At The Juju, we value honesty and transparency. We are committed to building a strong and lasting relationship with our clients, suppliers, and employees, based on trust and mutual benefit; that is why we take responsibility for protecting personal data and their privacy, and for complying with national and international privacy laws.
This Personal Data Protection Policy provides a common framework for the protection of information that Data Subjects have entrusted to The Juju, with the intent to exclusively collect the information that has been voluntarily provided for the purpose of carrying out its activities and providing its services.
The Juju commits to keeping any personal data confidential and to strictly limiting any disclosure in accordance with applicable local laws and regulations.
This information may be obtained through any of the following channels or means: commercial or professional relationship; execution of services; employment relationship; and sending emails requesting information.
Additionally, The Juju may also access other data related to the Data Subjects (as defined below) from information available in public/private databases.
The Juju does not collect or manage files, banks, or records that store information related to personal data, except to contact the data subjects, fulfill legal or contractual obligations, or send information of interest regarding activities carried out in compliance with its corporate purpose.
This Personal Data Protection Policy applies to The Juju in Argentina, Colombia, Mexico, Peru, and the United States (“The Juju”) and establishes the guidelines that these companies follow for the collection, processing, use, distribution, transfer, and storage of personal information of Employees, Candidates, Clients, Suppliers, or any other person whose personal information is processed by The Juju.
This Personal Data Protection Policy informs about our data protection and privacy practices, as well as how personal data is collected and utilized by The Juju.
The purpose of this policy is to establish the criteria for the collection, storage, use, circulation, and deletion of personal data handled by The Juju.
The Juju is responsible for processing the data of Employees, Candidates, Clients, Suppliers, and any other person whose personal information is processed by The Juju. To find out which company is responsible for data processing in your country of residence, you can consult Annex “A” corresponding to that country, which is located at the end of this text.
The data processor is the entity that decides on the processing of personal data. This Policy outlines the purposes or uses for which personal information will be utilized and the means that will be used for such processing.
The Juju collects and uses personal data after providing notice and obtaining consent, and after adequately informing the individual about the purpose of such collection.
“Personal data” refers to any information relating to a natural person that identifies or makes that person identifiable (a person is identifiable when they can be identified, directly or indirectly, by an identifier – such as a name, location data, or one or more specific factors of the physical, mental, economic, physiological, genetic, cultural, or social identity of that person).
This Policy does not cover anonymous personal data, meaning data that does not allow the identification of an individual or that only allows that individual to be identifiable by incurring disproportionately large expenses in time, cost, or effort.
The types of personal data that The Juju may collect include: full name, surname, age, place of birth, nationality, personal and tax identification numbers, marital status, image, signature, occupation, email address, mobile and/or landline phone number; educational, professional, financial, and asset history; interests; user ID and password for The Juju (when applicable); IP address.
The Juju may collect personal data to carry out the following operations:
The Juju is committed to treating personal data in a fair, legal, and transparent manner.
The Juju will only process personal data for specific and legitimate purposes and will refrain from any further processing incompatible with those purposes. This means only collecting personal data that is relevant and not excessive for the purposes for which it is needed and used.
The Juju will ensure that the personal data processed is adequate, relevant, and not excessive concerning the purposes for which it was collected. In other words, data collected and processed will be strictly necessary to achieve the stated purpose.
The Juju will process personal data only if the data subject has provided free, explicit, and informed consent, which must be documented in writing or by another means that is legally equivalent, according to the circumstances.
The Juju will require prior authorization from its clients, suppliers, and employees for the processing of personal data provided to The Juju within the framework of the contractual relationship established with The Juju.
Exceptions to the Prior and Express Authorization of the Data Subjet:
Authorization will not be required when the data, unless local regulations state otherwise:
The Juju will ensure that:
The Juju will take appropriate technical and organizational security measures to keep data secure and to prevent unauthorized access, illegal processing, and unauthorized or accidental loss, destruction, or damage to personal data.
The Juju adopts the necessary measures to ensure the security and confidentiality of personal data, to prevent its alteration, loss, unauthorized access, or processing, and to detect intentional or unintentional deviations of information, regardless of whether the risks arise from human actions or the technical means used.
Data Will be destroyed or archive once it is no longer strictly necessary or relevant to the purposes defined in point 2 or as determined by current regulations.
The Juju requires the signing of confidentiality agreements by personnel, third parties providing services, and any officials accessing the content of the databases.
Sensitive personal data refers to information that affects the privacy of the Data Subject or whose misuse can lead to discrimination, such as data revealing racial or ethnic origin, political orientation, religious or philosophical beliefs, membership in unions, social organizations, human rights organizations, or those promoting the interests of any political party or guaranteeing the rights and guarantees of opposition political parties, as well as data relating to health, sexual life, and biometric data. Data relating to minors is also recognized as sensitive.
The Juju will never require anyone to provide sensitive data.
Sensitive data may only be collected and processed when justified by authorized reasons of general interest. They may also be processed for statistical or scientific purposes when the data subjects cannot be identified.
The formation of files, banks, or records that store information that directly or indirectly reveals sensitive data is prohibited, unless there is consent from the data subjects.
Data relating to criminal or contraventional records may only be processed by the competent public authorities within the framework of the relevant laws and regulations.
A transfer to a third country or an international organization of personal data that is being processed or intended to be processed after such transfer may only occur if adequate safeguards or other specific exceptions are in place. Data transfer rules apply to internal transfers within The Juju as well as to external transfers.
The personal data collected by The Juju may be communicated/transferred to:
The Juju will require those who transfer personal data to comply with appropriate standards of confidentiality, protection, and security, especially when third parties are in countries that do not have adequate data protection legislation according to the parameters established by the authorities and local regulations.
Data subjects may exercise their rights of access, rectification, deletion, and confidentiality regarding their personal data. For this, please consult Annex “A” corresponding to your country.
Requests for the exercise of the rights mentioned in the previous point and/or any questions related to this Personal Data Protection Policy may be sent to the addresses listed in Annex “A” for your country.
The Juju guarantees that:
The websites owned by The Juju do not use cookies and comply with GDPR. Furthermore, The Juju has no way of identifying the IP address of users or visitors.
The Juju reserves the right to modify this Personal Data Protection Policy as necessary, for example, to comply with changes in laws, regulations, practices, and procedures of The Juju, or requirements imposed by data protection authorities.
In such cases, The Juju will inform candidates and other individuals of any significant changes to this policy. The Juju will publish all changes on relevant internal and external websites.
ARGENTINA
In Argentina, The Juju is the data processing responsible through: THE JUJU S.A. (CUIT: 30-71400935-0).
The data subject has the right to obtain clear, transparent, and understandable information about how we use their personal data and about their rights.
The data subject may withdraw their consent for our processing of their data when such processing is based on consent. The withdrawal of consent will not affect the legality of the processing based on consent prior to its withdrawal.
The data subject can inquire about what personal data The Juju holds about them.
If the personal data is inaccurate, erroneous, or incomplete, the data subject may request that it be modified.
The data subject may request deletion of their personal data were permitted by applicable data protection laws and regulations.
The data subject has the right to object at any time to the processing of their personal data by The Juju when such processing is based on legitimate interest, and to request the restriction of the processing of their personal data when authorized by applicable data protection laws and regulations.
If the data subject meets the conditions established by applicable data protection laws and regulations, they have the right to receive a subset of their personal data and to transmit it from The Juju to another data controller. They may also request the direct transmission from The Juju to another controller when technically feasible.
The data subject has the right to contact the National Directorate of Personal Data Protection, the regulatory body for Law 25.326, to file a complaint regarding The Juju’s data protection and security practices.
The data subject can exercise their rights regarding their personal data by sending a postal letter to Monroe 899, Autonomous City of Buenos Aires, Argentina (C1428BKC) – attention: Compliance of THE JUJU, or by sending an email to legales@untold.email. In any case, they must send the request to exercise their rights along with a legible copy of their identification document.
The Privacy Policy and Annex “A,” with respect to Argentina, regarding the interpretation, validity, execution, or compliance thereof, you and The Juju declare that you submit to the exclusive jurisdiction of the competent Courts of the Autonomous City of Buenos Aires, expressly waiving any other venue and/or jurisdiction that may correspond to you.
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COLOMBIA
In Colombia, The Juju is the data processing responsible through: THE JUJU S.A.S (NIT: 901.264.146-8), email legales@untold.email
Personal Data: Any information linked to or that can be associated with one or several identified or identifiable natural persons, such as names, landline and mobile numbers, email addresses, identification numbers, among others.
Data Processing Responsible: Natural or legal person, public or private, that by itself or in association with others carries out the processing of personal data on behalf of the Data Processing Responsible.
Personal Data Processing Policy: The document that establishes the terms, conditions, purposes, and duration to which the processing of the data will be subject by the Data Processing Responsible.
Data Controller: P Natural person whose personal data is subject to processing, i.e., the owner of the information processed by the data controller.
Treatment: Any operation or set of operations that are performed on personal data, are treatment operations: the collection, storage, use, circulation or deletion.
The Juju will process any inquiries or complaints regarding the Personal Information collected and processed through the designated channels in accordance with the procedure established in Articles 14 and 15 of Law No. 1581 of 2012.
The data subject may exercise their rights regarding their personal data by sending a postal letter to – Street 100 No. 7 – 33, Tower 1, Office 601, Bogotá D.C., Colombia (C110911) – attention: Compliance of THE JUJU, or by sending an email to legales@untold.email. In any case, they must send the request to exercise their rights along with a legible copy of their identification document.
These rights may be exercised by the data subject, their beneficiaries, or anyone explicitly authorized by the data subject for this purpose.
The maximum term established by law to resolve your complaint is 15 business days, counted from the day following the date of receipt. When it is not possible to address the complaint within this timeframe, the respective company of The Juju will inform the interested party of the reasons for the delay and the date on which their complaint will be addressed, which shall not exceed 8 business days following the expiration of the initial term. Once the terms specified by Law 1581 and any other regulations that govern or complement it have been fulfilled, the data subject whose rights of access, rectification, deletion, and revocation have been denied, in whole or in part, may bring their case to the Superintendency of Industry and Commerce – Delegation for the Protection of Personal Data.
The Juju, in compliance with the provisions of the General Data Protection Regulation in Colombia, will proceed to correct, update, rectify, or delete personal data at the request of the data subject or their representative, fulfilling the legal requirements.
If the request is incomplete, The Juju will require the interested party, within five (5) business days from the date of receipt, to remedy the deficiencies.
The requested information must be presented by the requester within two (2) months following the request; if not provided, it will be understood that the requester has withdrawn their request.
The maximum term for The Juju to address the request is fifteen (15) business days, counted from the day following the date of receipt. When it is not possible to attend to the request within this timeframe, the interested party will be informed of the reasons for the delay and the date on which their request will be addressed, which cannot exceed eight (8) business days following the expiration of the initial term.
The deletion of personal data will not be granted based on a request made by the data subject or their representative when there is a legal or contractual obligation for personal data to remain in the respective database.
The Juju seeks not to collect information from minors under the age of 18 in the course of its economic activity. Their data may only enter our databases with the express consent of the minor’s legal representative.
Notwithstanding the above, in the event that we receive data from minors, such data will be subject to the rules outlined below.
The processing of personal data of children and adolescents is prohibited unless it concerns publicly available data, in accordance with Article 7 of Law 1581 of 2012, and provided that such processing meets the following parameters and requirements:
If the above requirements are met, the legal representative of the child or adolescent will grant permission prior to the exercise of the minor’s right to be heard, an opinion that will be valued considering the minor’s maturity, autonomy, and ability to understand the matter.
According to the Colombian Constitutional Court, the personal data of individuals under the age of 18 may be processed as long as the prevalence of their fundamental rights is not jeopardized, and it unequivocally fulfills the principle of protecting their best interests. Nonetheless, any collection and use of data from minors registered in The Juju’s databases, or that may be requested, requires the express authorization of the child’s legal representative, giving them the opportunity to exercise the rights of access, cancellation, rectification, and opposition concerning the data of their dependents.
Every responsible and authorized party involved in the processing of personal data of children and adolescents must ensure its proper use. For this purpose, the principles and obligations established in Law 1581 of 2012 and the regulatory decree must apply.
Families and society must ensure that those responsible for the processing of minors’ personal data comply with the obligations set forth in Law 1581 of 2012 and the regulatory decree.
In light of the above, The Juju will only process data from minors with the respect of the principles mentioned in obtaining authorization and as long as the best interests of the minors are respected in the processing of that data.
The Privacy Policy and Annex “A,” with respect to Colombia, shall be governed by the laws of the Republic of Colombia. In the event of any dispute or disagreement regarding the interpretation, validity, execution, or compliance thereof, you and The Juju declare that you submit to the exclusive jurisdiction of the competent Courts of the City of Bogotá, expressly waiving any other venue and/or jurisdiction that may apply.
The competent authority in the Republic of Colombia for the protection of personal data is the Data Protection Delegation of the Superintendence of Industry and Commerce, and the applicable regulations regarding data protection are Law 1581 of 2012, Decree 1377 of 2013, and other related norms.
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MÉXICO
In Mexico, The Juju is the data processing responsible through: THE JUJU AGENCY S.A. DE C.V. with R.F.C. – JAG200903TC0.
The data subject has the right to obtain clear, transparent, and understandable information about how we use their personal data and about their rights.
The data subject can inquire about what personal data The Juju holds about them.
If personal data is inaccurate, erroneous, or incomplete, the data subject may request modifications.
The data subject can request the cancellation of their personal data when allowed by applicable data protection laws and regulations.
The cancellation of personal data will lead to a blocking period, after which the data will be deleted. The Juju may retain it exclusively for the purposes of liabilities arising from processing.
When personal data has been transmitted prior to the date of rectification or cancellation and continues to be processed by third parties, the responsible party must inform them of the rectification or cancellation request, so they can also process it.
The Juju will not be obliged to cancel personal data when:
The data subject has the right to object at any time to the processing of their personal data by The Juju.
The data subject has the power to receive the personal data they have provided to The Juju and transfer it to other controllers without hindrance from the previous one.
In this case, The Juju will provide their data in a structured, commonly used, and machine-readable format.
The data subject may exercise their rights regarding their personal data by sending a postal letter to THE JUJU AGENCY S.A. DE C.V. at Av. Álvaro Obregón 171, Colonia Roma Norte, Cuauhtémoc, Mexico City (C06700) – attention: Compliance of THE JUJU, or by sending an email to legales@untold.email. In any case, they must send the request to exercise their rights along with a legible copy of their identification document.
The Privacy Policy and Annex “A,” with respect to Mexico, shall be governed by the laws of the United Mexican States. In the event of any dispute or divergence related to the interpretation, validity, execution, or compliance thereof, you and The Juju declare that you submit to the exclusive jurisdiction of the competent Courts of Mexico City, expressly waiving any other venue and/or jurisdiction that may correspond to you.
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PERÚ
In Peru, The Juju is the data processing responsible through THE JUJU AGENCY S.A.C. (RUC: 20608591762).
Data subjects may exercise their rights regarding their personal data by sending a postal letter to Av. El Derby Nº 254, Office 2202, Santiago de Surco, Lima (C15023) – attention: Compliance of THE JUJU, or by sending an email to legales@untold.email. In any case, they must submit their request to exercise their rights along with a legible copy of their identification document.
The Privacy Policy and Annex “A,” with respect to Peru, shall be governed by the laws of the Republic of Peru. In the event of any dispute or divergence related to the interpretation, validity, execution, or compliance thereof, you and The Juju declare that you submit to the exclusive jurisdiction of the competent Courts of Lima, expressly waiving any other venue and/or jurisdiction that may apply to you.
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ESTADOS UNIDOS DE AMÉRICA
The Juju Agency LLC is in charge of your personal data.
You have the right to:
You may request a copy of the following: (1) The categories of Personal Information we collected about you; (2) The categories of sources from which the Personal Information is collected; (3) The business or commercial purpose for collecting or selling (if applicable) the Personal Information; (4) The categories of third parties with whom we share Personal Information and the categories of Personal Information shared; and (5) The specific pieces of your Personal Information we have collected, used or disclosed (if applicable).
You may request that we delete your Personal Information. Note that deletion requests are subject to certain limitations, for example, we may retain Personal Information as permitted by law, such as for tax or other record keeping purposes.
You have the right not to be discriminated against in service or price if you exercise your privacy rights, and we will love you just as much if you do exercise them. To request a copy of Personal Information we have collected about you, or to request that your information be deleted, please send an email to legales@untold.email. You will need to provide your name, email address, and country / state of residence. You may authorize another person (your “agent”) to submit a request on your behalf.
To submit a request via e-mail phone, contact +1 (347) 371 0818. To submit a request via e-mail: legales@untold.email.