Privacy Policy

EFFECTIVE DATE:  July 1, 2018

 

  1. GENERAL NOTICE

The privacy and the security of your personal information is extremely important to AJW Technology Consultants, Inc. (hereinafter “AJW Tech”). The purpose of this Privacy Policy is to explain how AJW Tech as a regulatory consulting service provider collects, stores, processes, and uses and transfers your personal data.

In addition, this policy explains where and how we collect your personal information, as well as your rights over any personal data we hold about you. Any processing of personal data is done according to the requirements detailed in the General Data Protection Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR).

  • Access to the ajwtech.com website (hereinafter “the Website”) implies full and unconditional acceptance by the User (hereinafter “User”) of this Privacy Policy (hereinafter “the Policy”).
  • Users of the Website acknowledge that they have read the information below and authorize AJW Tech to deal, in accordance with what is specified in this Policy, with the personal data the User communicates on/to the Website within the framework of the service proposed to be provided by AJW Tech (hereinafter the “Service”).
  • By providing information to Users, AJW Tech may be required to amend and adapt the Policy, in order to comply with any new applicable legislation and/or regulations, such as the adoption of the new European regulation in dealing with personal data, the guidelines, recommendations and good practice of the European Data Protection Committee, and the decisions of courts and tribunals in this field.
  • The Policy is valid for all the hosted pages on the Website. It is not valid for the pages hosted by third parties that AJW Tech may redirect to and where their privacy policies may differ. AJW Tech will not be held responsible for any data processed on those websites or by the operators of them.

 

  1. RESPONSBILITY
    • Access to the Website shall in principle be possible without having to provide personal data.
    • However, as part of the proposal or provision of the Service, the User may be required to transmit certain personal data, such as, for example, surname, first name, postal address, e-mail address, etc.. In such case, AJW Tech is the data controller and the person in charge of processing these data is located at our office in the United States. AJW Tech will take all steps reasonably necessary to ensure that User data is treated securely and in accordance with this Policy and no transfer of User personal data will take place to an organization or a country unless there are adequate security controls in place. Any question or request concerning the processing of these data may be sent to the following address:
      AJW Technology Consultants, Inc., 445 Apollo Beach Blvd, Apollo Beach, FL 33572 USA. info@ajwtech.com

 

  1. INFORMATION
    • Data transmitted to AJW Tech by active intervention of Users (by browsing the Website, filling out forms or newsletters on the Website, through the mobile application, or social networks linked to AJW Tech) allows AJW Tech to register and maintain, for the purposes addressed in this Policy, the following information:
      • Identification data, such as surname and first name, gender, e-mail address, date of birth and contact information, where applicable;
      • Communications between Users and AJW Tech;
      • The additional information requested by AJW Tech from the User in order to identify or prevent him/her from breaching any of the provisions of the Policy;
      • And any other information voluntarily transmitted to AJW Tech by the User for a determined purpose in the Policy, on/to the Website or on any other communication tool used by AJW Tech.
    • Data automatically transmitted to AJW Tech when consulting the Website:
      • In order to facilitate browsing the Website and optimize technical management, the Website may use “cookies”.
      • Cookies are small text filesthat are stored on your computer, phone or other web enabled device when you visit our Website. They are not harmful and do not contain any confidential information, they simply help us understand how visitors utilize our Website.
      • We differentiate between two categories of cookies: (1) functional cookies, without which the functionality of our Website would be reduced, and (2) optional cookies used for website analysis and marketing purposes.

 

  1. PURPOSE
    • General purposes – AJW Tech collects, saves and processes personal data of its Users in particular for the following purposes:
      • To perform a contract to provide the Service of a European Authorized Representative, US Agent, Regulations, Quality Systems Consultation;
      • To analyze, adapt and improve the content of the Website;
      • To detect and / or prevent fraud or similar activities of an illegal nature;
      • To facilitate the provision and use of the Website and improve the Services offered by AJW Tech as well as the experience of the Users;
      • To respond to User requests for information;
      • To promote AJW Tech services and inform Users about the evolutions of the Website and the Service;
      • For any other purpose for which the User has expressly consented or as required for AJW Tech to comply with its legal obligations.
    • AJW Tech will not collect sensitive personal data considered irrelevant for the performance of the said Service (information about racial or ethnic origin; political opinions; religious beliefs; trade union membership; physical or mental health; sexual life; and criminal allegations, proceedings or convictions). AJW Tech does not use personal data for automated decision-making.
    • AJW Tech collects and processes your personal data to meet contractual/management responsibilities under the legitimate interest provision of the GDPR Regulation. It includes, but is not limited to, data relating to: surname and family name, position and responsibilities within the organization, e-mail address and telephone/mobile number, postal address.
    • For the performance of the Service, AJW Tech may be required to provide your personal data to third party providers (i.e. Competent Authorities, Notified Bodies, Safety Assessor, etc.) which have adequate data protection policies. Nonetheless, with the exception of the Competent Authorities, AJW Tech will not share your personal data with any other third party without your prior consent. Your personal data will not be shared informally.
    • Transfer to a country not a member of the European Economic Area (EEA) – Except for our office in the United States and any affiliate offices necessary to provide the Service (all of which operate under this same Policy), AJW Tech does not transfer data to a country which is not a member of the European Economic Area unless the recipient provides an adequate level of protection within the meaning of the law applicable, or within the limits permitted by the same law, for example by ensuring the protection of data by appropriate contractual provisions.

 

  1. SECURITY
    • Personal data is collected and used fairly, stored safely and not disclosed unlawfully. The data can be stored electronically in an AJW Tech Database, on paper or on other materials. AJW Tech will strictly collect data relevant for the performance of its role and services as European Authorized Representative or Consultant.
    • AJW Tech has taken adequate measures to ensure that the servers hosting the processed personal data prevent, to the extent possible:
      • The processing, access or unauthorized modification of these data;
      • The unintended use or disclosure of such data; and
      • The unlawful destruction or accidental loss of such data.
    • Your personal data will be processed exclusively by authorized personnel who are subject to strict confidentiality obligations. AJW Tech ensures the data is handled appropriately by promoting adequate internal use of personal data, and by ensuring that all systems, services and equipment used for storing data meet acceptable security standards. AJW Tech cannot, however, be held liable for any misappropriation of these data by a third party in spite of the adopted security measures.
    • The User agrees not to commit any acts which may be contrary to the present Policy or, generally, the law. Offenses against the confidentiality, integrity and availability of computer systems and saved data, processed or transmitted by such systems, or the attempt to commit any of these offenses, are punishable by law.

 

  1. RETENTION PERIOD

AJW Tech will normally keep the personal data of its Users for the duration necessary to provide the Service or otherwise accomplish the pursued purposes. AJW Tech may also continue to maintain personal data provided by the User in other ways, including any correspondence or request for assistance addressed to AJW Tech, in order to be able to answer any questions or complaints that may be addressed to it or to comply with legal obligations. AJW Tech may retain payment information for such period necessary in order to comply with all applicable laws (including taxation).

  1. USER’S RIGHTS
    • The User may at any time request access to, or transmission, rectification or, if necessary, deletion of his/her personal data, with the exception of those data which AJW Tech would have a legal obligation to keep, by sending a written request accompanied by a copy of government issued identification:

At the following postal address: AJW Technology Consultants, Inc., 445 Apollo Beach Blvd, Apollo Beach, FL 33572 USA; or

To the following email address: info@ajwtech.com

  • If the User wishes to raise a complaint on how their personal data was handled, he/she can contact our office at info@ajwtech.com and AJW Tech will investigate the matter.
  • If the User is a resident of the European Economic Area (EEA), the User has certain data protection rights. AJW Tech aims to take reasonable steps to allow the User to correct, amend, delete, or limit the use of their personal data. Users in the EEA have the following data protection rights:
  • The right to access, update or to delete the information AJW Tech has on the User.
  • The right of rectification. The User has the right to have their information rectified if that information is inaccurate or incomplete.
  • The right to object. The User has the right to object to AJW Tech’s processing of their personal data.
  • The right of restriction. The User has the right to request that AJW Tech restrict the processing of their personal data.
  • The right to data portability. The User has the right to be provided with a copy of the information AJW Tech has on the User in a machine-readable and commonly used format.
  • The right to withdraw consent. The User has the right to withdraw consent at any time where AJW Tech relied on User consent to process personal information.
  • Please note that AJW Tech may ask the User to verify their identity before responding to such requests.
  • The User has the right to complain to a data protection authority about AJW Tech’s collection and use of User’s personal data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

 

  1. CHILDREN’S PRIVACY

AJW Tech does not knowingly collect personally identifiable information from anyone under the age of 18.  If AJW Tech becomes aware that it has collected personal data from children without verification of parental consent, it will take steps to delete that data.

 

  1. PERIODIC UPDATE

In respect to AJW Tech’s continuous efforts to uphold data privacy requirements and its high quality of service, this Policy is subject to periodic non-retroactive review and may be revised based on any revisions to the tasks, responsibilities and requirements introduced by applicable regulations, decisions or laws on data protection.  Updates to this Policy will be announced by notice on the Website, and Users are advised to periodically review this Policy for any updates.

  1. APPLICABLE LAW & JURISDICTION
  • The Policy shall be governed by US law to the fullest extent permitted by applicable law.
  • In the event of a dispute concerning the validity, application, interpretation or enforcement of the Policy, the state and federal courts having jurisdiction over Hillsborough County, Florida, shall have exclusive jurisdiction, to the fullest extent permitted by applicable law.
  • To the fullest extent permitted by applicable law, before undertaking any legal dispute resolution, the User covenants to undertake to resolve the dispute by amicable means directly, and if necessary by mediation, before resorting to arbitration, litigation, or any other means of dispute resolution.