Gary Jonas Computing Ltd. and its worldwide subsidiaries and affiliates that comprise the Jonas Family of Companies (“Jonas,” “we,” “us,” ”our”) are committed to protecting your privacy. There are various ways that you might interact with Jonas, and the information you provide when doing so allows us to improve our services. By using this website and our related websites (collectively, the “Site”) and by supplying your details to Jonas, you consent to Jonas collecting and processing your information.

Our privacy policy explains:

  • What information we collect, and why we collect it;
  • How we use that information;
  • How we protect that information;
  • How you can control your information, including accessing, updating and deleting what we store;
  • How we share information collected.

Compliance

Jonas adheres to Canadian and international statutes and regulations which govern the protection of personal information. In Canada Jonas adheres to the Personal Information and Protection of Electronic Documents Act (“PIPEDA”). In the United States, Jonas adheres to statutes of general application and statutes of specific application such as the Health Insurance Portability and Accountability Act (“HIPPA”) where applicable. In Australia, Jonas complies with the Privacy Act, 1988, a federal statute as well as with State and Territory laws pertaining to protection of personal information, including the Health Records Act 2001(VIC) where applicable. In New Zealand, Jonas follows the Privacy Act, 1993. In Europe, Jonas adheres to the Data Protection Act, 1998, the European Union ("EU") Data Protection (95/46/EC) and ePrivacy (2002/58/ED) Directives (as transposed into national law), the EU Privacy Directive dated May 26, 2012 (regarding cookies and other matters), EU General Data Protection Regulation (GDPR) dated May 25th, 2018 and registers annually with the Information Commissioner’s Office.

EZFacility complies with the U.S. – E.U. Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data from the European Union member countries. EZFacility has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view EZFacility’s certification, please visit http://www.export.gov/safeharbor/.

EU-U.S. Privacy Shield

EZFacility participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. EZFacility is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List. [ https://www.privacyshield.gov/list]

EZFacility is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. EZFacility complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, EZFacility is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, EZFacility may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Under certain conditions, more fully described on the Privacy Shield website [ https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

Our Privacy Shield certification record (accessible here) lists the U.S. entities and/or subsidiaries that adhere to the Privacy Shield Principles.

Information We Collect & Share

We may collect or record basic personal information (e.g., name, e-mail address, mailing address, phone number) which you voluntarily provide through forms on our Site, through electronic mail you send to us, or through other means of communication between you and us.

We only collect personal information of a more sensitive nature (e.g. social security or other governmental ID numbers, credit card details and account numbers) where it is appropriate or necessary for conducting business. This information will be collected, stored, accessed and processed in a secure manner. We may also collect general non-personal information pertaining to users of our sites, including IP addresses, source domain names, specific web pages, length of time spent, and pages accessed. This information is collected, among other things, to aggregate statistical information, facilitate system administration and improve the Site. We recognize and have controls in place to ensure that the privacy of personal information about an identifiable individual used in the course of commercial activity is protected and managed.

We also collect, use, and disclose identifiable information about individual contacts for our customers (“Business Contact Information”) in the ordinary course of our business for managing and maintaining customer relationships. In particular, we may obtain the following types of Business Contact Information: name, address, invoice information including bank account information, and order information. Unless otherwise specified or prohibited, we may share information with affiliates, business partners, service providers, subsidiaries or contractors who are required to provide you with services which you have requested from us.

We may also post links to third party websites as a service to you. These third party websites are operated by companies that are outside of our control, and your activities at those third party websites will be governed by the policies and practices of those third parties. We encourage you to review the privacy policies of these third parties before disclosing any information, as we are not responsible for the privacy policies of those websites.

How We Use Information

We use the information we collect to provide you with services which you request and to improve our existing services and the content of our Site. When you contact us, we may keep a record of your communication to help solve any issues that you might be facing. Your information may be retained for a reasonable time for use in future contact with you, or for future improvements to our services. You have the option to opt-out or opt-in for further communications from us.

We may also use or disclose your personal information when we believe, in good faith, that such use or disclosure is reasonably necessary to (i) comply with law, (ii) enforce or apply the terms of any of our user agreements, or (iii) protect our rights, property or safety, or the rights, property or safety of our users, or others. We reserve the right to transfer and disclose your information if we become involved in a business divestiture, change of control, sale, merger, or acquisition of all or a part of our business.

In certain cases, we also operate as an information processor for our business customers. Our business customers remain the information controllers with respect to any customer information that they provide to us for our provision of services. We therefore act in accordance with the instructions of such customers regarding the collection, processing, storage, deletion and transfer of customer information, as well as other matters such as the provision of access to and rectification of customer information.

We do not sell our services to children. As such, our Sites are designed for adult user interaction. We do not intentionally collect personally identifiable information from children under the age of 13.

Web User Tracking – Use of Cookies, IP Addresses and Aggregate Information

Cookies are a technology that can be used to help personalize your use of a website. A cookie is an element of information that a website can send to your browser, which may then store it on your system. You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether to accept it or decline at any time. To enable us to assess the effectiveness and usefulness of this Site, and to give you the best user experience, we collect and store information such as pages viewed by you, your domain names and similar information. Our Site makes use of anonymous cookies for the purposes of:

  • Completion and support of Site activity;
  • Site and system administration;
  • Research and development; and
  • Anonymous user analysis, user profiling, and decision-making.

An Internet Protocol (“IP”) address is associated with your computer’s connection to the internet. We may use your IP address to help diagnose problems with our server, to administer the Site and to maintain contact with you as you navigate through the Site. Your computer’s IP address also may be used to provide you with information based upon your navigation through the Site.

Aggregate information is used to measure the visitors’ interest in, and use of, various areas of the Site and the various programs that we administer. We will rely upon aggregate information, which is information that does not identify you, such as statistical and navigational information. With this aggregate information, we may undertake statistical and other summary analyses of the visitors’ behaviors and characteristics. Although we may share this aggregate information with third parties, none of this information will allow anyone to identify you, or to determine anything else personal about you.

Collection and Use of Employee Personal Information

We also collect personal information from our employees and from job applicants (human resource data) in connection with administration of our human resources programs and functions. These programs and functions include, but are not limited to: job applications and hiring programs, compensation and benefit programs, performance appraisals, training, access to our facilities and computer networks, employee profiles, employee directories, human resource recordkeeping, and other employment related purposes. It is our policy to keep all past and present employee information private from disclosure to third parties. There are certain business related exceptions and they are:

•To comply with legal obligations;

•Third parties with which we have contractual agreements to assist in administration of company sponsored benefits;

•Inquiries from third parties with a signed authorization from the employee to release the information. All such requests of this type shall be referred to and completed on a confidential basis by the human resources or payroll department. The information will be returned directly to the requesting party and filed as part of the human resources department’s confidential records.;

•Requests from prospective employers for written verification of employment. As  it  may  not be  reasonable  for  us  to  ask  for  consent from past employees on  every  occasion  that  we  receive  a  reference  request, past employees should let  us  know  if  they  object  to  us  processing  their  data  for  this purpose. All such requests of this type shall be referred to and completed on a confidential basis by the human resources or payroll department. The reference letter will be returned directly to the requesting party and filed as part of the human resources department’s confidential records.

Security

The security of your personal information is important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it.

We use reasonable measures to safeguard personally identifiable information, which measures are appropriate to the type of information maintained, and follows applicable laws regarding the safeguarding of any such information under our control. In addition, in some areas of our Sites, we may use encryption technology to enhance information privacy and help prevent loss, misuse, or alteration of the information under our control. We also employ industry-standard measures and processes for detecting and responding to inappropriate attempts to breach our systems.

No method of transmission over the Internet, or method of electronic storage, can be 100% secure. Therefore, we cannot guarantee the absolute security of your information. The Internet by its nature is a public forum, and we encourage you to use caution when disclosing information online. Often, you are in the best situation to protect yourself online. You are responsible for protecting your username and password from third party access, and for selecting passwords that are secure.

Monitoring and Enforcement

We regularly review our compliance with our privacy policy. We also adhere to several self-regulatory frameworks in addition to complying with applicable law. If we receive formal written complaints, we will follow up with the person making the complaint. We work with the appropriate regulatory authorities to resolve any complaints that cannot be resolved directly.

Accessing and Updating Your Personal Information

If you have provided us with your personal information, you may have the right to inspect the information stored by us for accuracy, or may request that the information be removed from our files. We will make a reasonable effort to comply with such requests except where it would require a disproportionate effort (for example developing a new system or changing an existing practice). We may require that you verify your identity before we act on a request to edit or remove your information. Please direct any questions about your information to the Privacy Contact identified below to review any personal information held about you.

Social Media and Online Engagement

We occasionally use a variety of new technologies and social media options to communicate and interact with customers, potential customers, employees and potential employees. These sites and applications include popular social networking and media sites, open source software communities and more. To better engage the public in ongoing dialog, certain of our businesses use certain third-party platforms including, but not limited to, Facebook, Twitter and LinkedIn. Third-Party Websites and Applications (TPWA) are Web-based technologies that are not exclusively operated or controlled by us. When interacting on those websites, you may reveal certain personal information to us or to third parties. Other than when used by our employees for the purpose of responding to a specific message or request, we will not use, share, or retain your personal information.

Changes to this Privacy Policy

We may change this privacy policy from time to time. If this privacy policy changes, the revised privacy policy will be posted at the "Privacy Policy” link on the Site’s home page. In the event that the change is significant or material, we will notify you of such a change by revising the link on the home page to read "Newly Revised Privacy Policy." Please check the privacy policy frequently. Your continued use of the Site constitutes acceptance of such changes in the privacy policy, except where further steps are required by applicable law. This privacy policy was last updated on the date set out at the end of the policy.

Contacting Us

Questions regarding this privacy policy should be directed to our Customer Success team at 67 Froehlich Farm Blvd., Woodbury, NY 11797; telephone 1.866.498.3279; e-mail info@ezfacility.com.

LAST UPDATED: June, 2018