Privacy Policy

This privacy policy has been compiled to better serve those who are concerned with how their ‘Personally Identifiable Information’ (PII) is being used online. PII, as described in US privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personally Identifiable Information in accordance with our website.

Who we are

AJC is an advisory and accounting firm established in Vanuatu since 2003.

Our website address is: https://ajc-vanuatu.com

GENERAL PROVISIONS OF PRIVACY POLICY

Our company (hereinafter referred to as “AJC“) hereby declares that AJC strives to protect the personal information (hereinafter referred to as “Personal Information“) of our clients (hereinafter referred to as “User” or “Users“), always keeping the following in mind:

  • AJC appoints a person responsible for Personal Information protection in relation to Personal Information of Users, its business partners and its employees, and strictly protects such information by always conducting thorough employee education as well as enhancing internal control and system security.
  • If AJC acquires and uses the information of User, AJC uses such information within the minimum scope specified in the Terms of Use of AJC (hereinafter referred to as the “Terms“). AJC does not acquire, use or provide such information beyond such scope. Further, AJC takes necessary measures for such purposes.
  • AJC may provide or deposit the information of User to its business partners, under certain conditions, within the above scope, to improve its services or the convenience of User. In such case, AJC selects such partners who have a sufficient level of Personal Information protection, and implement such protection.
  • AJC diligent strives to maintain User information that is the most accurate and up-to-date. Upon User request, AJC will promptly act to ensure that any needed changes are made. If any erroneous information is found, AJC promptly corrects such information.
  • AJC takes necessary security measures against any threats such as unauthorized access to, or loss, destruction, falsification or leakage of Personal Information. If such threats become apparent, AJC strives to correct such security measures to deal with such threats.
  • AJC may send various useful information to User by different means (such as email, website notification, postal mail, etc). If User does not wish to receive such information, AJC promptly responds to the request for suspension of such sending by User.
  • AJC prevents any unauthorized external access by maintaining security measures for its systems such as firewalls. AJC concurrently uses “SSL encryption technology” and its unique encryption technology for data communications in relation to Personal Information. 
  • AJC complies with any and all laws, regulations, guidelines, codes or any other rules in relation to handling of Personal Information. AJC improves and operates its Personal Information protection management system by continuously reviewing it.
  • AJC conducts a periodic audit and strives to implement and observe its Privacy Policy.

PRIVACY POLICY

In this privacy policy (hereinafter referred to as “Privacy Policy“), AJC explains to Users how AJC collects, stores, uses and protects Personal Information of Users. With respect to any and all products, services, contents, functions, technologies or functionalities provided on AJC website (hereinafter collectively referred to as the “Services“), at the time when User subscribe to a newsletter, respond to a survey, fill out form or broadly use the Services, such User shall be deemed to have agreed to Privacy Policy and any collection, storage or use by AJC in relation to Personal Information of such User. Unless otherwise agreed by and between User and AJC, this Privacy Policy stipulates the use of the Services by User.

AJC may revise this Privacy Policy anytime, by posting such “revised Privacy Policy” on the website of AJC. Such revised Privacy Policy shall become effective on the date of release. If any important change is included in the revised Privacy Policy, AJC notifies Users of such change by advising of the same on the “Updates of Policy” section of its website at least 15 days prior to such change. User shall be deemed to have agreed to such revised Privacy Policy, at the time of termination of such 15-day notice period.

COLLECTION OF USER INFORMATION

When a user uses our Services, his/her IP address and standard log information such as type of browser used or pages accessed on the website of AJC are collected.

When using our Services, the following User information collected are contact information: name, address, phone number, citizenship, e-mail address and any other similar information…

While User is using our Services, AJC collects the information in relation to any activities on the website or use of our Services by such User. AJC may collect the information in relation to the computer or any other access devices of such User to prevent any unauthorized or wrongful act.

AJC does not collect credit card information.

What personal information do we collect?

We collect personal information that you explicitly fill in our forms, or when you subscribe to our newsletter.

We anonymously collect website usage and traffic information use such as your IP address, country of origin, page visited, etc.

When do we collect information?

We collect personal information from you when you subscribe to a newsletter, respond to a survey, fill out a form or enter information on our site. Anonymous website usage information is automatically collected through Google Analytics service.

How do we use your information?

We may use the information we collect from you when you register, make a purchase, sign up for our newsletter, respond to a survey or marketing communication, surf the website, or use certain other site features in the following ways:

• To personalize your experience and to allow us to deliver the type of content and product offerings in which you are most interested.
• To improve our website in order to better serve you.
• To allow us to better service you in responding to your customer service requests.
• To administer a contest, promotion, survey or other site feature.
• To send periodic emails regarding your order or other products and services.

How do we protect your information?

All communication between your browser and our server is encrypted with SSL.

We only provide articles and information. We never ask for credit card numbers.
We do not use Malware Scanning.

HANDLING OF SENSITIVE INFORMATION

AJC, in principle, does not acquire, use or provide to any third party any information in relation to political opinion, belief (religion, thought or faith), membership of labor union, race, ethnicity, origin, permanent legal domicile, healthcare, sex life and criminal history (hereinafter collectively referred to as “Sensitive Information“). AJC may acquire, use or provide to any third-party Sensitive Information within its necessary scope in any of the following cases (with strict management on the part of AJC):

  • if such acquisition, use or provision is based on laws and regulations, etc.;
  • if such acquisition, use or provision is necessary to protect life, body or property of any person;
  • if such acquisition, use or provision is especially necessary to enhance public health or promote sound development of children;
  • if AJC is required to cooperate with governmental institutions, local governments or their entrustees, for their performance of the affairs stipulated by laws and regulations;
  • if AJC acquires, uses or provides to any third-party Sensitive Information, to the extent necessary to perform transfer, etc. of any rights or obligations due to inheritance procedures;
  • if AJC acquires, uses or provides to any third-party Sensitive Information, on the basis of the consent of User, to the extent necessary to execute its operations, due to the necessity to ensure appropriate operations of AJC;
  • if AJC uses any biometric authentication information which is Sensitive Information, for identification of User, on the basis of the consent of such User.

USE OF COOKIES

When User accesses the AJC website or uses the Services, AJC (including its business partners) creates small data files in the computer or any other device of such User. Such data files may be a cookie, a pixel tag, or any other local storage provided by the browser or related applications used by such User (hereinafter collectively referred to as the “Cookie“).

AJC uses such Cookies for any of the following purposes:

• to provide the Services, contents or advertisements suited to the User;

• to measure promotional effects;

• to compile aggregate data about site traffic and website interaction;

• to reduce any risk and avoid any unauthorized use;

• to improve the reliability and security of the AJC website and the entire Services.

AJC’s Cookie can be refused if the browser or add-on of such browser used by User permits such refusal, unless such Cookie is necessary to prevent any unauthorized use or to ensure the security of the website managed by AJC. In the case of refusal of the Cookie, the use of AJC’s website or of the Services may be obstructed.

PROTECTION AND STORAGE OF PERSONAL INFORMATION

The term “Personal Information” in Privacy Policy means any information in relation to a specific individual which is usable to identify such individual. If such information includes any anonymous information where a specific individual cannot be identified, such information is not deemed to be Personal Information.

AJC securely stores and processes Personal Information of User in its computers located in Vanuatu and its server based in Sydney, Australia. AJC protects Personal Information of User by taking physical, electronic and procedural security measures. AJC takes security measures in relation to its computers such as firewalls or data encryption and controls any physical access to its buildings, facilities and files. Further, any permits for access to Personal Information are limited only to the employees who need such Personal Information to perform their duties.

RETENTION PERIOD OF PERSONAL INFORMATION

AJC will only retain your personal data:

  • for as long as it is necessary for the purpose for which it was intended;
  • for the purposes of performing or fulfilling a contractual obligation with your or the organization you represent;
  • for as long as required or permitted by the law.

USE OF COLLECTED PERSONAL INFORMATION

The first purpose of collecting Personal Information of User is to provide such User with a safe, smooth and efficient environment suited to such User. As a result, AJC uses Personal Information of User for any of the following purposes:

  • to provide you with the service you have requested;
  • to deal with communications that you send to AJC and responding to your queries, requests and complaints;
  • to solve objections or to solve problems;
  • to control risks, or to detect, prevent and/or correct any unauthorized act or any other potential prohibited or illegal act;
  • to detect, prevent or correct any breach of policies, the Terms or any other applicable terms;
  • to carry out the recruitment process;
  • to comply with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities;
  • to enhance the Services by customizing usage experiences of User;
  • to measure the results of the Services and to improve their contents and layout;
  • to manage and protect the information technology platform of AJC;
  • to conduct target marketing, to provide advertisements or service updates, or to distribute notices on campaigns, on the basis of the means of communication designated by User.

MARKETING

AJC does not sell or lend any Personal Information of User, without express consent of such User, to any third party.

AJC provides User with the Services, contents or advertisements suited to the applications of such User, by integrating the information of such User and the information collected from other companies, and strives to improve the quality and effect of such provision.

If you no longer wish to be contacted for marketing purposes, you may contact us at the contact information provided below.

SHARING OF PERSONAL INFORMATION WITH THIRD PARTY

Personal Information of User is shared with other third parties for any of the following purposes:

  • with its affiliated companies (hereinafter referred to as “Affiliated Companies“). Further, AJC uses such information for detection and prevention of any possible illegal acts or any breach of AJC policies, or for decisions in relation to the products, services or communications of such affiliated companies. Such affiliated companies deliver marketing communications to User by using such information, only if such User requests them to provide their services.
  • with law-enforcement institutions, governmental institutions or any other third parties in any of the following cases:
      • if AJC is obliged to disclose such Personal Information due to any subpoena, court order or any other similar legal procedures;
      • if AJC is required to disclose such Personal Information to comply with laws and regulations;
      • if AJC cooperates with any ongoing investigations of law-enforcement institutions;
      • if AJC considers in good faith that the disclosure of such Personal Information is necessary to avoid any physical harm or economic loss, to report any suspicious illegal acts or to investigate any breach of the Terms.
  • in the case of prevention of wrongful acts and risk management: In the course of AJC activities to evaluate and manage risks and avoid wrongful acts.
  • in the case of compliance with laws and regulations: AJC complies with verification obligations to prevent money laundering and funding to terrorists.
  • in the case of merger or acquisition, AJC requests the company which plans to merge with or acquire AJC to comply with the Privacy Policy in relation to Personal Information of Users. If User Personal Information is used in breach of Privacy Policy, AJC gives a prior notice to such User.
  • with service provider: AJC enables its contracted service providers to support a part of the business operations of AJC such as prevention of wrongful acts, collection of bill, marketing, customer service or technical service.
  • with User consent: personal Information of User is shared with any third party permitted or designated by such User in relation to such sharing.

User needs to acknowledge that such third party may be located in the country where the laws in relation to handling of Personal Information are laxer than the laws of the country of such User.

If User uses the Services directly on the website of any third party, the information entered by such User on such website (which is not the information directly entered in the Services) is shared with the owner of such website, and therefore such information needs to comply with the privacy policy of such third party. AJC shall not be liable for any handling of contents or information by such third party.

OVERSEAS TRANSFER OF PERSONAL INFORMATION

AJC undertakes best efforts to sufficiently protect Personal Information of Users, regardless of storage location of data, and strives to properly protect Personal Information of Users in transferring such information to overseas locations.

ACCESS TO AND CHANGE OF PERSONAL INFORMATION

If you have entered some Personal Information on AJC website, you can request the following:

  • right to access your personal information: if you want to review the data we hold, collect and process about you, please contact us at the contact information provided below.
  • right to rectification: if the data we hold, collect and process about you are inaccurate or incomplete, you have the right to update such data by contacting us at the contact information provided below.
  • right to erasure: if you decide that you do not want us to retain any personal data, we collected from you may request we delete your data by contacting us at the contact information provided below.
  • right to restriction of processing: you may contact us at the contact information provided below to withdraw any consent previously given to us and require us to stop processing your data.
  • right to object: you may object to certain types of processing. If you want so, you can contact us at the contact information provided below.
  • right to data portability: you may have the right to have your personal data transmitted directly from us to another controller only if you have asked us.
  • right to lodge a complaint with the supervisory authority: you have the right to lodge a complaint about the way we handle or process your personal data with your national data protection regulator.

Please be aware that these rights are not always absolute and there may be some situations in which, technically or legally, AJC may not be able to comply with your request.

Google

Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users. https://support.google.com/adwordspolicy/answer/1316548?hl=en

We use Google AdSense Advertising on our website.

Google, as a third-party vendor, uses cookies to serve ads on our site. Google’s use of the DART cookie enables it to serve ads to our users based on previous visits to our site and other sites on the Internet. Users may opt-out of the use of the DART cookie by visiting the Google Ad and Content Network privacy policy.

We have implemented the following:
• Remarketing with Google AdSense
• Google Display Network Impression Reporting
• Demographics and Interests Reporting
• DoubleClick Platform Integration

We, along with third-party vendors such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our website.

Opting out

Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add on.

California Online Privacy Protection Act

CalOPPA is the first state law in the USA to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require any person or company in the United States (and conceivably the world) that operates websites collecting Personally Identifiable Information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals or companies with whom it is being shared. – See more at: http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf

According to CalOPPA, we agree to the following:

Users can visit our site anonymously.
Once this privacy policy is created, we will add a link to it on our home page or as a minimum, on the first significant page after entering our website.
Our Privacy Policy link includes the word ‘Privacy’ and can easily be found on the page specified above.

You will be notified of any Privacy Policy changes:

• On our Privacy Policy Page

You can change your personal information:

• By emailing us

How does our site handle Do Not Track signals?

We honor Do Not Track signals and Do Not Track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.

Does our site allow third-party behavioral tracking?

It’s also important to note that we allow third-party behavioral tracking

COPPA (Children Online Privacy Protection Act)

When it comes to the collection of personal information from children under the age of 13 years old, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States’ consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.

We do not specifically market to children under the age of 13 years old.

Fair Information Practices

The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.

In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:
We will notify you via email within a reasonable number of days

We also agree to the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.

CAN SPAM Act

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

We collect your email address in order to:
• Send information, respond to inquiries, and/or other requests or questions
• Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.

To be in accordance with CANSPAM, we agree to the following:
• Not use false or misleading subjects or email addresses.
• Identify the message as an advertisement in some reasonable way.
• Include the physical address of our business or site headquarters.
• Monitor third-party email marketing services for compliance, if one is used.
• Honor opt-out/unsubscribe requests quickly.
• Allow users to unsubscribe by using the link at the bottom of each email.

If at any time you would like to unsubscribe from receiving future emails, follow the instructions at the bottom of each email and we will promptly remove you from ALL correspondence.

What rights you have over your data

If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

ACCESS TO AND CHANGE OF PERSONAL INFORMATION

If you have entered some Personal Information on AJC website, you can request to receive an exported file of such Personal Information, including any information you have provided to AJC, by emailing AJC. You can also request to rectify your Personal Information and that AJC erase any Personal Information held about you, by emailing AJC. This does not include any information AJC is obliged to keep for administrative, legal, or security purposes.

Contacting Us

If there are any questions regarding this privacy policy, you may contact us using the information below.

AJC
Govant Building, P.O. BOX 1276
Port Vila,
Vanuatu
contact@ajc-vanuatu.com

Last Updated October 18, 2016