PRIVACY NOTICE

Last Updated: February 1, 2020

JuJu Immersive Limited ("we") are committed to protecting and respecting your privacy.

This Privacy Notice tells you how we use personal information collected from you when you access and use our website at https://jujusuite.com (the "Website") and JuJu Suite software, including related iOS, macOS and Windows applications (collectively, "JuJu Suite").

We are acting a data controller regarding personal data we collected from you or you provided us with.

Please note that we are not a data controller with respect to data that was uploaded to JuJu Suite by its users. In such a case we are acting as a data processor, i.e. the one who processes personal data upon controller’s instructions. However, if you believe that we are processing your personal data, you may still send us an enquiry.

References to "you" and "your" means each natural or legal person who interacts with us, uses our website or the products and services we provide.

WHO ARE WE?

We are a unified sales platform for the real estate market called "JuJu Suite".

Our contact details are:

JuJu Immersive Limited
Company number 10795313
197-213 Oxford Street, London, United Kingdom, W1D 2LF
Email address: support@jujusuite.com.

We are not required to have a Data Protection Officer (DPO), therefore any enquiries about the use of your personal data and this Privacy Notice can be addressed to us through the contact details above.

WHEN DO WE COLLECT YOUR PERSONAL DATA?

We collect and process your personal data when you interact with JuJu Suite, for example when you:

(1)

register for an account with JuJu Suite;

(2)

use the JuJu Suite website or apps;

(3)

correspond with us via SMS, messenger (e.g. WhatsApp), or email; or

(4)

subscribe to our newsletter.

WHAT PERSONAL INFORMATION DO WE COLLECT?

We collect various types of information, for example:

(1)

Information you provide to us when you register on the Website and/or contact us, for example: name, email address, phone number, photo, job title, and details of the company you represent, if applicable.

(2)

Technical information that is collected automatically when you use JuJu Suite, for example: Internet protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, etc.

(3)

User information that is collected automatically when you use JuJu Suite, including: cookies (as described in the ‘Cookies’ section below), log files, full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

(4)

Information received from other sources. Sometimes we may receive information about you if you use any of the other websites we operate or the other services we provide. We may receive certain information necessary to provide you with our services or for our legitimate interest, from third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies).

JuJu Suite is not intended for the use of minors. Thus, we do not knowingly collect or solicit personal data of minors (anyone under age of 13, or other age determined by the country of your residence) or knowingly allow such persons to register for JuJu Suite. In the event that we learn that we have processed personal data of a minor without parental consent, we will delete that information as quickly as possible. If you believe that we might have any data from or about a minor, please contact us at support@jujusuite.com

COOKIES

Our Website uses cookies to distinguish you from other users of our Website. This helps us to provide you with better services and experience when you browse our Website and allows us to improve our site. We will always ask for your consent to place cookies on your device.

Cookies are small files of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain certain information that is transferred to us from your browser or computer’s hard drive.

We use the following cookies:

(1)

Strictly necessary cookies. These are cookies that are required for the operation of the Website. Therefore, we will not ask your consent for placing them. They include, for example, cookies that enable you to log into secure areas of our Website or make use of e-billing services.

(2)

Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.

(3)

Functionality cookies. These are used to recognise you when you return to our Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

(4)

Targeting cookies. These cookies record your visit to our Website, the pages you have visited and the links you have followed. We will use this information to make our Website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You may always change your cookie preferences as well as withdraw your consent for using them in the Cookie preference centre available on the Website.

HOW DO WE USE YOUR DATA?

We use your personal data for the following purposes:

(1)

to provide you with our products and services, including JuJu Suite apps;

(2)

to administer and improve JuJu Suite and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

(3)

to protect the security of and managing access to JuJu Suite, to prevent and detect security threats, fraud, or other criminal or malicious activities;

(4)

to comply with our legal obligations (e.g. record keeping obligations);

(5)

to contact you with our direct marketing materials (find out more about direct marketing in the ‘Direct marketing’ section below);

(6)

for any purpose related and/or ancillary to any of the above or any other purpose for which your personal data was provided to us.

Depending on the purpose of personal data processing, we may process your personal data on one or more of the following legal grounds:

(1)

processing is necessary for the performance of a contract with you (including to provide you with JuJu Suite);

(2)

processing is necessary to comply with our legal obligations;

(3)

processing is necessary for the purposes of our legitimate interest, where such interest is not overridden by your interests or fundamental rights and freedoms (for example, to maintain IT security or to contact existing customers with direct marketing materials).

We may also process your data based on your consent where you have expressly given that to us. For example, when you subscribe to our marketing emails.

DIRECT MARKETING

On our Website you may request to receive direct marketing emails regarding JuJu Suite. In this case, we will send you our marketing materials on the basis of your consent. Please note that you may withdraw your consent at any time and unsubscribe from receiving marketing emails by (1) following the "unsubscribe" link in the footer of a marketing email or (2) sending your request to support@jujusuite.com with detailed instructions for our team.

We may also contact you to market our similar products and services, if you provide us with your personal data (i.e. register on the Website and/or use JuJu Suite apps). This processing is based on our legitimate interest to market our products or services to existing customers.

In case we contact you with a direct marketing material, you will always have a right to stop it at the moment of contact (by following the "unsubscribe" link in the footer of an email or otherwise as may be applicable) or by sending your request to support@jujusuite.com with detailed instructions for our team.

CAN YOU REFUSE TO PROVIDE YOUR PERSONAL DATA?

Provision of some personal data is necessary to receive our services on JuJu Suite (for example, registration information and certain technical information) or is a statutory obligation (for example, record keeping obligations). If you fail to provide such necessary information to us, we will not be able to provide our services to you.

HOW DO WE SHARE YOUR PERSONAL DATA?

We do not sell or rent out your personal data. We may share your personal data with third parties in accordance with this Privacy Notice or after receiving your consent.

We may share your data with the following categories of recipients:

(1)

our affiliates, meaning the companies that are controlled by, or under common control with JuJu Immersive Limited;

(2)

web services used to set up servers (such as Amazon Web Services);

(3)

business partners, suppliers and sub-contractors for the execution of any contract we enter into with you;

(4)

analytics and search engine providers that assist us in the improvement and optimisation of JuJu Suite;

(5)

advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 women aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience.

Your personal data may also be disclosed if:

(1)

we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;

(2)

we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;

(3)

we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect our rights or rights of third parties. This includes exchanging information with other companies and organisations for the purposes of fraud protection and risk reduction.

Please note that if we share any portion of your personal data with third parties, we will do our best to secure such transfer using appropriate legal, organisational, and technical measures.

From the technical side we may use end-to-end encryption of transferred personal data.

From the organisational side we will do our best to ensure that your personal data is transferred in accordance with the best practice, and that any recipient will treat your personal data as strictly as we do.

From the legal side we will ensure that the transfer is made in accordance with the applicable laws and this Privacy Notice.

Sometimes we may transfer your personal data to countries which do not offer the same level of data protection as the laws of your country (such as, for example, the data protection legislation of the EU/EEA). You may find out more about countries which maintain ‘adequate’ level of data protection at https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en. In case we transfer your personal data to a country that does not maintain the ‘adequate’ level of data protection, we will put in place suitable safeguards that give you more protection and control regarding your personal data. We may use the following safeguards:

(1)

Standard Contractual Clauses (special documents developed by the European Commission). Find out more about Standard Contractual Clauses at https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en;

(2)

Transfer personal data to a company which is a member of the EU-US Privacy Shield Framework. Find out more about the EU-US Privacy Shield Framework at https://www.privacyshield.gov/welcome.

You may reach us at support@jujusuite.com to ask whether your personal data is subject to transfer to another country.

HOW DO WE SECURE YOUR PERSONAL DATA?

We always do our best to keep your data secure by reviewing and updating appropriate technical and organisational measures in accordance with our internal policies and procedures regarding storage, access and disclosure of personal data.

Some personal information is anonymised so that even we cannot identify the user. Other personal information undergoes pseudonymisation and encryption to ensure safe transfer and/or storage of your information.

HOW LONG DO WE KEEP YOUR DATA?

We will maintain records of your personal data for as long as:

(1)

you are subscribed to our mailing list;

(2)

you are registered as a user/member of JuJu Suite;

(3)

it is necessary to provide our services to you (including JuJu Suite);

(4)

the data is necessary for other purposes described in this Privacy Notice.

When the processing is no longer necessary, subject to this Privacy Notice and the requirements of the applicable law, we will either delete or anonymise such personal data.

If the processing is based on your consent and you have withdrawn it, we will stop such processing if we are not otherwise legally permitted or required to keep the data.

We may further process your personal data if it is required by the applicable law or is necessary for the purposes of defending or making legal claims until the end of the period required by the relevant law or until the settlement of any such claims, as applicable.

WHAT RIGHTS DO YOU HAVE?

Subject to certain limitations under the applicable law you have the following rights:

(1)

right to access your personal data;

(2)

right to correct your incorrect data and complete your incomplete data;

(3)

right to erase your personal data (right to be forgotten);

(4)

right to restrict use of your personal data;

(5)

right to data portability (to receive your data from us);

(6)

right to submit a complaint with a supervisory authority (Information Commissionaire’s Office website is available at https://ico.org.uk/).

You also have the right to object to the processing of your personal data for the direct marketing purposes as well as the right to object to the processing based on our legitimate interest.

JuJu Suite automatically collects and processes certain personal data (in particular Usage Data) to analyse your behaviour and usage of JuJu Suite. Such automatically collected data is used to generate analytical and statistical reports regarding the sale or rent of property developers’ units. According to the GDPR, such processing is considered as automated decision-making and you have certain additional rights in this regard. Such automated decision-making is necessary for the JuJu Suite software. You have the right to obtain human intervention on our part, to express your point of view and to contest such automatic decision. You may exercise these rights by contacting us at support@jujusuite.com with the detailed description of your request. Please note that we may request you to provide certain proof to verify your identity.

CHANGES TO THIS PRIVACY NOTICE

Any changes we may make to this Privacy Notice in the future will be posted on this page. Such changes will take effect as soon as they are posted on this page. In such case, we will update the ‘Last updated’ date above. Please check back frequently to see any updates or changes to this Privacy Notice.