Privacy Policy

Note:

• We do not use Special Categories of Personal Data except where you have explicitly consented, where required by law, or where necessary to establish, exercise, or defend legal claims.
• We do not sell your Personal Data except as disclosed in the “Corporate Transactions and Data Transfer” section below.

Personal Data we collect from the Site include:

• Your name (first & last)
• Title (e.g., job position)
• Mailing address (including residential or other specified address)
• Business address
• Personal email address
• Business email address
• Internet protocol (IP) address used to connect your computer to the Internet
• Personal Data collected in the employment application and talent management context, such as:
  • Background and qualification Personal Data: Information related to your education, employment history, skills, criminal record (if permitted by law), credit history, and similar data.
  • References: Personal Data about your third-party references.
  • Previous applications or employment: Information related to prior applications or previous employment history with us.
  • Demographic Personal Data (when permitted by law): Information about you, including race, ethnicity, gender, disability status, and other demographic identifiers collected for internal reporting or compliance purposes.

Any additional categories of Personal Data collected from the Site will be collected only with your explicit consent or as required to provide services to you.

Purposes for collecting Personal Data from the Site include:

• Provide and Improve Services: To offer features, functionality, and content on the Site for a better user experience.
• Compliance with Legal Requirements: To comply with applicable laws, regulations, and government mandates.
• Security and Fraud Prevention: To protect against unauthorised access, fraud, or other security incidents affecting the Site or our services.
• Communication and Support: To respond to inquiries, provide customer service, or address requests submitted via the Site.
• Process Improvement and Analytics: To analyse website performance and improve functionality, user experience, and business processes.
• Employment Application and Talent Management: To support our recruitment and talent management processes, including assessing job applications, verifying applicant information, and facilitating communication during the hiring process.
• Other Legal or Reasonable Purposes: For other purposes that are reasonable, lawful, and communicated to you as required.

We may share this Personal Data with third parties (see the “Sharing and Disclosure of Personal Data” section) in accordance with this Privacy Notice. We will obtain your consent before sharing your Personal Data for a secondary purpose.

Legal bases for Processing your Personal Data

We rely on the following legal bases to Process your Personal Data, depending on context in which it is collected and used:

• Performance of a contract: When we need to Process your Personal Data to provide you with services you have requested, such as creating and managing your account with us, providing customer support, or delivering the services you requested.
• Consent: When required by law, or where we rely on your consent for specific purposes, including marketing communications or sharing your Personal Data with third parties.
• Legitimate interest: When Processing is necessary for our legitimate business interests, provided those interests are not overridden by your rights and freedoms, for example fraud prevention, service improvement, or platform enhancement and security.
• Compliance with legal obligations: When Processing is required to comply with applicable laws, including the UK GDPR and EU GDPR, regulatory requirements, inquiries, or legal proceedings.

We determine the appropriate legal basis depending on the nature of the Personal Data and the specific purpose for which it is Processed, as further described in this Privacy Notice.

Use of Cookies on Our Site

Our Site uses cookies, which are small text files sent to your device each time you visit our Site, as well as similar technologies to record log data, enhance functionality, and personalise your experience. For more information about cookies and how we use them, please refer to our “Cookie Notice”. You can manage your cookie preferences, including opting out of targeted advertising, by adjusting your browser settings or using the “Cookie & Privacy Preferences” tool available in the Site footer.

Personal Data we collect from the Mobile App

Personal Data we collect from the Mobile App include:

• Your name (first & last)
• Mailing address
• Email address
• Registration Data (usernames & passwords)
• Geolocation information, if enabled on your device (you can withdraw consent by disabling location services in your device settings; note that this may limit certain app features)
• Tenant unique identifier for the tenant (that the PMS system generates and uses)
• Tenant unit number
• Access logs, including information about the dates, times, and durations of access to the unit
• Shared Key (we obtain the same information for anyone the “Master” tenant has shared their digital key with)
• Unit identification information
• Unit unique identifier (that the property management system, if any, generates and uses)
• Unit status – available, rented, overlocked, auction
• Unit name (usually an alphanumeric number associated with the unit)

Any additional categories of Personal Data collected from the Mobile App will be collected only with your explicit consent or as required to provide services to you.

Purposes for collecting Personal Data from the Mobile App

We collect Personal Data from our customers’ personnel, tenants, and certain Company managers who use our Mobile App.

When Processing Personal Data on behalf of our customers, we operate under strict contractual obligations to maintain compliance with privacy laws and industry standards. This Personal Data is:

• Handled exclusively for the purposes defined by our customers.
• Not used for our independent purposes.
• Limited in use to the service for which the customer has engaged Company.

Personal Data Received from Customers Through Our Services

We receive Personal Data from our customers through our storage facility-related services. We Process and use Personal Data pursuant to contracts we have in place with our customers. The use of Personal Data Processed through these services shall be limited to the purpose of providing the service for which the customer has engaged us. We generally Process Personal Data at our customer’s direction and do not typically have a direct relationship with the tenants whose Personal Data we receive. See the sections on “Managing Consent for Personal Data Collection” and “Your Privacy Rights and Managing Your Personal Data” for more information.

Audio and Visual Materials on Our Site

We use live and pre-recorded audio-visual materials and video teleconferencing platforms, such as Google, Zoom, WebEx, and Skype for Business, to enhance your experience and deliver services like conferences, meetings, training sessions, and other programs. These platforms may involve third-party service providers (see the “Sharing and Disclosure of Personal Data” section for more details on how we engage with them).

By accessing or participating in our audio-visual or video teleconferencing activities, you consent to the following:

• Collection and Use of Personal Data: Information shared during these activities, including content, conversations, and discussions, may be recorded, collected, and retained for purposes such as training, compliance, or promotional content.
• Third-Party Privacy Practices: Recordings and related data may be stored or retained by service providers administering the platform, subject to their privacy policies and practices. We encourage you to review their privacy policies to understand how your data is handled.
• If you have concerns about how your Personal Data is handled or wish to withdraw consent for recordings, please contact us using the details provided in the “Contacting Us” section. Note that withdrawing consent may limit your ability to participate in certain activities or access specific materials.

How We Access Your Personal Data

We limit access to Personal Data acquired to personnel who require it for legitimate business purposes, and only to the extent necessary to fulfil their job responsibilities. The categories of personnel who may handle your Personal Data include, but are not limited to:

• Support Staff: Personnel responsible for assisting with inquiries, technical support, and resolving issues related to the Site, Mobile App, or services provided.
• Marketing and Communications Team: Personnel involved in creating and sending communications such as newsletters, special offers, updates, or other promotional materials.
• IT and Security Personnel: Personnel responsible for maintaining the security, functionality, and integrity of the Site and Mobile App, including data protection measures and handling security incidents.
• Product and Development Team: Personnel involved in improving or developing the Site, Mobile App, features, or user experience, and who may need to analyse user behaviour, app performance, or feedback.
• Compliance and Legal Team: Personnel responsible for maintaining the Company’s compliance with applicable laws and regulations regarding data protection, privacy policies, and contractual obligations.

Our personnel are trained on the importance of data protection and must adhere to strict confidentiality and privacy standards when handling Personal Data.

Managing Consent for Personal Data Collection

You may refuse to provide your consent to our collection of your Personal Data. However, refusing to provide consent may limit our ability to provide goods or services to you. We will not deny a request for goods or services solely based on refusal of consent unless collection is essential for service delivery. You may refuse or withdraw consent for secondary uses of your Personal Data at any time, except where such use is necessary for the delivery of our core services. For more information on withdrawing consent, see the “Your Privacy Rights” section.

Use of Your Personal Data

We may use your Personal Data for the purposes described below:

Marketing and Communications:

• To provide you with information requested from us relating to our products or services.
• To notify you about any changes to our Site, such as improvements or service/product changes, that may affect our service.
• With your consent, to communicate with you to manage our contractual relationship with you and/or for a legitimate business or commercial purpose.

Deliver the product/service and customer support:

• To manage our contractual relationship with you and/or for a legitimate business or commercial purpose. If you do not provide the data that we request, or prohibit us from collecting such data, we may not be able to provide the requested services.
• To provide you or our customer’s access to the Mobile App and customer support.

Business Purposes:

• In certain circumstances, to comply with laws.
• To prevent and detect fraud and abuse in order to protect the security of our customers, Company, and others.
• To process transaction payments (including, but not limited to, service fees, subscriptions, registration fees, voluntary contributions, and payments, refunds and reimbursements for any products or services that you choose to purchase from us).
• To request anonymised ratings and reviews of the Mobile App and the products or services we offer.
• To contact you to respond to an inquiry.

Additional Purposes:

• To enforce this Privacy Notice and our “Terms of Use”.
• Comply with applicable due diligence laws and requirements regarding security, anti-terrorism, anti-bribery, customs, immigration, and similar matters.
• For any other necessary purposes as permitted or required by law.
• We may also ask for your consent to Process your Personal Data for a specific purpose that we communicate to you.

In addition to the purposes listed above, we will inform you of any other purposes for which your Personal Data will be at or before the time of collection.

If we later intend to use your Personal Data for a purpose not previously disclosed to you, we will seek your separate consent beforehand, unless applicable law permits us to do so without your consent.

Automated Decision-Making and Human Oversight

We do not use automated decision-making that produces legal or similarly significant effects without human intervention.

Sharing and Disclosing Your Personal Data

We may disclose Personal Data to third-party partners through analytical and advertising tools for personalized marketing to enhance your experience. You can manage cookie preferences and opt out of personalized advertisements via the “Cookie & Privacy Preferences” tool in the Site footer.

We may also disclose your Personal Data in the following ways:

1. Intra-Group: We may disclose your Personal Data with our parent, subsidiaries, and affiliate entities.
2. With third-party service providers, agents, or contractors: We use other companies, agents or contractors (“Service Providers”) to perform services on our behalf or help us provide services to you. For example, we may engage Service Providers to process credit card transactions or other payment methods, or, we may engage Service Providers for marketing, advertising, communications, IT infrastructure, and related services to provide customer service, to collect debts, and to analyse and enhance data (including data about users’ interactions with our service). Service Providers may access your Personal Data to perform these functions. In addition, some of the Personal Data we request may be collected by Service Providers on our behalf. Our Service Providers are contractually required to use your Personal Data solely for the specified services and to maintain appropriate security measures in compliance with applicable privacy laws. We do not authorise them to use or disclose your Personal Data except in connection with providing their services.
3. It is likely that the identity and categories of such Service Providers will change during the life of your account. We require that our Service Providers use only your Personal Data as necessary to provide the requested services to us and each Service Provider is subject to a set of terms consistent with the applicable portions of this Privacy Notice.
4. To Comply with legal process or to protect Company: Except as otherwise described in this Privacy Notice, we will not disclose your Personal Data to any third party unless required to do so by applicable law, a valid court order or subpoena, or other legally enforceable obligations. This includes responding to government or regulatory inquiries or demands that comply with applicable legal standards.

We may disclose Personal Data if we determine, in good faith, that such action is necessary to:

• comply with applicable law or respond to a valid legal process served on us or our parent, its subsidiaries, and affiliate entities, contracted vendors, and affinity partners;
• investigate, prevent, or take action regarding suspected or actual illegal activities;
• enforce our “Terms of Use”, other policies, or contractual obligations (including for billing and collection purposes);
• mitigate or take precautions against liability;
• investigate and defend ourselves against any third-party claims or allegations;
• assist government enforcement agencies or comply with lawful national or provincial security requirements;
• protect the security, integrity, or proper functioning of our Site, Mobile App, services, or any software we provide related thereto; or,
• safeguard the rights, property, or personal safety of us, our users, or others.

We will make a reasonable effort to notify you of any such request unless we determine, in good faith, that: (i) providing notice is prohibited by the legal process itself, by court order, or by applicable law, or (ii) providing notice would be futile, ineffective, or create a risk of harm, such as injury or bodily harm, fraud, or security threats, to us, our users, our Site, the Mobile App, or our services. If we comply with legal requests without providing prior notice for these reasons, we will notify you after the fact unless legally prohibited or risks remain.

Business Transfers

You acknowledge and consent to the disclosure of your Personal Data to a third party in connection with a proposed or actual merger, divestiture, restructuring, reorganisation, dissolution, sale, or other transfer of some or all of our business, assets, or equity, including as part of bankruptcy, liquidation or other similar proceeding, whether as a going concern or otherwise, in which Personal Data held by us is among the assets transferred. You consent to the transfer of your Personal Data as part of a merger, acquisition, or restructuring, without requiring additional consent, as permitted by applicable law.

Corporate Transactions and Data Transfer

We may transfer or disclose Personal Data as part of a merger, acquisition, divestiture, restructuring, reorganisation, bankruptcy, or other corporate transaction involving our parent undertaking or its subsidiaries and affiliates. This may include the transfer of customer records, visitor data, and other related Personal Data to a successor entity or potential acquirer.

International Transfer of Your Personal Data

We transfer Personal Data to countries outside of the United Kingdom and the European Economic Area, including the United States, where our parent company and certain service providers are located.

Where required by law, we implement appropriate safeguards to provide an adequate level of protection for Personal Data transferred internationally. These safeguards include reliance on the European Commissioner’s Standard Contractual Clauses together with the UK International Data Transfer Addendum, as applicable. We also conduct transfer impact assessments and require our service providers to implement appropriate technical and organisational measures to protect Personal Data.

If you have any questions about international transfers of your Personal Data or the safeguards we use, please contact us using the details provided in the “Contacting Us” section.

Storing Your Personal Data

We store your Personal Data on secure servers, operated either by us or by trusted Service Providers, in a manner designed to align with applicable legal requirements. We take commercially reasonable steps to safeguard your Personal Data, including implementing encryption protocols and maintaining access controls to help protect against unauthorised access, use, or disclosure.

For further information about how we store your Personal Data or the measures we use to protect it, please contact us using the details provided in the “Contacting Us” section.

How Long We Retain Your Personal Data

We retain your Personal Data for as long as necessary to fulfil purposes described in this Privacy Notice or as otherwise required or permitted by law. Retention periods may vary based on the nature of the Personal Data and the identified purposes for which it was collected. For example:

• We retain your Personal Data for as long as necessary to fulfil the purposes outlined in this Privacy Notice, comply with legal obligations, or provide services you have requested.
• We may also retain your Personal Data for a reasonable period thereafter for purposes such as compliance with legal obligations, internal reporting, reconciliation, and responding to your requests for feedback or information.

At the end of the applicable retention period, we endeavour to securely destroy, delete, or otherwise render your Personal Data unidentifiable in accordance with our records retention practices and technical capabilities.

How We Secure Your Personal Data

We are committed to safeguarding the security and confidentiality of your Personal Data. While no security system can guarantee absolute protection, we employ security measures to minimise risks and maintain the integrity of your Personal Data. To protect against unauthorised access, use, disclosure, alteration, or destruction, we implement a combination of advanced technical, physical, and organisational safeguards, including:

1. Encryption: We use encryption technologies to secure Personal Data during transmission and storage.
2. Access control: We enforce strict access control protocols to limit access to authorised personnel or Service Providers with a legitimate business need.
3. Personnel training: Personnel Processing Personal Data receive ongoing training on data security, privacy protection, and compliance with applicable laws.
4. Data integrity: We regularly monitor and audit our systems to maintain data accuracy and prompt resolution of any unauthorised alterations or breaches.
5. Third-Party Service Providers: Service Providers Processing Personal Data on our behalf are required to implement robust security measures and comply with contractual and legal requirements.
6. Incident response: We maintain procedures to detect, investigate, and mitigate risks to your Personal Data in the event of a security incident or breach of your Personal Data. If required by law, we will notify you and the appropriate regulatory authorities as soon as feasible.
7. Notification of security incidents: If we experience a security incident affecting your Personal Data, we will notify you as soon as required by applicable law and provide guidance on protective measures you can take. If you suspect a security issue with your account, contact us using the details provided in the “Contacting Us” section immediately so we can investigate and mitigate potential risks.

Your Privacy Rights and Managing Your Personal Data

We Process your Personal Data in accordance with this Privacy Notice and our obligations under applicable privacy laws. We strive to address your privacy rights requests promptly and transparently, but our ability to act on specific requests depends on the privacy laws applicable to your jurisdiction. If you wish to exercise your rights concerning your Personal Data, please contact us using the details provided in the “Contacting Us” section.

When you submit a request regarding your Personal Data, we will follow these steps:

1. Acknowledge your request: We will promptly confirm receipt of your request and outline the next steps.
2. Authenticate your identity: To confirm that the request is from you or an authorised representative, we may authenticate your identity. This may involve verifying account credentials or requesting documentation to confirm your identity.
3. Verification: We may verify the details of your rights request against our records to determine whether we can fulfil the request accurately in compliance with legal or regulatory requirements.
4. Response: We will respond to your request within the timeframes required by applicable laws, either fulfilling it or providing an explanation if we cannot fulfil it (e.g., due to legal privilege, third-party confidentiality, business obligations requiring retention) along with additional steps you may take.

Your Privacy Rights:

We respect your privacy rights, which may vary based on your location. We make reasonable efforts to fulfil your requests under applicable law and, in other cases, as part of our commitment to providing a transparent and user-focused experience.

1. Access to Personal Data: You have the right to request access to the Personal Data we have collected about you. When making an access request, we will:
   • Provide a copy of your Personal Data, where required, in your preferred format, if feasible (e.g., a machine-readable or digital format).
2. Correction of inaccuracies: You can request corrections to inaccurate or incomplete Personal Data. When making a correction request, we will:
   • Verify and correct inaccurate or incomplete Personal Data in our systems, where required. If verification is needed, we may request supporting documentation before making changes.
3. Deletion of Personal Data: You may request that we delete your Personal Data. When making a deletion request, we will:
   • Promptly delete your Personal Data in our systems, where required.
4. Withdrawal of consent: You have the right to withdraw your consent to the Processing of your Personal Data at any time for activities that rely on your consent. Withdrawal of consent will not affect the lawfulness of Processing carried out before the withdrawal. However, withdrawing consent may prevent us from fulfilling services that require such consent. Please note the following:
   • Potential impact on services: Withdrawing consent may prevent us from providing certain services or products that require your consent.
   • Exceptions: In some cases, you may not be able to withdraw consent if Processing your Personal Data is:
     
     1. Required to comply with legal or regulatory obligations.
     2. Necessary to fulfil a contractual obligation.
     3. Justified by other lawful bases, such as our legitimate business interests.
5. Right to Restrict Processing: You have the right to request that we restrict the Processing of your Personal Data in certain circumstances, such as when the accuracy of the Personal Data is contested, or when you object to the Processing based on our legitimate interest.
6. Right to Personal Data Portability: You may request a copy of your Personal Data in a structured, commonly used, and machine-readable format, and may request that we transmit that Personal Data directly to another controller, where technically feasible.
7. Right to Object to Processing: You have the right to object to the Processing of your Personal Data where the Processing is based on our legitimate interests, including direct marketing purposes.

Promotional Communications

By providing us with your email address (e.g., by following, liking, or linking your account to our Mobile App or services on a third-party platform), you consent to receive promotional communications, such as newsletters, service updates, and special offers, only if you have explicitly opted in.

To withdraw consent for promotional communications (e.g., newsletters, special offers), use the “Subject Rights & Privacy Enquiries”. Withdrawing consent for promotional communications will not affect your receipt of essential service-related communications.

Service-Related Emails

Service-related communications are necessary to fulfil our contractual obligations to you and maintain the proper functioning and security of our services. You cannot withdraw consent for essential communications required for:

• Account management updates.
• Transaction confirmations.
• Security alerts and important notifications.
• Changes to terms, policies, or services.

Your Personal Data Responsibilities

Protecting Personal Data is a shared responsibility between us and our users, and you play an important role in maintaining its security. As part of this shared effort, you agree to:

1. Provide accurate and reliable Personal Data:
   • Ensure that the Personal Data you share with us is accurate, relevant, and reliable. Providing incorrect or outdated information may impact your experience and our ability to deliver services effectively.
2. Update and Delete Your Personal Data:
   • Keep your Personal Data up to date to maintain its accuracy and reliability. For example:
     • You can update details like your name, email, or phone number directly through your Company account settings where available.
     • If you require assistance or cannot make updates or delete your Personal Data directly, contact us via the “Contacting Us” section.
     • Cooperate with us when your data needs to be reviewed or updated for compliance with applicable Personal Data protection laws.
3. Protect Your Account:
   • Safeguard your login credentials by using strong passwords, enabling multi-factor authentication, and logging out of shared devices.
   • Monitor your accounts for suspicious activity and promptly update login details if you suspect unauthorised access.
   • Avoid phishing scams; Company will never request your credentials via email. Report suspicious communications to us immediately.

Third-Party Links on Our Site

The Site may contain links to third-party websites, plug-ins, services, social networks, or applications. By clicking on these links or enabling such connections, you may permit third parties to collect or share Personal Data about you. Please be aware that these third parties operate under their own privacy policies. We do not assume any responsibility or liability for their content or practices. As we do not control these third-party websites or services, we strongly recommend that you review the privacy policies of each website or service you access.

As a resource to you, we may have links on our Site to other websites that we do not operate. Our Privacy Notice does not apply to such third-party websites or organisations. If you click on a third-party link, you will be taken directly to that website which is governed by its own privacy notice. We strongly encourage you to read that privacy notice. We do not control that website and assume no responsibility for the content, policies, or its practices and your engagement with such websites or services is at your own risk.

Accessibility Statement

We strive to provide all individuals with access to information related to our Services, including this Privacy Notice. Please contact us using the details provided in the “Contacting Us” section if you would like this Privacy Notice provided in an alternative format. We will make reasonable efforts to accommodate your needs and make the information accessible to you.

Changes to the Notice

We regularly review this Privacy Notice and will update it from time to time. Any changes will be reflected in the “Last Reviewed” date above. It is your responsibility to review the Privacy Notice periodically to stay informed about any updates. Your continued use of our Services after any changes signifies your acceptance of the updated Privacy Notice. While we may notify you of significant changes via email or other communications, such notifications are not a substitute for your responsibility to regularly review this Privacy Notice.

Contacting Us

If you have any questions or comments regarding this Privacy Notice, or if you wish to submit a data subject rights request, please use our “Data Subject Rights & Privacy Enquiries Form” for prompt and accurate handling. You may also reach out to our Data Protection Officer using the following information:

Filing a Complaint

If you have concerns regarding your Personal Data, you may file a complaint with Janus’ Data Protection Officer using the “Data Subject Rights & Privacy Enquiries Form”. Janus will acknowledge receipt of your complaint, may contact you for clarification, and will conduct a confidential investigation. You will be informed of the findings, and if your complaint is justified, Janus will take appropriate corrective measures.

If you are located in the United Kingdom, you also have the right to lodge a complaint with the UK Information Commissioner’s Office:

If you are located in the European Economic Area, you have the right to lodge a complaint with the local supervisory authority. A list of national supervisory authorities is available at: https://www.edpb.europa.eu/about-edpb/about-edpb/members_en.

If you are a resident of a U.S. state with an applicable privacy law, you may also have the right to lodge a complaint with your state’s Attorney General or other designated privacy regulator. Please refer to your state privacy law or the regulator’s website for additional information.