Last Updated: Jun 11, 2022

Nothing in this Privacy Statement may be construed to create any obligation for the Company beyond what is required by applicable law.

This Privacy Statement (“Privacy Statement” or “Statement”) describes the practices of JCRAM CONSULTING LTD (“The Company” or “Equityram” or “we” or “us”) with respect to information, including Personally Identifiable Information (“PII” or Personal Data) (which means any information relating to an identified or identifiable natural person), and non-personally identifiable information (“non-PII”), we obtain from and about individuals interacting with us and our websites, mobile applications, products and services (collectively, our “Services”). This Statement does not apply to job applicants or Company employees.

This Privacy Statement only applies to the data processing activities of JCRAM CONSULTING LTD. This Privacy Statement does not apply to services, websites, or mobile apps offered by third parties, even if this site links to those services or third parties. We encourage you to read the privacy statements of every third-party website that collects your PII.

Please read the information below to learn about the information, including PII, collected about you and how it is used.

Changes to this Statement
We may change this Statement at any time by posting revisions to the Statement on our Services, including, without limitation, this site. Therefore, you should review the Statement from time to time. If you do not accept all of the terms, conditions, and notices set forth in the Privacy Statement, you must discontinue using the Services, which includes exiting this site immediately. The most current version of the Statement may be reviewed by clicking on the “Privacy Policy” link located at the bottom of our site.

Collection of Information from Children
We do not intentionally collect information from or regarding minors. The Services are not directed to or intended for use by children under the age of 18. Children may not use or submit any information through the Services or its sites. If you are under the age of 18, you may not use our Products or Services. If a child under 18 submits information through any part of the Services, and we become aware that the person submitting the information is a child, we will attempt to delete this information as soon as possible.

Information We Collect
We may collect two general types of information when you use our Services or interact with us:

Personally Identifiable Information (“PII”), which may include your first and last name, home or other physical address, telephone number, e-mail address, user id, other identifiers that permit physical or online contact with you, or any information about you collected online and maintained in personally identifiable form in combination with any of the preceding categories. You also may view or engage with our Services through third-party social networking sites or social media plug-ins and applications. When you engage with our Services and content through such third-party sites, plug-ins, or applications, we may have access to certain information from your social media profile, such as your name, photo, gender, birthday, location, videos, your list of friends, etc. This information is included in the definition of PII.

Non-personally identifiable information (“non-PII”) such as the type of browser you are using, the type of operating system you are using, the web pages you have visited sites visited before and after you use our Services, the type of handheld or mobile device used to access the Services or other device-specific information.

Certain features available within the Services will require you to submit PII about yourself as a condition of participation. Some of the features may be offered by us, while others may be offered by third parties. (For example, you may be required to submit PII in order to request information and offers from us and our partners.) When you choose to submit PII to a third party in connection with your use of the Services, the third party’s privacy policy, rather than this Statement, will control the use of your PII. YOU CAN ALWAYS REFUSE TO PROVIDE PII TO US, BUT THIS MAY RESULT IN DECREASED FUNCTIONALITY OF THE SERVICES FOR YOU AND LIMIT YOUR ABILITY TO RECEIVE INFORMATION ABOUT SERVICES THAT MAY BE OF PARTICULAR INTEREST TO YOU.

How Information is Collected
We collect information, both actively and passively. For example, we will collect information about you that you voluntarily provide while using our Services. In addition to the information provided directly by you, we (and third parties that offer features through the Services) may collect non-PII through the use of “cookies,” “web beacons,” “Flash cookies” or by other electronic means.

Cookies
In general, a cookie is a small amount of data sent to your browser from a web server and stored on your computer’s hard drive, where it can be used to identify your computer. Cookies can be used to measure website usage, improve navigation around websites, and personalize a returning visitor’s experience on the websites. In most cases, you can set your browser to turn off cookies or to notify you before you receive one so that you can decide whether to accept it or not. Because cookies allow you to take advantage of some of the features of the Services, we recommend that you leave them turned on. If you block or reject our cookies, some of the features of the Services may not work for you. You can refer to the instructions for your browser to learn more about these functions.

Web Beacons
We, our third-party service providers, advertisers, and partners, also may use “web beacons” or similar technologies. Web beacons are small strings of code placed on a web page to collect data about how visitors use the Services. For example, web beacons may be used to count the number of users who visit the Services or to deliver a cookie to the browser of a visitor to the Services. If you set your browser to turn off cookies, web beacons and similar technologies will detect your visits to the Services, but they will not associate your activity on the Services with information that otherwise would be stored in cookies. We do not control tracking technologies used by third parties with the Service.

Flash Cookies
The Services uses locally stored objects, also called “Flash cookies,” when it uses Adobe Flash Player (“Flash”) to provide special content such as video streaming, video on demand, video clips, or animation. Flash, and similar applications, use Flash cookies to remember visitors’ Services settings, preferences, and usages. Flash cookies are managed directly through Adobe’s websites, rather than through your web browser.

Third-Party Advertising and Third-Party Websites
These websites allow advertising by third parties that provide links to third-party websites. Internet advertising companies and the third-party websites on whose behalf they advertise (collectively “Third Parties”) may use the technology described above to send (or “serve”) directly to your browser the advertisements that appear on our Services. When this happens, Third Parties automatically receive non-PII, such as information from your computer and browser, including your cookie information. They also may use cookies, Javascript, Pixel Tags, and other technologies to deliver advertisements; collect information about the effectiveness of their advertisements; collect anonymous information about your visits to the Services, such as the number of times you have viewed an ad; or customize the advertising content you see. Third Parties will not collect your name, address, or other PII unless you affirmatively provide it to them. We let Third Parties set and access their cookies on your computer. Third Parties’ use of their own cookies is subject to their own privacy policies. For more information about these specialized cookies and other technologies, and to learn more about behavioral advertising, you can visit https://www.networkadvertising.org. You may review the instructions and/or the privacy settings for your operating system to find out how to opt out of tailored in-application advertisements.

Third-Party Links
Please note that our Services, including this site, contain links to other websites that do not follow this Privacy Statement. For instance, clicking on an advertisement, links, or other elements on the Services may take you to entirely different websites. Links to other websites may use our Services logo or style as a result of a co-branding agreement. These websites may send their own cookies to you and may collect data and make use of that data in ways that these Services would not. After you leave our Services, this Privacy Statement will no longer apply to PII or any other data collected from or provided by you. You should check the other websites’ applicable privacy policies to determine how they will handle such data.

How Information is Used and Shared
We use your PII for the purpose of conducting our business and pursuing our legitimate interests. For example, we use your PII to:

Facilitate communication from third parties to you at your request;
Create and manage your account;
Provide the products and services you request;
Enroll you in contests, programs or other offers you request;
Tell you about other products and services that may be of interest to you (you can opt-out of receiving such communications by following the instructions provided in the communication);
Process payments for purchases you have made;
Protect against or identify possible fraudulent transactions;
Analyze the use of our Services;
Develop new products and services;
Understand how you arrived at our Services;
Manage the Services, including this site;
Enforce our Terms & Conditions; and
Enforce the terms of our Privacy Policy.

Advertisements, Marketing Material, and Other Offers
Unless you tell us that you do not want to receive these offers and are subject to applicable law, the Company or those companies that we have a commercial relationship with may occasionally send advertisements, marketing material, or other offers that we think might be of interest to you. If you do not want to receive these advertisements, marketing material, or other offers, please contact us using the contact information found at the end of this Privacy Statement. Where required by law, we will seek your consent prior to sending you any marketing materials. To the extent allowed by law, the provision of your e-mail and phone number to us constitutes your prior express written consent, and electronic signature, authorizing us to contact you at that e-mail address and phone number, including through the possible use of an automatic telephone dialing system or artificial or prerecorded voice, live calls and text messages, for both promotional and informational reasons. You agree that this consent may be assigned by us to third parties and affiliates. You are not required to provide such consent in order to make a purchase as you can always contact us directly to arrange an alternate purchase method. By providing your telephone number to us, you certify that this is your own number that you own, and not a line owned or used by another and that you will immediately notify us if your number changes or is reassigned. You agree to indemnify us if this is not the case and if the future owner or user of the number makes a claim against us for contact at that number. You may opt out of such contact at any time and through any of the reasonable methods outlined herein.

In the event that Company is considering a sale of its business, in its entirety or a component thereof, or substantially all of its assets are acquired, or a portion thereof, PII and non-PII, may be one of the transferred assets, and may, therefore, be used by a third-party acquirer in accordance with this Privacy Statement. Such use by a third party may include a review of PII, using such PII to contact you either before or after such a transfer or sale, use or transfer of non-PII before or after such a transfer or sale, or for other purposes.

WE MAY DISCLOSE PII ABOUT YOU TO A THIRD PARTY FOR COMPENSATION.

In addition, we may share your information as described below:

Information You Elect to Share: You may choose to share information with Third Parties by clicking on links to those Third Parties from within the Services. In addition, you may elect to share information, including PII, through the Services, for instance, posting comments on comment boards. Some of your activity on the Services, including content you have posted, is public by default. Some of this content may include PII.

Third-Party Advertisers and Websites: We may share your non-PII with or make your non-PII available to, Third Parties, as described in the section above titled Third-Party Advertising and Third-Party Websites.

Information Disclosed to Vendors, Partners, Service Providers, and Others for Business Purposes: We contract with vendors to provide services related to the Services and may share PII with such vendors in order to provide products or services to you or to help maintain the Services. We also may share non-PII with our partners, service providers, and other persons with whom we conduct business. We will only share your PII in accordance with applicable law.

Information Disclosed for the Protection of the Services and for Others. We may disclose PII when (1) required by law or to respond to legal processes or lawful requests, including from law enforcement; (2) when we believe it is necessary to prevent, investigate, or address (a) possible illegal activities, including fraud, (b) violation of our Terms of Use, (c) violation of this Privacy Statement, or (d) threats to the physical safety of any person; or (4) to protect our rights or property.

Forums
The Services may include forums (such as message boards, chat rooms, comment boards, and reviews) that enable users to post a comment or communicate with each other. We are under no obligation to moderate or edit the forums and will not be responsible for the content or use of any material posted on any forum within the Services. We retain the right to delete at any time and for any reason any material posted within the Services.

Information Security
We take information security seriously, and we use reasonable administrative, technical, and physical safeguards to protect the PII we collect from unauthorized access, use, or disclosure. But we have no control over the security of other websites on the Internet that you might visit. If you share your computer or use a computer that is accessed by the general public, remember to sign off and close your browser window when you have finished your session. This will help to ensure that others cannot access your PII.

Additionally, and as you are likely aware, no system can be completely secure. Therefore, although we take commercially reasonable steps to secure your information, we do not promise, and you should not expect that your PII, searches, or other communications always will remain secure. In the event of a breach of the confidentiality or security of your PII, we will notify you if reasonably possible and as reasonably necessary so that you can take appropriate protective steps. We may notify you under such circumstances using the e-mail address(es) we have on record for you. You should also take care of how you handle and disclose your PII.

Your Rights
Under the law of some countries, you may have certain rights with respect to your PII. These rights include the right to (i) request access to and rectification or erasure of your PII; (ii) obtain restriction of processing or object to the processing of your PII; and (iii) ask for a copy of your PII to be provided to you or a third party in a machine-readable format. If you wish to exercise one of the above-mentioned rights, please send us your request to the contact details set out below. If you have unresolved concerns, you may also have the right to lodge a complaint about the processing of your PII with your local data protection authority in the European Union or elsewhere.

Your EU Privacy Rights
If you are using our Services from the EU or where applicable EU data protection laws so provide, you may exercise the following rights regarding your PII:

Access. You have the right to obtain from us confirmation if your PII is being processed and certain information in this regard.
Rectification. You have the right the request the rectification of inaccurate PII and to have incomplete data completed.
Objection. You have the right, when we process PII on the grounds of legitimate interests, to object to the processing of your PII for compelling and legitimate reasons relating to your particular situation, except in cases where legal provisions expressly provide for that processing. In addition, you have the right to object at any time when your PII is processed for direct marketing purposes.
Portability. You may receive the PII that you have provided to us in a structured, commonly used, and machine-readable format and have the right to transmit them to other data controllers without hindrance. This right only exists if the processing is based on your consent or a contract, and the processing is carried out by automated means.
Restriction. You may request to restrict the processing of your PII if (i) you contest the accuracy of it – for a period we need to verify your request; (ii) the processing is unlawful, and you oppose the erasure of it and request restriction instead; (iii) we no longer need it, but you tell us you need it to establish, exercise or defend a legal claim; or (iv) you object to processing based on public or legitimate interest – for a period we need to verify your request
Erasure. You may request to erase your PII if it is no longer necessary for the purposes for which we have collected it, you have withdrawn your consent, and no other legal ground for the processing exists, you objected, and no overriding legitimate grounds for the processing exist, the processing is unlawful, or erasure is required to comply with a legal obligation.
Right to lodge a complaint. You also have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of your residence, or the location where the issue that is the subject of the complaint occurred.
The right to refuse or withdraw consent. Please note that in case we ask for your consent to certain processing, you are free to refuse to give consent, and you can withdraw your consent at any time without any adverse negative consequences. The lawfulness of any processing of your PII that occurred prior to the withdrawal of your consent will not be affected.
Retention. We retain your PII for as long as you remain a customer and thereafter only for the period necessary to fulfill the purposes outlined in this Privacy Statement, unless a longer retention period is required or allowed by law, including to fulfill a legal obligation.

If you have questions about exercising any of those rights or their applicability to any of our particular processing activities or have questions about any data transfer mechanism or want a copy thereof, you may contact us at support@equityram.com.

Your Choices
If you do not wish to receive information regarding our products, services, special offers, and upcoming events, please click on the “Unsubscribe” link if it is shown on our e-mails and electronic newsletters to you or contact us at support@equityram.com and we will remove your name from our mailing lists. You may access your PII and correct, amend, or delete any of the PII you have provided to us on the Services by emailing us at support@equityram.com. Please include your name, address, and/or e-mail address when you contact us. It is possible that you may be denied access to your PII, or may not be able to delete all your PII. For instance, access can be denied when: giving one person access would compromise another’s privacy rights; disclosure is likely to interfere with the safeguarding of national security, defense, or public security, and disclosure could interfere with law enforcement or legal actions. These are only examples, and access may be denied in other situations in compliance with applicable laws. For additional information about EU rights, please see Section 21

Contact Information
Unless otherwise stated, JCRAM CONSULTING LTD is a data controller under applicable law for PII processed subject to this Statement. If you have any questions about this Statement or the Service, including any request to review or change your PII, or if you believe that your PII has been processed or disclosed in violation of this Statement, please contact us at support@equityram.com

We will investigate and attempt to resolve any complaints and disputes regarding the processing of your PII.