Privacy Policy

“Personal Information” means any information that identifies, relates to, describes, or is reasonably capable of being associated with an identified or identifiable natural person, and includes “personal data” and “personal information” as defined under applicable data protection law.

“Applicable Data Protection Law” means all laws and regulations governing the processing of Personal Information that apply to us, which may include the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”), and other U.S. state privacy laws; the EU General Data Protection Regulation (“GDPR”) and the UK GDPR and Data Protection Act 2018; Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”) and substantially similar provincial legislation, including Québec’s Act respecting the protection of personal information in the private sector; Singapore’s Personal Data Protection Act 2012 (“PDPA”); and Vietnam’s Law on Personal Data Protection and its implementing regulations.

Exclusions. This Policy does not apply to:

1. Personal Information we process on behalf of our clients in the course of providing consulting, implementation, or training services. That processing is governed by our agreements with those clients, and we act as a processor or service provider for the client, which is the controller or business responsible for that information;
2. Personal Information of our own employees and contractors, which is governed by separate internal notices; and
3. the practices of third parties that we do not own or control, including websites linked from the Site.

Joon Solutions Global Inc., 1111 Sixth Ave, San Diego, CA 92101, USA, is the controller (or “business”) responsible for Personal Information collected through the Site. Where you interact directly with one of our affiliates, including our offices in Toronto, Canada; Singapore; and Ho Chi Minh City, Vietnam, that affiliate may act as a joint controller together with Joon Solutions Global Inc.

You may contact our Data Protection Officer, who also serves as our Privacy Officer for purposes of Canadian law and our data protection officer for purposes of the PDPA, at support@joonsolutions.com (subject line: “Attn: Data Protection Officer”).

Information you provide to us

We collect Personal Information that you voluntarily provide when you complete a contact or inquiry form, request a consultation, register for or attend an event or webinar, subscribe to communications, apply for an internship or position, or otherwise correspond with us. This may include your name, business email address, telephone number, employer, job title, country, the content of your message, and, for applicants, your résumé, education, work history, and any other information you choose to include.

Information collected automatically

When you access the Site, we and our service providers automatically collect certain information about your device and usage, including your IP address, browser type and version, operating system, device type, language preference, referring and exit pages, pages viewed, links clicked, the date and time of each request, and approximate location derived from your IP address. We collect this information using cookies, pixels, local storage, and similar technologies, as described in the “Cookies and similar technologies” section below.

Information from third parties

We may receive Personal Information about you from third parties, including business contact data providers and sales intelligence platforms, event co-sponsors and technology partners, educational institutions and job boards (for applicants), and publicly available sources such as professional networking profiles. We may combine this information with information we collect directly from you, for example to verify or supplement business contact details submitted through our contact form.

Sensitive Personal Information

We do not intentionally collect sensitive or special category Personal Information (such as government identifiers, financial account information, precise geolocation, health information, racial or ethnic origin, religious beliefs, or biometric data) through the Site, and we ask that you not submit it. If you provide sensitive Personal Information in an application or message, we will use it only as permitted by Applicable Data Protection Law and will not use it to infer characteristics about you.

We use Personal Information for the purposes described below. Where the GDPR, UK GDPR, or similar law applies, we rely on the legal bases indicated for each purpose, as set out in Article 6(1) of the GDPR.

Where we rely on legitimate interests, we have balanced those interests against your rights and freedoms. You may request more information about this assessment by contacting us. We will not use Personal Information for purposes materially different from those described in this Policy without providing you notice and, where required, obtaining your consent.

Automated decision-making. We do not engage in automated decision-making, including profiling, that produces legal effects concerning you or similarly significantly affects you.

We do not sell Personal Information. We disclose Personal Information only to the following categories of recipients and only for the purposes described in this Policy:

1. Affiliates. Our affiliates and subsidiaries, so that the appropriate office can respond to your inquiry or application, subject to this Policy.
2. Service providers and processors. Vendors that process Personal Information on our behalf and under written contractual obligations of confidentiality and data protection, including website hosting (GitHub, Inc.), web analytics (Google LLC), form hosting and customer relationship management (Apollo.io), email and productivity services, and recruiting platforms.
3. Professional advisors. Lawyers, auditors, accountants, and insurers, where necessary in the course of the professional services they render to us.
4. Legal and regulatory recipients. Courts, regulators, law enforcement, and other public authorities, where we believe in good faith that disclosure is required by law, regulation, or legal process, or is necessary to protect the rights, property, or safety of Joon Solutions, our clients, or others.
5. Corporate transactions. Actual or prospective acquirers, investors, or successors in connection with a merger, acquisition, reorganization, financing, sale of assets, or bankruptcy, subject to customary confidentiality undertakings.
6. With your consent. Other third parties where you have directed or consented to the disclosure.

Cookies are small text files placed on your device when you visit a website. We and our service providers use the following categories of cookies and similar technologies on the Site:

1. Strictly necessary. Required for the Site and embedded forms to function and to maintain security. These cannot be disabled through our Site.
2. Analytics. We use Google Analytics 4 to understand how visitors use the Site. Google Analytics sets first-party cookies (such as _ga) and collects information about your use of the Site, which Google processes on our behalf. We do not use Google Analytics advertising features to serve personalized advertising. Information on Google’s practices is available at policies.google.com/technologies/partner-sites, and you may opt out using the Google Analytics Opt-out Browser Add-on.
3. Functional. Our contact form is provided by Apollo.io, which may set cookies necessary to render the form and to associate a form submission with the browsing session in which it was made.

You can refuse or delete cookies through your browser settings. If you do, some features of the Site may not function as intended.

Opt-out preference signals. We treat a legally recognized browser-based opt-out preference signal, such as Global Privacy Control, as a valid request to opt out of the sale or sharing of Personal Information for the browser or device that sends it, where required by Applicable Data Protection Law. Because there is no uniform industry standard for “Do Not Track” signals, we do not otherwise respond to them.

Joon Solutions operates in the United States, Canada, Singapore, and Vietnam, and our service providers maintain facilities in these and other countries. As a result, your Personal Information may be transferred to, stored in, and processed in countries other than the one in which it was collected, including the United States, whose data protection laws may differ from and be less protective than those of your jurisdiction.

Where we transfer Personal Information from the European Economic Area, the United Kingdom, or Switzerland to a country that has not received an adequacy decision, we rely on appropriate safeguards, such as the European Commission’s Standard Contractual Clauses (together with the UK International Data Transfer Addendum, where applicable) or a recipient’s certification under the EU-U.S. Data Privacy Framework and its UK and Swiss extensions, supplemented where necessary by additional technical and organizational measures. For transfers from Singapore, we take steps to ensure that recipients provide a standard of protection comparable to that under the PDPA. For transfers from Canada, we use contractual and other means to provide a comparable level of protection, and we conduct assessments of privacy-related factors where required by Québec law. Transfers from Vietnam are made in accordance with the requirements of Vietnamese law. You may request a copy of the relevant safeguards by contacting us.

We retain Personal Information only for as long as reasonably necessary to fulfill the purposes for which it was collected, including to satisfy legal, accounting, tax, or reporting requirements. In determining retention periods, we consider the amount, nature, and sensitivity of the information; the potential risk of harm from unauthorized use or disclosure; the purposes of processing and whether they can be achieved by other means; and applicable limitation periods. As a general guide:

1. Inquiry and marketing contact information is retained for the duration of our business relationship and for up to three (3) years after your last interaction with us, or until you ask us to delete it or unsubscribe, whichever occurs first (we retain a record of opt-outs so we can honor them).
2. Applicant information is retained for up to two (2) years after the conclusion of the recruiting process so that we may consider you for future opportunities, unless you request earlier deletion or local law requires a different period. If you are hired, it becomes part of your personnel record.
3. Site analytics data is retained in Google Analytics for no longer than fourteen (14) months, after which it is used only in aggregated form.

We may retain Personal Information for longer where required by law or to establish, exercise, or defend legal claims. When retention is no longer required, we securely delete or anonymize the information.

We maintain reasonable administrative, technical, and physical safeguards designed to protect Personal Information against accidental, unlawful, or unauthorized access, use, alteration, disclosure, loss, or destruction, including encryption of data in transit, access controls based on the principle of least privilege, and contractual security obligations for our service providers. However, no method of transmission over the Internet or method of electronic storage is completely secure, and we cannot guarantee absolute security. If we become aware of a breach affecting your Personal Information, we will notify you and the relevant authorities where and as required by Applicable Data Protection Law.

Depending on your jurisdiction, and subject to certain exceptions and limitations under Applicable Data Protection Law, you may have some or all of the following rights with respect to your Personal Information:

1. Access and portability: to confirm whether we process your Personal Information and to obtain a copy of it, in a portable format where technically feasible;
2. Correction: to have inaccurate or incomplete Personal Information corrected;
3. Deletion: to have your Personal Information deleted;
4. Restriction and objection: to restrict or object to our processing, including processing based on legitimate interests;
5. Opt out of marketing: to stop receiving marketing communications at any time, by using the unsubscribe link in any marketing email or contacting us;
6. Withdrawal of consent: where processing is based on consent, to withdraw that consent at any time, without affecting the lawfulness of processing before withdrawal; and
7. Complaint: to lodge a complaint with a competent data protection authority.

How to submit a request

To exercise any of these rights, email support@joonsolutions.com with the subject line “Privacy Rights Request” and describe the right you wish to exercise. To protect your Personal Information, we will take reasonable steps to verify your identity before responding, which may include asking you to confirm information we already hold. You may designate an authorized agent to submit a request on your behalf; we may require the agent to provide a signed authorization or valid power of attorney and may ask you to verify your identity directly with us.

We will respond within the time period required by Applicable Data Protection Law, which is generally thirty (30) days under the GDPR and PIPEDA and forty-five (45) days under the CCPA, and may be extended where permitted. We do not charge a fee to process a request unless it is manifestly unfounded, excessive, or repetitive, in which case we may charge a reasonable fee or decline to act, as permitted by law.

Appeals

If we decline to take action on your request, you may appeal our decision by emailing support@joonsolutions.com with the subject line “Privacy Rights Appeal” within thirty (30) days of our response. We will respond to your appeal within the period required by law. If your appeal is denied, you may contact the attorney general or data protection authority in your jurisdiction.

This section supplements this Policy for residents of California and other U.S. states with comprehensive consumer privacy laws, to the extent those laws apply to us. It also serves as our notice at collection under the CCPA.

Categories of Personal Information

In the preceding twelve (12) months, we have collected the following categories of Personal Information, from the sources indicated, and have disclosed each category for a business purpose to the categories of recipients indicated. We collect and use these categories for the business and commercial purposes described in the “How we use Personal Information and our legal bases” section above, and retain them for the periods described in the “Data retention” section above.

No sale or sharing

We do not sell Personal Information, and we do not share Personal Information for cross-context behavioral advertising, as those terms are defined under the CCPA. We do not process Personal Information for targeted advertising or for profiling in furtherance of decisions that produce legal or similarly significant effects. We have no actual knowledge of selling or sharing the Personal Information of consumers under sixteen (16) years of age. We do not use or disclose sensitive Personal Information for purposes that would give rise to a right to limit under the CCPA.

Your rights

California residents have the right to know the categories and specific pieces of Personal Information we have collected, the categories of sources, the business or commercial purposes for collection, and the categories of third parties to which we disclose it; and the rights to delete, to correct, and to opt out of the sale or sharing of Personal Information. Residents of other states, including Colorado, Connecticut, Oregon, Texas, Utah, and Virginia, may have similar rights under their state laws. You may exercise these rights as described in the “Your rights” section above. We will not discriminate or retaliate against you for exercising any of your privacy rights.

Shine the Light. California Civil Code § 1798.83 permits California residents to request information about disclosures of Personal Information to third parties for their direct marketing purposes. We do not make such disclosures.

European Economic Area, United Kingdom, and Switzerland

If you are located in the EEA, the UK, or Switzerland, you have the rights described in the “Your rights” section above, and you may lodge a complaint with the supervisory authority in the country where you live or work, or where an alleged infringement occurred. In the UK, this is the Information Commissioner’s Office (ico.org.uk). We would, however, appreciate the chance to address your concerns before you approach a supervisory authority.

Canada

By providing Personal Information to us, you consent to its collection, use, and disclosure as described in this Policy, including its transfer outside your province and outside Canada, where it may be accessible to courts, law enforcement, and national security authorities of other jurisdictions. You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. Residents of Québec have additional rights, including the right to be informed of the use of technologies that allow them to be identified, located, or profiled. You may file a complaint with the Office of the Privacy Commissioner of Canada or, in Québec, the Commission d’accès à l’information.

Singapore

We collect, use, and disclose Personal Data in accordance with the PDPA, on the basis of your consent or deemed consent, or as otherwise permitted by the PDPA. You may request access to or correction of your Personal Data, or withdraw consent, by contacting our data protection officer as set out in this Policy. If you are not satisfied with our response, you may contact the Personal Data Protection Commission.

Vietnam

We process Personal Data of data subjects in Vietnam in accordance with Vietnam’s Law on Personal Data Protection and its implementing regulations. By submitting Personal Data to us, you consent to its processing for the purposes, and its transfer to the recipients and countries, described in this Policy. You may exercise your rights as a data subject, including the rights to be informed, to consent or withdraw consent, to access, correct, and delete your data, to restrict or object to processing, and to complain, by contacting us as set out in this Policy.

The Site is directed to business audiences and is not intended for individuals under the age of sixteen (16). We do not knowingly collect Personal Information from children under sixteen (16). If you believe that we have inadvertently collected such information, please contact us and we will promptly delete it.

The Site contains links to, and embedded content from, websites and services operated by third parties, including Medium, LinkedIn, YouTube, Facebook, and Instagram. Those third parties may collect information about you in accordance with their own privacy policies. We are not responsible for the privacy practices of any third party, and we encourage you to review their policies before providing them with Personal Information.

We may update this Policy from time to time to reflect changes in our practices or in Applicable Data Protection Law. The “Last updated” date at the top of this Policy indicates when it was last revised. If we make material changes, we will provide notice by posting a prominent notice on the Site or by other means required by law and, where required, obtain your consent. Your continued use of the Site after the effective date of an updated Policy constitutes your acknowledgment of the updated Policy.

If you have any questions, comments, or complaints about this Policy or our privacy practices, please contact: