.ai.

17. Additional Contact Details for Data Protection Authorities

If you have concerns or complaints regarding your data privacy, you may also contact the relevant Data Protection Authorities in your jurisdiction:

• United Kingdom:
  Information Commissioner’s Office (ICO)
  Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, United Kingdom
  Website: ico.org.uk
  Phone: +44 303 123 1113

• European Union:
  Contact details for Data Protection Authorities in EU member states can be found on the European Data Protection Board (EDPB) website.

• Canada:
  Office of the Privacy Commissioner of Canada
  30 Victoria Street, Gatineau, Quebec K1A 1H3, Canada
  Website: priv.gc.ca
  Phone: +1 800-282-1376

18. Third-Party Links and Services

Our Services may contain links to third-party websites, applications, or services that are not operated or controlled by Just Verify. Please note that this Privacy Policy does not apply to such third-party sites. We encourage you to review the privacy policies of any third-party services you access through our platform to understand how your information may be collected and used.

19. Children’s Privacy

Our Services are not intended for use by individuals under the age of 18. We do not knowingly collect or solicit personal information from minors. If we become aware that we have collected personal information from a minor, we will take steps to delete such information as soon as possible.

20. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. If we make significant changes, we will notify you by email or through our Services. We encourage you to review this Privacy Policy periodically to stay informed about our data practices.

21. Contact Information

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at:

Email: contact@justverify.ai