<h2 id="1-general-provisions">1. General Provisions</h2>
Privacy Policy (hereafter «the Policy») is the present document, describing the rules and procedures of Virtual Users’ User Data processing, carried out by the Company during rendering services on fraud risk and other operational risks assessment for the purpose of financial, reputational and other losses reduction for Customer’s and Licensee’s businesses and services, carried out online via the Internet. It also describes the Company’s policy towards Personal Data Processing and describes the measures taken by the Company in order to ensure Personal Data security for protection of human and civil rights and liberties during one’s Personal Data Processing, including protection of rights to privacy and private life.
The Policy is valid from the 1st of June, 2024.
Policy application and limitation of liability of the Company This Policy applies to the Company software use released in the last 6 (six) months for front-end/data collection and testing libraries and 36 (thirty-six) months for back-end/scoring libraries. We constantly notify Customers/Licensees of the necessary updates and provide all necessary materials and assistance, including automatic update mechanisms for front-end libraries. We reserve the right to modify the present Policy anytime.
We kindly ask you to look through all the updates of our Policy on a regular basis.

1. General Provisions 

<h2 id="2-terms-and-definitions">2. Terms and Definitions</h2>
•	Authentication is a process of Virtual User or/and Virtual User Device probabilistic fingerprinting (digital ID) via analysis of User Data and comparison of User Device data and/or Virtual User Data with a set of different attributes and characteristics in order to identify fraud or other operational risk, which may lead to financial, reputational or other losses of the Customer or Licensee. This process is carried out without the use of Direct Identifiers and does not allow to identify the Virtual User.
•	Company (JCSC GLOBAL DIGITAL RISK MANAGEMENT SOLUTIONS L.L.C., we) is a legal entity registered in accordance with the legislation of UAE, license number 1072565. •	Company’s Feedback Form is an application form placed on Company’s Web Site designed for sending the requests to the Company from legal and natural persons regarding different cooperation issues.
•	Company’s Web Site is a web site generally available through the link <a href="https://jcsc.tech/">https://jcsc.tech/</a>. The web site is used for the posting of content about the Company for informational and other purposes.
•	Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.
•	Cookie is a file, which usually consists of letters and numbers, located on the Device and/or transmitted from server and loaded to the browser’s memory in the moment of submission or/and processing of the web site content. Cookie files allow the web site to identify the device of site visitor.
•	Customer or Licensee are legal entities or individual entrepreneurs, to whom the Company provides services under the contract and/or provides the license for the Service.
•	Data Subject is a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
•	Device is a mobile or stationary device with an Internet access used by a Virtual User to enter Web Resource.
•	Direct Identifier is a unique data attribute related to the Data Subject, which allows setting a univocal correspondence between the attribute and natural person.
•	Do Not Track is a HTTP-headline, which notifies whether a Virtual User informs about one’s willing/denial of tracking or monitoring of his actions on web sites or mobile application. •	Identification is a processing of natural person’s Personal Data in order to identify the attributes, which individually or collectively let to identify this natural person clearly and unambiguously.
•	Irreversibly Changed Value means a value obtained by irreversibly removing part of the original information and then hashing the rest of the information before analytical processing to avoid the possibility of restoring the original value.
•	JavaScript for the purposes of the present Policy is a software, based on the relevant programming language and included to the Service for User Data collection via Web Resource.
•	Modified Value is a value altered on Device by adding of dynamic variable alphanumeric character set and hashing; all alterations are performed before value processing by the Company software.
•	Natural Non-Randomness is a nonzero probability of randomly guessing a natural person.
·	Personal Account is a functionality within the secured part of the Services which is created for the Customer by the Contractor and allows receiving various technical information, statistics, and monitoring requests processing. •	Personal Data is any information relating to an identified or identifiable natural person (Data Subject).
•	Personal Data Processing means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
•	SDK in the present Policy means a software, based on the relevant programming language and included to the Service for User Data collection from iOS and Android-family Devices via native mobile application of a Customer or a Licensee, as well as via mobile application JS App — Device Risk Analytics. •	Service means combined elements of the infrastructure, server hardware and software used by the Company, which allow to estimate the risk of fraud or other operational risks arising from the formalized actions of a Customer’s or a Licensee’s User on the basis of User Data that do not allow to identify the User directly or indirectly.
•	Session (or JuicySession) is a unique identifier of Internet-session (which is not Direct Identifier), registered on a Web Resource which is formed on the Company’s servers and which is practically an enhanced token and does not contain Personal Data.
•	Soliciting Activity means measures aimed at receiving and processing of consumers’ requests for obtaining goods and services.
•	User Data is Virtual Users’ data, collected by means of program modules applied by respective Web Resource used by Virtual Users, which neither contain Direct Identifiers, nor allow to identify a natural person directly or indirectly without the use of data not collected using Service functionality applied on the Web Resource.
•	Virtual User (User) is a user of Web Resource of a Customer or a Licensee, which User Data is collected from correspondent Web Resource.
•	Web Resource is a web site, mobile application or any other resource of a Customer or a Licensee, which Virtual User may have access via the Internet.

2. Terms and Definitions

3.	User Data Processing

<h2 id="4personal-data-processing">4.	Personal Data Processing</h2>
<h3 id="41-purposes-of-personal-data-processing">4.1. Purposes of Personal Data Processing</h3>
The Company is a Controller with respect to Personal Data of Data Subjects specified in clause 4.2 herein.
Personal Data Processing is limited by achievement of specified, explicit and legitimate purposes.
The Personal Data shall be adequate, relevant and comply with the stated purposes of processing.
Personal Data Processing incompatible with the purposes of Personal Data collection is not allowed.
The Company does not process Personal Data during core service rendering to a Customer or during the license providing to a Licensee.
The Company processes Personal Data for the following purposes:
o	Signing a contract with Data Subject and its further performance;
o	Conducting Company’s personnel management and record keeping;
o	Corporate documentation and records maintenance in accordance with the legislation of UAE, recruitment;
o	Conducting economic and administrative activities;
o	Contact with the representatives of legal entity which is a potential user of Company’s services, advice on services, rendered by the Company;
o	Entering into and performance of the service agreement or license agreement;
o	Other legitimate purposes, provided for by applicable law.
<h3 id="42data-subjects">4.2	Data Subjects</h3>
The Company processes Personal Data of the following categories of Data Subjects:
o	Natural persons, who are job candidates;
o	Natural persons, who are Company’s founders or employees;
o	Natural persons, who are dismissed employees;
o	Natural persons, carrying out work under a contract;
o	Natural persons, who left one’s request in a feedback form on the Company’s Web Site;
o	Natural persons, who are contact persons of the companies – parties of the contracts executed;
o	Any other natural persons, provided consent for Personal Data Processing by the Company.
<h3 id="43legal-basis-of-personal-data-processing">4.3.	Legal Basis of Personal Data Processing</h3>
The Company processes Personal Data in strict compliance with the law.
Personal Data Processing shall be lawful only if and to the extent that at least one of the following applies:
o	the Data Subject has given expressed consent to the Personal Data Processing for one or more specific purposes;
o	Personal Data Processing is necessary for the performance of a contract to which the Data Subject is a party or in order to take steps at the request of the Data Subject prior to entering into a contract;
o	Personal Data Processing is necessary for compliance with a legal obligation to which the Company is subject;
o	Personal Data Processing is necessary in order to protect the vital interests of the Data Subject or of another natural person;
o	Personal Data Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Company;
o	Personal Data Processing is necessary for the purposes of the legitimate interests pursued by the Company or by a third party, or to achieve socially significant goals subject to non-infringement of fundamental rights and freedoms of Data Subject.
<h3 id="44data-subject-rights">4.4.	Data Subject Rights</h3>
The Data Subject has the right to:
o	Obtain the information related to one’s Personal Data Processing, including purposes of processing, categories of Personal Data concerned in order, form and terms set by Personal Data regulations;
o	Require: rectification of inaccurate Personal Data; to have incomplete Personal Data completed, including by means of providing a supplementary statement; erasure of Personal Data no longer necessary for the purposes for which they were collected or otherwise processed; restriction of processing of Personal Data concerning the Data Subject or to object to such processing;
o	Receive the Personal Data concerning him or her, which he or she has provided to a Company, in a structured, commonly used and machine- readable format;
o	Take the measures prescribed by law in order to protect one’s rights;
o	Withdraw a consent to Personal Data Processing;
o	Exercise any other rights provided for by the Personal Data regulations.
<h3 id="45personal-data-erasure">4.5.	Personal Data Erasure</h3>
Personal data Erasure is available through application submitted:
o	Via feedback form on the Company’s Web Site (<a href="https://jcsc.tech/">https://jcsc.tech/</a>);
o	Via the request in written form, send to the address Office №702-06, Emaar Square Building 6, Burj Khalifa Community, Dubai, UAE.
The Company commits to take all possible measures in order to implement the received applications to delete the Personal Data. The application consideration time shall not exceed 30 (thirty) calendar days from the moment of application submission.
Personal Data is to be erased upon reaching the purposes of Personal Data Processing or in case of Data Subject consent withdrawal of Personal Data Processing, provided that:
o	It has not been otherwise agreed in the contract, a party and beneficiary and guarantor of which is the Data Subject;
o	The Company has no right to process Personal Data without the Data Subject consent pursuant to national personal data legislation; o	It has not been otherwise stated by any other agreement between the Company and Data Subject;
o	Storage of Personal Data is required by laws and regulations (ex., data on salary, taxes, financial transactions).

4.	Personal Data Processing

<h2 id="5tracking-technologies">5.	Tracking Technologies</h2>
<h3 id="51-technologies-used-on-companys-website">5.1 Technologies used on Company’s Website</h3>
We use various tracking technologies on Company’s Web Site, such as scripts for collection and processing of information related to Web Site visitors while they stay on the Web Site, such as IP address, location (country or city), type and version of Device operating system, type and version of Device browser, type and resolution of the display, source of traffic, operating system and browser language and others.
Cookies are not used on the Company’s Web Site in the meaning of files, stored in the relevant section Document.Cookies, LocalStorage, SessionStorage of browser database. Alternative tracking technologies are not used on the Company’s Web Site, such as persistent sessions in IndexedDB, Device Fingerprinting, ETag marks.
Types of tracking technologies used on the Company’s Web Site:
o	IndexedDB, storage period is constantly. This method of persistent sessions use is set up on the feedback form in order to enable data deletion upon request;
o	Device Fingerprinting, storage period is 3 months. Device Fingerprinting mechanism is set up on the feedback form in order to enable data deletion upon request. In the SDK settings, it is possible to disable Device Fingerprinting tools that are based on graphics and media and are different from the basic ones accepted in the financial sector, as well as to disable different types of Device Fingerprinting formed on the Virtual User’s Device (for a more detailed description, please refer to the Company’s technical documentation provided during the execution of the agreement concluded with the Customer/Licensee).
Please note that the use of User Data solely to assess the risk of fraud or other operational risks in order to reduce financial, reputational or other losses for the businesses and services of the Customer or the Licensee, as well as for security purposes, is not regarded by the Company as tracking, therefore the value of the Do Not Track flag is not taken into account during the operation of Sessions and data collection software modules running on the Web Resource.
If the storage of constant session (persistent session) in browser memory of User’s Device infringes requirements of personal data legislation established in legal jurisdiction of a Customer or a Licensee, this technology may be disabled.
<h3 id="52-technologies-used-for-customers-licensees-personal-account-functionality">5.2. Technologies used for Customer’s/ Licensee’s Personal Account functionality</h3>
The Company uses Cookies to maintain the operation of the Customer/Licensee&#39;s Personal Account, created for interaction with the Customer/Licensee under the concluded agreement. At the same time, the Customer/Licensee is required to obtain the consent of individuals whose contact details are indicated in agreement with a Customer / Licensee and who interact with the Company through the Personal Account to process personal data and transfer such data to the Company in order to fulfill obligations under concluded contracts.
For Customer’s / Licensee’s Personal Account protection persistent sessions (IndexDB and Device Fingerprinting) are applied, application instructions are described in clause 5.1 herein. 
<h3 id="53-how-to-delete-cookies-from-your-browser">5.3. How to delete Cookies from your browser?</h3>
You can withdraw your consent to Cookies storage by changing your browser settings.
You can find the instructions about Cookies management, published by providers of Microsoft Edge, Google Chrome, Safari (for computers, mobile devices), Firefox, respectively.

5.	Tracking Technologies

<h2 id="6data-storage-and-protection">6.	Data Storage and Protection</h2>
<h3 id="61personal-data-andor-user-data-protection-measures">6.1.	Personal Data and/or User Data Protection Measures</h3>
The Company takes all the necessary legal, organizational and technical measures in order to protect the collected data from unauthorized, illegal or accidental access, deletion, changing, blocking, copying, providing, distribution of data, to which may refer:
o	Limitation and regulation of the staff, who have access to the Personal Data and/or User Data via the Feedback form on the Company’s Web Site;
o	Designation of a person responsible for organization of Personal Data and/or User Data Processing; designation of a person responsible for security of Personal Data or/and User Data;
o	Familiarization of employees who are directly in charge of Personal and/or User Data processing with the provisions of the applicable legislation and this Policy; o	Organization of accounting, storage and circulation of media, which contain the information about Personal and/or User Data;
o	Identification of threats to Personal Data security during its processing, threat models developing;
o	Personal Data protection system development on the basis of threat models;
o	Testing of readiness and effectiveness of the information security tools use;
o	Control of users’ access to the informational resources, software and hardware information processing tools;
o	Registration and accounting of information systems users’ activities;
o	Information system access password protection;
o	Physical division of Personal Data and User Data storage and processing systems and preventing of combined storage, processing or/and any other activities;
o	Application of instruments for control of access to communicational ports, output information devices, removable media as well as external memories;
o	Antivirus control; application of firewall; information backups;
o	Provision of data recovery, modified or deleted in the result of illegal access.
<h3 id="62personal-data-and-user-data-storage">6.2.	Personal Data and User Data Storage</h3>
Personal Data storage is carried out in a manner that allows to identify the Data Subject and for a period no longer than it is required for the purposes of Personal Data Processing unless otherwise provided for by applicable Personal Data regulations. The terms of Personal Data storage are established subject to compliance with requirements of Personal Data regulations or provisions of a contract, party and beneficiary or guarantor of which is the Data Subject. Personal Data is to be deleted after the expiration of the storage period unless otherwise is required by laws and regulations.
User Data collected from Web Resource, in respect of which there was NO request to the Service for User risk assessment from a Customer or a Licensee, are stored for not more than 30 (thirty) days from the moment of collection.
User Data collected from the Web Resource in respect of which there was a request from a Customer or Licensee for User risk assessment, is stored for not more than 2 (two) years from the moment of collection.
In order to comply with the applicable legislation or/and current business practices and regulations all the raw data, including User Data, are localized in the following regions of the use of Service (determined on the basis of Virtual User IP address location): USA, European Union, UAE, Singapore, India and other locations. For data processing and storage, the Company uses physical infrastructure within its network, situated in the regions of the Service use. Moreover, all Customers and Licensees are provided with the functionality of forced raw data localization in one of selected global locations including UAE.
The Company is not the owner of User Data, processed in Company’s IT-systems and provides its secure storage basing on the service contract, signed with a Customer or license contract signed with a Licensee.

6.	Data Storage and Protection

<h2 id="7contact-us">7.	Contact Us</h2>
JCSC GLOBAL DIGITAL RISK MANAGEMENT SOLUTIONS L.L.C. (license number 1072565)
Registered and mailing address: Office №702-06, Emaar Square Building 6, Burj Khalifa Community, Dubai, UAE
E-mail address for messages on Personal Data Processing and User Data issues: <a href="mailto:info@jcsc.tech">info@jcsc.tech</a>.

7.	Contact Us

Mobile Privacy Policy

JCSC Mobile Privacy Policy.pdf

JCSC Mobile Privacy Policy

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1. General Provisions

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