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RJV TECHNOLOGIES LTD PRIVACY POLICY
Document Version: 1.0
Effective Date: January 1, 2026
Last Updated: July 2, 2025
Document Classification: Public Policy
Approval Authority: Chief Executive Officer
Review Cycle: Annual
Next Review Date: January 1, 2027
CHAPTER I: FOUNDATIONAL PROVISIONS AND DEFINITIONS
Section 1.1: Policy Commitment and Scope
RJV Technologies Ltd, a company incorporated under the laws of England and Wales with company registration number 11424986 having its registered office at 21 Lipton Road, London, E1 0LJ (hereinafter referred to as “RJV Technologies”, “the Company”, “we”, “us” or “our”), hereby establishes this Privacy Policy as a legally binding document that governs the collection, processing, storage, transfer, disclosure and deletion of all forms of personal data and personally identifiable information processed by or on behalf of the Company in connection with its business operations, products, services, websites, mobile applications and any other digital platforms or technologies operated, controlled or administered by the Company.
This Privacy Policy applies universally to all natural persons who interact with RJV Technologies in any capacity whatsoever including but not limited to customers, prospective customers, website visitors, mobile application users, employees, contractors, consultants, vendors, suppliers, business partners, shareholders, directors, officers, agents, representatives and any other individuals whose personal data may come into the possession or control of RJV Technologies through any means whether directly or indirectly, intentionally or inadvertently, actively or passively, electronically or otherwise.
The Company recognizes that privacy is a fundamental human right and commits to implementing privacy-by-design principles throughout all aspects of its operations, ensuring that data protection considerations are embedded into every business process, technological implementation and strategic decision from conception through execution and beyond.
Section 1.2: Comprehensive Definitions
For the purposes of this Privacy Policy the following terms shall have the meanings ascribed to them below which definitions shall be interpreted broadly to ensure maximum protection of individual privacy rights:
“Personal Data” means any information relating to an identified or identifiable natural person including but not limited to names, addresses, telephone numbers, email addresses, identification numbers, location data, online identifiers, biometric data, genetic data, financial information, health information, employment information, educational records, communication content, behavioural data, preferences, characteristics and any other information that alone or in combination with other information could reasonably be used to identify, contact or locate a specific individual whether such information exists in electronic, physical or any other format.
“Sensitive Personal Data” means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data processed for the purpose of uniquely identifying a natural person, data concerning health, data concerning a natural person’s sex life or sexual orientation, criminal convictions and offenses, financial information, social security numbers, passport numbers, driver’s license numbers and any other information designated as sensitive under applicable data protection laws.
“Processing” means any operation or set of operations performed on personal data or sets of personal data, whether or not by automated means including collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure by transmission, dissemination, making available, alignment, combination, restriction, erasure, destruction and any other handling of personal data.
“Data 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.
“Data Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the data controller.
“Data Subject” means any identified or identifiable natural person whose personal data is processed by or on behalf of RJV Technologies.
“Third Party” means any natural or legal person, public authority, agency, or body other than the data subject of RJV Technologies and persons who under the direct authority of RJV Technologies are authorized to process personal data.
“Consent” means any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which they, by a statement or by clear affirmative action, signify agreement to the processing of personal data relating to them.
Section 1.3: Legal Framework and Compliance Standards
This Privacy Policy has been developed to ensure full compliance with all applicable data protection and privacy laws, regulations, and standards worldwide, including but not limited to the General Data Protection Regulation (GDPR) of the European Union, the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), the Personal Information Protection and Electronic Documents Act (PIPEDA) of Canada, the Privacy Act 1988 of Australia, the Personal Data Protection Act of Singapore, the Lei Geral de Proteção de Dados (LGPD) of Brazil, the Personal Information Protection Law (PIPL) of China, the Data Protection Act 2018 of the United Kingdom and any other applicable federal, state, provincial, territorial or local privacy and data protection laws that may govern the processing of personal data.
RJV Technologies acknowledges that data protection laws continue to evolve globally and commits to continuously monitoring legal developments and updating this Privacy Policy as necessary to maintain compliance with emerging regulatory requirements and to incorporate industry best practices as they develop.
CHAPTER II: DATA COLLECTION PRACTICES AND METHODOLOGIES
Section 2.1: Categories of Personal Data Collected
RJV Technologies collects personal data through various channels and mechanisms in connection with the provision of its services, operation of its business and fulfilment of its legal and contractual obligations.
The categories of personal data collected include but are not limited to:
Identity and Contact Information: Full legal names, preferred names, aliases, nicknames, titles, gender, date of birth, age, nationality, citizenship status, passport numbers, national identification numbers, driver’s license numbers, residential addresses, business addresses, mailing addresses, telephone numbers (mobile, landline, fax), email addresses, social media handles and profiles, emergency contact information and any other information necessary to identify and communicate with individuals.
Professional and Employment Information: Job titles, employer information, work addresses, work telephone numbers, work email addresses, professional qualifications, educational background, employment history, professional licenses and certifications, business affiliations, industry classifications, salary information, compensation details, performance evaluations, disciplinary records and any other employment related information.
Financial and Transaction Information: Bank account details, credit card information, payment card numbers, billing addresses, transaction histories, purchase records, payment amounts, invoice details, tax identification numbers, credit scores, financial statements, income information, assets and liabilities, investment portfolios, insurance information and any other financial data necessary for business transactions and compliance with financial regulations.
Technical and Device Information: Internet Protocol (IP) addresses, Media Access Control (MAC) addresses, device identifiers, device types, operating systems, browser types and versions, software applications, hardware specifications, network connection information, internet service provider details, mobile carrier information, device settings, installed applications and any other technical information related to devices used to access RJV Technologies’ services.
Usage and Behavioural Data: Website navigation patterns, page views, click through rates, time spent on pages, search queries, download history, feature usage statistics, user preferences, settings configurations, interaction patterns, engagement metrics, conversion data and any other information related to how individuals use and interact with RJV Technologies’ services.
Biometric and Health Information: Fingerprints, facial recognition data, voice prints, retinal scans, DNA data, health records, medical history, prescription information, allergies, disabilities, dietary restrictions, fitness data, and any other biometric or health related information that may be collected in connection with specific services or security measures.
Location and Geographic Information: Precise geographic coordinates, approximate location data, travel patterns, location history, address verification information, shipping and delivery addresses, time zone information and any other location based data collected through GPS, Wi Fi, cellular towers or other positioning technologies.
Communication and Content Data: Email communications, text messages, chat logs, voice recordings, video recordings, call logs, communication metadata, social media posts, comments, reviews, feedback, survey responses, support tickets and any other content or communications shared with or through RJV Technologies’ platforms.
Section 2.2: Methods and Sources of Data Collection
RJV Technologies collects personal data through multiple channels and employs various collection methodologies all of which are designed to be transparent, lawful and proportionate to the purposes for which the data is collected:
Direct Collection from Data Subjects: Personal data is collected directly from individuals when they voluntarily provide information through account registration processes, form submissions, survey completions, subscription sign ups, purchase transactions, customer service interactions, support requests, feedback submissions, contest entries, event registrations, newsletter subscriptions and any other voluntary interactions with RJV Technologies’ services or representatives.
Automated Collection through Digital Platforms: Technical and usage data is automatically collected when individuals access or use RJV Technologies’ websites, mobile applications or other digital platforms through the deployment of cookies, web beacons, pixel tags, software development kits (SDKs), application programming interfaces (APIs), log files and other tracking technologies that capture information about user behaviour, device characteristics, and platform interactions.
Third Party Sources and Data Providers: Personal data may be obtained from legitimate third party sources including but not limited to business partners, vendors, suppliers, customers, marketing partners, data brokers, social media platforms, public records, government databases, credit reporting agencies, identity verification services, fraud prevention services and other external sources where individuals have provided consent or where collection is otherwise lawful.
Offline Collection Methods: Personal data may be collected through offline interactions including but not limited to in person meetings, telephone conversations, physical events, trade shows, conferences, paper forms, printed surveys, business card exchanges and other non digital interactions where individuals voluntarily provide information or where collection is necessary for business purposes.
Employee and Human Resources Data: Personal data is collected from current and prospective employees, contractors and other personnel through recruitment processes, employment applications, background checks, reference verifications, onboarding procedures, performance evaluations, training programs, benefits administration, payroll processing and other human resources activities necessary for employment management and legal compliance.
Section 2.3: Data Minimization and Purpose Limitation Principles
RJV Technologies adheres to the fundamental principles of data minimization and purpose limitation ensuring that personal data collection is always proportionate, relevant and limited to what is necessary for the specific, explicit and legitimate purposes for which it is processed.
The Company implements robust controls and oversight mechanisms to prevent the collection of excessive or irrelevant personal data and regularly reviews its data collection practices to ensure ongoing compliance with these principles.
All personal data collection activities are governed by documented procedures that specify the legal basis for collection, the purposes for which the data will be used, the categories of data to be collected, the sources from which data may be obtained, the retention periods applicable to different types of data and the security measures that will be implemented to protect the collected information.
RJV Technologies conducts regular assessments of its data collection practices to identify opportunities for further minimization and to ensure that collection activities remain aligned with evolving business needs and regulatory requirements.
Where technological or operational changes enable the reduction of data collection while maintaining service quality and legal compliance the Company commits to implementing such improvements in a timely manner.
CHAPTER III: LAWFUL BASES FOR PROCESSING AND PURPOSE SPECIFICATIONS
Section 3.1: Legal Foundations for Data Processing
RJV Technologies processes personal data only when such processing is based on one or more valid legal foundations as recognized under applicable data protection laws.
The Company has implemented comprehensive procedures to identify and document the appropriate legal basis for each processing activity and ensures that all processing operations are conducted in accordance with the requirements and limitations associated with the applicable legal basis.
Consent Based Processing: Where processing is based on the data subject’s consent of RJV Technologies ensures that such consent is freely given, specific, informed and unambiguous.
Consent mechanisms are designed to provide clear information about the purposes of processing, the types of data involved, the retention periods applicable and the rights available to data subjects.
Individuals are provided with granular control over their consent preferences and can withdraw consent at any time through easily accessible mechanisms that are as simple to use as providing consent.
The Company maintains detailed records of consent collection including timestamps, IP addresses, consent versions and withdrawal requests to demonstrate compliance with regulatory requirements.
Contractual Necessity Processing: Personal data is processed when such processing is necessary for the performance of contracts to which the data subject is a party or to take steps at the request of the data subject prior to entering into a contract.
This includes processing necessary for account creation, service delivery, payment processing, customer support, order fulfilment, warranty services and other activities directly related to contractual obligations.
The Company ensures that processing under this legal basis is limited to what is strictly necessary for contract performance and does not extend to ancillary activities that could be conducted under alternative legal bases.
Legal Obligation Compliance Processing: RJV Technologies processes personal data to comply with legal obligations to which the Company is subject under applicable laws and regulations.
This includes processing for tax compliance, regulatory reporting, anti money laundering checks, know your customer verification, employment law compliance, health and safety requirements, environmental regulations and other legal obligations that require the processing of personal data.
The Company maintains comprehensive documentation of legal processing requirements and regularly reviews such obligations to ensure continued compliance.
Vital Interests Protection Processing: In exceptional circumstances, personal data may be processed when such processing is necessary to protect the vital interests of the data subject or another natural person.
This legal basis is applied sparingly and only in situations involving serious threats to health, safety or life where other legal bases are not available or appropriate.
The Company has established protocols for assessing when vital interests processing may be justified and for documenting the circumstances that support such processing.
Public Task Performance Processing: Where applicable RJV Technologies may process personal data when such processing is necessary for the performance of tasks carried out in the public interest or in the exercise of official authority vested in the Company.
This legal basis is applied only when the Company is acting in a public capacity or performing functions that serve the public interest and all such processing is conducted in accordance with applicable public law requirements.
Legitimate Interests Processing: RJV Technologies may process personal data when such processing is necessary for the purposes of legitimate interests pursued by the Company or third parties except where such interests are overridden by the fundamental rights and freedoms of the data subject.
The Company conducts comprehensive legitimate interests assessments (LIAs) before relying on this legal basis evaluating the necessity of processing, the legitimacy of the interests pursued and the potential impact on data subjects.
Balancing tests are performed to ensure that processing does not unduly prejudice individual privacy rights.
Section 3.2: Specific Processing Purposes and Activities
RJV Technologies processes personal data for clearly defined, specific and legitimate purposes that are communicated to data subjects at the time of collection or before processing commences.
The following represents a comprehensive overview of the purposes for which the Company processes personal data:
Service Provision and Customer Management: Personal data is processed to provide, maintain and improve the services offered by RJV Technologies including account creation and management, user authentication and authorization, service customization and personalization, technical support provision, customer relationship management, order processing and fulfilment, billing and payment processing warranty and guarantee services, service usage monitoring and optimization, feature development and enhancement and quality assurance activities.
Business Operations and Administration: The Company processes personal data for essential business operations including vendor and supplier management, partner relationship administration, contract negotiation and management, business planning and strategy development, financial management and accounting, legal compliance and risk management, internal reporting and analytics, audit and compliance monitoring, corporate governance activities and business continuity planning.
Marketing and Communications: Subject to applicable legal requirements and individual preferences RJV Technologies processes personal data for marketing and promotional activities including direct marketing communications, newsletter distribution, promotional offer delivery, market research and surveys, customer segmentation and profiling, advertising campaign management, event invitation and management, content personalization, social media engagement and brand awareness initiatives.
Security and Fraud Prevention: Personal data is processed to protect the security and integrity of RJV Technologies’ systems, services and operations including user identity verification, fraud detection and prevention, security monitoring and incident response, access control and authorization, threat assessment and mitigation, compliance with security standards and regulations, forensic analysis of security incidents and protection of intellectual property and confidential information.
Legal Compliance and Regulatory Requirements: The Company processes personal data to comply with applicable legal and regulatory obligations including tax reporting and compliance, anti money laundering and counter terrorism financing checks, employment law compliance, health and safety reporting, environmental compliance, intellectual property protection, litigation support and legal proceedings, regulatory investigations and audits and compliance with court orders and legal process.
Research and Development: Personal data may be processed for research and development activities including product development and improvement, service innovation and enhancement, market research and analysis, user experience research, technology development and testing, statistical analysis and reporting, trend identification and forecasting and academic and scientific research collaborations always ensuring appropriate anonymization or pseudonymization where possible.
Human Resources and Employment Management: In relation to current and prospective employees, contractors and other personnel of RJV Technologies processes personal data for recruitment and hiring, onboarding and orientation, performance management and evaluation, training and development, compensation and benefits administration, workplace health and safety, disciplinary and grievance procedures, termination and offboarding, and alumni and retiree management.
Section 3.3: Processing Limitations and Safeguards
RJV Technologies implements comprehensive safeguards to ensure that personal data processing remains within the bounds of the stated purposes and applicable legal requirements.
The Company prohibits the processing of personal data for purposes that are incompatible with the original collection purposes unless a new legal basis is established and appropriate notice is provided to data subjects.
All processing activities are subject to regular review and assessment to ensure continued necessity, proportionality and compliance with purpose limitations.
Where processing purposes evolve or expand, the Company conducts impact assessments to evaluate the implications for data subject rights and implements additional safeguards as necessary to maintain appropriate protection levels.
The Company maintains detailed processing records that document the purposes of each processing activity, the legal basis relied upon, the categories of data processed, the retention periods applied and the security measures implemented.
These records are regularly updated to reflect changes in processing activities and are made available to supervisory authorities upon request as required by applicable data protection laws.
CHAPTER IV: DATA SHARING, DISCLOSURE AND INTERNATIONAL TRANSFERS
Section 4.1: Third Party Data Sharing Framework
RJV Technologies recognizes that the sharing of personal data with third parties requires careful consideration of legal requirements, contractual safeguards and data subject rights.
The Company has established a comprehensive framework governing all data sharing activities to ensure that personal data remains protected throughout the disclosure process and that all sharing activities are conducted in accordance with applicable data protection laws and the legitimate expectations of data subjects.
Categories of Third Party Recipients: Personal data may be shared with carefully selected categories of third party recipients who have demonstrated appropriate technical and organizational security measures and who have entered into legally binding data processing agreements with RJV Technologies.
These categories include:
Service Providers and Processors: Cloud computing and hosting providers, software-as-a-service vendors, payment processors, customer relationship management providers, marketing automation platforms, analytics and business intelligence services, identity verification services, fraud prevention services, cybersecurity providers, technical support services, data backup and recovery services and other technology vendors who process personal data on behalf of RJV Technologies under strict contractual controls.
Professional Service Providers: Legal counsel and law firms, accounting and audit firms, management consultants, regulatory compliance advisors, tax preparation services, business valuation experts, insurance providers, banking and financial institutions, real estate professionals and other professional service providers who require access to personal data to deliver specialized services to RJV Technologies.
Business Partners and Affiliates: Joint venture partners, strategic alliance participants, subsidiary companies, parent companies, affiliated entities, distribution partners, reseller networks, integration partners, co marketing partners and other business entities with whom RJV Technologies maintains formal business relationships that require limited data sharing for specific business purposes.
Regulatory and Government Authorities: Tax authorities, financial regulators, employment agencies, health and safety authorities, environmental agencies, intellectual property offices, courts and tribunals, law enforcement agencies, national security organizations and other governmental or regulatory bodies that have legal authority to request or require the disclosure of personal data for specific purposes.
Merger and Acquisition Participants: In connection with potential or completed mergers, acquisitions, divestitures, reorganizations, bankruptcies or other business transactions, personal data may be shared with prospective buyers, sellers, investors, due diligence participants, legal representatives, financial advisors and other transaction participants subject to appropriate confidentiality agreements and data protection safeguards.
Section 4.2: Data Sharing Principles and Safeguards
All data sharing activities conducted by RJV Technologies are governed by strict principles designed to minimize privacy risks and ensure appropriate protection of personal data throughout the sharing process:
Necessity and Proportionality Assessment: Before sharing personal data with any third party RJV Technologies conducts a thorough assessment to determine whether the sharing is necessary for the intended purpose and whether the scope of data to be shared is proportionate to the legitimate need.
The Company implements a data minimization approach, sharing only the specific categories and elements of personal data that are required for the stated purpose.
Legal Basis Verification: All data sharing activities are predicated on a valid legal basis for processing which may include contractual necessity, legal obligations, legitimate interests or explicit consent, depending on the circumstances of the sharing.
The Company maintains documentation of the legal basis for each category of data sharing and ensures that sharing activities remain within the scope of the applicable legal justification.
Contractual Protection Requirements: RJV Technologies enters into comprehensive data processing agreements with all third party recipients of personal data, which agreements include detailed provisions regarding the purposes for which data may be used, the security measures that must be implemented, the retention periods that apply, the circumstances under which data must be returned or deleted, the audit rights retained by RJV Technologies and the liability allocation for any data breaches or misuse.
Due Diligence and Vendor Assessment: Before engaging any third party that will have access to personal data, RJV Technologies conducts thorough due diligence assessments to evaluate the recipient’s data protection capabilities, security infrastructure, compliance history, financial stability and overall suitability as a data handling partner.
This assessment includes review of certifications, audit reports, security policies, incident history and references from other customers.
Ongoing Monitoring and Oversight: RJV Technologies maintains active oversight of all third party data sharing relationships through regular monitoring activities including security assessments, compliance audits, performance reviews, contract compliance monitoring, and incident response coordination.
The Company retains the right to conduct on site inspections and requires prompt notification of any security incidents or compliance issues.
Section 4.3: International Data Transfer Mechanisms
Given the global nature of modern business operations and technology infrastructure RJV Technologies recognizes that personal data may need to be transferred across international borders to enable effective service delivery and business operations.
The Company has implemented comprehensive safeguards to ensure that all international data transfers comply with applicable data protection laws and provide appropriate protection for personal data regardless of the destination country.
Adequacy Decision Transfers: Where personal data is transferred to countries or territories that have been subject to adequacy decisions by relevant data protection authorities (such as the European Commission adequacy decisions under GDPR) RJV Technologies relies on such adequacy determinations as the legal basis for international transfers while maintaining ongoing monitoring of the adequacy status and implementing additional safeguards as necessary.
Standard Contractual Clauses Implementation: For transfers to countries that have not been subject to adequacy decisions RJV Technologies implements Standard Contractual Clauses (SCCs) approved by relevant data protection authorities as the primary transfer mechanism.
The Company conducts Transfer Impact Assessments (TIAs) to evaluate the effectiveness of SCCs in the specific destination country and implements supplementary measures where necessary to ensure adequate protection.
Binding Corporate Rules Framework: RJV Technologies is developing a comprehensive Binding Corporate Rules (BCR) framework to govern intra group transfers of personal data between the Company and its subsidiaries, affiliates and related entities.
This framework will establish consistent global privacy standards and provide a robust legal mechanism for international data transfers within the corporate group.
Certification and Code of Conduct Adherence: The Company participates in recognized certification schemes and adheres to approved codes of conduct that provide additional safeguards for international data transfers.
These mechanisms provide external validation of RJV Technologies’ data protection practices and demonstrate ongoing commitment to maintaining high privacy standards.
Derogation Based Transfers: In limited circumstances where other transfer mechanisms are not available or appropriate, RJV Technologies may rely on specific derogations provided under applicable data protection laws such as explicit consent, contractual necessity, important public interest grounds or vital interests protection.
Such transfers are conducted sparingly and only when strict conditions are met.
Transfer Documentation and Records: RJV Technologies maintains comprehensive records of all international data transfers, including documentation of the transfer mechanism relied upon, the categories of personal data transferred, the destination countries involved, the purposes of the transfer, the safeguards implemented and any additional measures adopted to ensure adequate protection.
These records are regularly reviewed and updated to reflect changes in transfer arrangements or regulatory requirements.
CHAPTER V: DATA RETENTION, STORAGE AND DELETION PROTOCOLS
Section 5.1: Comprehensive Data Retention Framework
RJV Technologies has established a comprehensive data retention framework that ensures personal data is retained only for as long as necessary to fulfil the purposes for which it was collected comply with applicable legal and regulatory requirements and protect the legitimate interests of the Company and data subjects.
This framework is based on the principles of storage limitation, data minimization and proportionality ensuring that retention periods are carefully calibrated to balance operational needs with privacy protection requirements.
Purpose Based Retention Categories: The Company has developed detailed retention schedules that categorize personal data based on the purposes for which it is processed and establish specific retention periods for each category:
Customer and Transaction Data: Personal data collected in connection with customer relationships and commercial transactions is retained for the duration of the active business relationship plus additional periods necessary to fulfil warranty obligations, handle potential disputes, comply with accounting and tax requirements and meet other legal obligations.
Active customer data is typically retained for the duration of the account relationship plus seven years following account closure unless longer retention is required by specific legal obligations or shorter retention is appropriate based on the nature of the data and services provided.
Marketing and Communications Data: Personal data collected for marketing purposes is retained based on the ongoing validity of consent or other applicable legal bases with regular review of retention necessity.
Newsletter subscription data is retained until consent is withdrawn or the subscriber becomes inactive for extended periods.
Marketing analytics data may be aggregated and anonymized for longer term retention where individual identification is removed and re identification is prevented through technical and organizational measures.
Employment and Human Resources Data: Employee personal data is retained throughout the employment relationship and for specified periods following termination as required by employment laws, pension regulations, health and safety requirements and other applicable legal obligations.
Recruitment data for unsuccessful candidates is typically retained for shorter periods unless consent is provided for inclusion in talent pools for future opportunities.
Technical and System Data: Server logs, security monitoring data and other technical information is retained based on operational requirements, security needs and regulatory obligations.
High level system logs may be retained for extended periods for security monitoring and forensic purposes while detailed transaction logs are typically retained for shorter periods unless specific incidents require longer preservation.
Legal and Compliance Data: Personal data retained for legal compliance purposes is maintained for the periods specified by applicable laws and regulations, which may include extended retention periods for tax records, regulatory filings, anti money laundering documentation and other compliance related information.
The Company maintains detailed documentation of legal retention requirements and regularly updates retention periods based on regulatory changes.
Section 5.2: Secure Data Storage Infrastructure
RJV Technologies implements industry leading data storage infrastructure designed to ensure the security, integrity and availability of personal data throughout the retention period.
The Company’s storage systems incorporate multiple layers of security controls and redundancy measures to protect against unauthorized access, data corruption, natural disasters and other threats that could compromise data security or availability.
Physical Security Controls: All data centres and storage facilities used by RJV Technologies implement comprehensive physical security measures including biometric access controls, 24/7 security monitoring, environmental controls, fire suppression systems, backup power supplies and restricted access protocols.
The Company maintains detailed records of physical access to storage facilities and conducts regular security assessments of all storage locations.
Logical Security Implementation: Digital storage systems implement multiple layers of logical security controls including strong encryption for data at rest and in transit, access control mechanisms based on the principle of least privilege, network segmentation and firewalls, intrusion detection and prevention systems, malware protection, vulnerability management and security monitoring and logging.
All security controls are regularly tested and updated to address emerging threats and vulnerabilities.
Data Encryption Standards: All personal data stored by RJV Technologies is encrypted using industry standard encryption algorithms and key management practices.
Encryption keys are managed through secure key management systems that implement separation of duties, regular key rotation, secure key storage and comprehensive audit logging.
The Company maintains detailed documentation of encryption standards and regularly reviews cryptographic implementations to ensure continued effectiveness.
Backup and Recovery Procedures: The Company implements comprehensive backup and disaster recovery procedures to ensure data availability and business continuity while maintaining appropriate security controls for backup data.
Backup systems implement the same security controls as primary storage systems including encryption, access controls and monitoring.
Recovery procedures are regularly tested to ensure effectiveness and compliance with recovery time objectives and recovery point objectives.
Storage Location Management: RJV Technologies maintains detailed records of all storage locations for personal data including the geographic locations of data centres, the types of data stored in each location, the security controls implemented at each facility and the legal frameworks governing data processing in each jurisdiction.
The Company conducts regular assessments of storage locations to ensure continued compliance with applicable legal requirements and security standards.
Section 5.3: Data Deletion and Destruction Protocols
RJV Technologies has implemented comprehensive data deletion and destruction protocols to ensure that personal data is securely and permanently removed from all systems when retention periods expire or when deletion is requested by data subjects exercising their rights under applicable data protection laws.
Automated Deletion Processes: The Company has implemented automated systems that identify personal data eligible for deletion based on predetermined retention schedules and business rules.
These systems generate deletion queues, notify relevant stakeholders of pending deletions, provide opportunities for legitimate retention extensions and execute secure deletion processes according to established timelines.
All automated deletion activities are logged and monitored to ensure proper execution and compliance with retention policies.
Manual Deletion Procedures: For personal data that cannot be automatically deleted due to technical constraints or special circumstances RJV Technologies has established manual deletion procedures that include identification of data eligible for deletion, approval processes for deletion execution, secure deletion methods appropriate to the storage medium, verification of successful deletion and documentation of deletion activities.
Manual deletion procedures are conducted by authorized personnel following established protocols and oversight requirements.
Secure Destruction Standards: All data deletion and destruction activities comply with industry recognized standards for secure data destruction, ensuring that deleted data cannot be recovered through technical means.
For electronic storage media, the Company implements multi pass overwriting procedures, cryptographic erasure where appropriate and physical destruction of storage devices that cannot be securely wiped.
For physical documents and other non electronic media, secure destruction methods include shredding, incineration or other destruction methods that prevent data recovery.
Third Party Deletion Coordination: When personal data is stored or processed by third party service providers RJV Technologies coordinates deletion activities through contractual requirements and oversight procedures.
The Company requires third party processors to implement deletion procedures consistent with RJV Technologies’ standards, provide confirmation of successful deletion and return or destroy any personal data upon termination of processing relationships.
Deletion Verification and Auditing: All data deletion activities are subject to verification procedures to confirm successful completion and compliance with established protocols.
The Company maintains deletion logs that document the date and time of deletion, the categories and volumes of data deleted, the deletion methods employed, the personnel responsible for deletion and any exceptions or issues encountered during the deletion process.
These logs are regularly reviewed and audited to ensure compliance with retention policies and regulatory requirements.
Legal Hold and Litigation Preservation: RJV Technologies has implemented procedures to identify and preserve personal data that may be subject to legal holds, litigation preservation requirements, regulatory investigations or other legal processes that may override normal retention and deletion schedules.
The Company maintains detailed documentation of legal preservation requirements and implements systematic approaches to identify, isolate and preserve relevant data while continuing normal deletion processes for unaffected data.
CHAPTER VI: INDIVIDUAL RIGHTS AND REQUEST PROCESSING PROCEDURES
Section 6.1: Comprehensive Rights Framework
RJV Technologies recognizes and upholds the fundamental privacy rights of individuals under applicable data protection laws worldwide.
The Company has established comprehensive procedures to facilitate the exercise of these rights and ensure that all requests are processed in a timely, efficient and legally compliant manner.
The rights framework encompasses all recognized individual rights under global data protection legislation and provides mechanisms for efficient request processing and response.
Right of Access and Information: Data subjects have the right to obtain confirmation from RJV Technologies regarding whether personal data concerning them is being processed and where such processing is taking place to access the personal data and obtain comprehensive information about the processing activities.
This includes information about the purposes of processing, the categories of personal data involved, the recipients or categories of recipients to whom data has been or will be disclosed, the envisaged retention periods, the source of the data if not collected directly from the data subject, the existence of automated decision making including profiling and the logic involved in such processing.
When responding to access requests RJV Technologies provides the information in a commonly used electronic format unless the data subject specifically requests a different format.
The Company implements identity verification procedures to ensure that personal data is only disclosed to authorized individuals and maintains comprehensive logs of all access requests and responses to demonstrate compliance with legal requirements.
Right to Rectification and Correction: Data subjects have the right to obtain rectification of inaccurate personal data concerning them and to have incomplete personal data completed including by means of providing supplementary statements.
RJV Technologies has implemented procedures to facilitate prompt correction of personal data and ensures that rectifications are communicated to all recipients to whom the data has been disclosed unless such communication proves impossible or involves disproportionate effort.
The Company maintains audit trails of all rectification activities including documentation of the original data, the corrected data, the date of correction, the identity of the requesting party and any supporting documentation provided.
Where rectification requests are declined, the Company provides clear explanations of the reasons for refusal and information about available appeal procedures and supervisory authority complaint rights.
Right to Erasure and Deletion: Data subjects have the right to obtain erasure of personal data concerning them when specific conditions are met including when the data is no longer necessary for the original purposes when consent is withdrawn and no other legal ground exists for processing, when data has been unlawfully processed, when erasure is required for compliance with legal obligations or when data was collected from children without appropriate consent.
RJV Technologies has implemented comprehensive erasure procedures that ensure complete removal of personal data from all systems including backup systems, archives and third party processors.
The Company provides confirmation of successful erasure and maintains documentation of erasure activities while ensuring that any technical impossibility of erasure is clearly communicated to data subjects along with explanations of the circumstances preventing complete erasure.
Right to Restrict Processing: Data subjects have the right to obtain restriction of processing when they contest the accuracy of personal data, when processing is unlawful but the data subject opposes erasure, when the Company no longer needs the data but the data subject requires it for legal claims or when the data subject has objected to processing pending verification of legitimate grounds.
When processing is restricted RJV Technologies implements technical and organizational measures to prevent further processing of the restricted data while maintaining the data’s availability for the limited purposes that justify continued storage.
The Company provides clear notification to data subjects when restrictions are lifted and ensures that all recipients of restricted data are informed of the restriction and any subsequent lifting of restrictions.
Right to Data Portability: Data subjects have the right to receive personal data concerning them in a structured, commonly used and machine readable format and to transmit that data to another controller when processing is based on consent or contract and is carried out by automated means.
RJV Technologies has implemented technical solutions to facilitate data portability requests and provides data in standardized formats that enable efficient transfer to other service providers.
The Company maintains detailed documentation of data portability procedures including the technical formats supported, the scope of data included in portability responses, the verification procedures applied and any limitations or exceptions that may apply to specific types of data or processing activities.
Right to Object to Processing: Data subjects have the right to object to processing of personal data when such processing is based on legitimate interests, public task performance or direct marketing purposes.
For legitimate interests and public task processing RJV Technologies must demonstrate compelling legitimate grounds that override the interests, rights and freedoms of the data subject or show that processing is necessary for establishment, exercise or defence of legal claims.
For direct marketing objections, the Company immediately ceases all marketing related processing of the objecting individual’s personal data and implements permanent suppression mechanisms to prevent future marketing communications.
The Company maintains comprehensive objection tracking systems to ensure that objections are properly recorded and respected across all business units and processing activities.
Right to Withdraw Consent: Where processing is based on consent, data subjects have the right to withdraw consent at any time with the same ease as providing consent.
RJV Technologies implements user friendly mechanisms for consent withdrawal and ensures that withdrawal does not affect the lawfulness of processing conducted prior to withdrawal.
The Company provides clear information about the consequences of consent withdrawal including any services or features that may no longer be available and implements technical measures to ensure that consent withdrawal is immediately effective across all relevant processing activities.
Right to Lodge Complaints: Data subjects have the right to lodge complaints with supervisory authorities regarding the processing of their personal data.
RJV Technologies provides clear information about relevant supervisory authorities in different jurisdictions and assists data subjects in understanding their complaint rights and procedures.
Section 6.2: Request Processing Infrastructure and Procedures
RJV Technologies has established a sophisticated infrastructure for receiving, processing and responding to individual rights requests that ensures efficient handling while maintaining appropriate security and verification controls.
Request Reception Mechanisms: The Company provides multiple channels through which data subjects can submit rights requests including dedicated online portals with secure authentication, email addresses monitored by privacy specialists, postal mail addresses for written requests, telephone hotlines for urgent matters and in person submission options where appropriate.
All reception channels implement appropriate security measures to protect the confidentiality of requests and personal data.
Identity Verification Protocols: Before processing any rights request RJV Technologies implements comprehensive identity verification procedures to ensure that personal data is only disclosed to authorized individuals and that fraudulent requests are prevented.
Verification procedures are proportionate to the sensitivity of the data involved and may include knowledge based authentication, document verification, multi factor authentication or other appropriate verification methods.
The Company maintains detailed documentation of verification procedures and provides clear information to data subjects about the verification requirements and the reasons such verification is necessary to protect their privacy and prevent unauthorized access to personal data.
Request Categorization and Routing: All incoming rights requests are systematically categorized based on the type of right being exercised, the urgency of the request, the complexity of the required response and any special circumstances that may affect processing.
Requests are routed to appropriate processing teams with relevant expertise and authority to handle the specific type of request efficiently and accurately.
Processing Timeline Management: RJV Technologies has implemented comprehensive timeline management systems to ensure that all rights requests are processed within applicable legal deadlines.
The Company typically responds to straightforward requests within shorter timeframes than legally required and provides regular status updates for complex requests that may require extended processing periods.
When additional time is needed to process complex requests, the Company provides prompt notification to data subjects explaining the reasons for delay, the expected completion timeline and any interim measures being taken to address urgent aspects of the request.
Quality Assurance and Review Procedures: All rights request responses undergo multiple levels of review to ensure accuracy, completeness and legal compliance.
Review procedures include technical verification of data accuracy, legal review of response content, privacy impact assessment of disclosure decisions and supervisory approval for complex or sensitive requests.
The Company maintains comprehensive quality metrics for rights request processing including response times, accuracy rates, data subject satisfaction scores and complaint rates and uses these metrics to continuously improve request processing procedures.
Section 6.3: Special Procedures for Complex and High Risk Requests
RJV Technologies has developed specialized procedures for handling rights requests that involve complex technical considerations, high privacy risks, legal complications or other circumstances that require enhanced processing protocols.
Voluminous Data Requests: For requests involving large volumes of personal data, the Company implements specialized procedures to manage the scope and delivery of responses while maintaining data security and minimizing processing burdens.
This may include providing data in multiple instalments offering data sampling options for verification purposes, implementing secure data transfer mechanisms or proposing alternative approaches that meet the data subject’s needs while managing practical constraints.
Third Party Data Considerations: When rights requests involve personal data that also relates to other individuals (third party data) RJV Technologies conducts careful balancing assessments to determine the appropriate scope of disclosure while protecting the privacy rights of all affected individuals.
The Company may implement redaction procedures, seek consent from affected third parties or provide alternative approaches that meet the requesting party’s needs without compromising other individuals’ privacy rights.
Legal Privilege and Confidentiality Issues: For requests involving data subject to legal professional privilege, attorney client privilege, trade secret protection or other confidentiality obligations, the Company conducts detailed legal analysis to determine the appropriate scope of disclosure while maintaining necessary confidentiality protections.
The Company provides clear explanations of any limitations on disclosure and offers alternative approaches where possible.
Cross Border Request Coordination: When rights requests involve personal data processed across multiple jurisdictions with different legal requirements RJV Technologies coordinates response efforts to ensure compliance with all applicable legal frameworks while providing coherent and comprehensive responses to data subjects.
This may involve consultation with legal counsel in multiple jurisdictions, coordination with international subsidiaries or partners and careful consideration of conflicting legal requirements.
Emergency and Urgent Requests: For rights requests involving urgent circumstances, such as safety concerns, medical emergencies or time sensitive legal proceedings, the Company has implemented expedited processing procedures that prioritize urgent requests while maintaining appropriate verification and quality controls.
Emergency procedures include dedicated contact channels, accelerated review processes, and provisional response mechanisms for situations requiring immediate action.
CHAPTER VII: SECURITY INFRASTRUCTURE AND INCIDENT RESPONSE PROTOCOLS
Section 7.1: Comprehensive Security Architecture
RJV Technologies has implemented a multi layered security architecture designed to protect personal data against unauthorized access, accidental or unlawful destruction, loss, alteration, unauthorized disclosure and all other forms of unlawful processing.
This security architecture encompasses technical, organizational and procedural safeguards that work together to create a robust defence system capable of addressing evolving cybersecurity threats and maintaining the confidentiality, integrity and availability of personal data.
Technical Security Controls: The Company’s technical security infrastructure implements industry leading technologies and practices across all aspects of data processing and storage.
Network security controls include next generation firewalls with deep packet inspection capabilities, intrusion detection and prevention systems with behavioural analytics, network segmentation and micro segmentation technologies, virtual private networks for secure remote access, distributed denial of service protection systems and comprehensive network monitoring and logging capabilities.
Application security measures encompass secure software development lifecycle practices, regular application security testing including static and dynamic analysis, web application firewalls with custom rule sets, application level encryption and tokenization, secure authentication and authorization mechanisms including multi factor authentication, session management and timeout controls and comprehensive application logging and monitoring.
Database security implementations include database encryption at rest and in transit, database activity monitoring and auditing, privileged access management for database administrators, database firewall technologies, regular database vulnerability assessments, secure database configuration management and data loss prevention controls specifically designed for database environments.
Endpoint and Device Security: All endpoints and devices that access or process personal data are subject to comprehensive security controls including enterprise grade endpoint detection and response solutions, centralized device management and configuration, mandatory encryption of all data storage devices, regular security patching and vulnerability management, anti malware protection with real time scanning, device compliance monitoring and enforcement and secure remote wipe capabilities for lost or stolen devices.
Mobile device security measures include mobile device management platforms, application containerization and wrapping technologies, mobile threat defence solutions, secure mobile application development practices, mobile data encryption and secure key management and comprehensive mobile device monitoring and compliance reporting.
Cloud Security Framework: For cloud based processing and storage activities RJV Technologies implements cloud specific security controls that include cloud security posture management tools, cloud workload protection platforms, cloud access security brokers, container security and orchestration controls, serverless security monitoring, cloud encryption and key management services and comprehensive cloud activity logging and monitoring.
The Company maintains detailed cloud security assessments for all cloud service providers and implements shared responsibility model frameworks that clearly define security obligations between RJV Technologies and cloud providers ensuring that all aspects of cloud security are appropriately addressed and monitored.
Section 7.2: Organizational Security Measures
RJV Technologies recognizes that effective data security requires comprehensive organizational measures that complement technical controls and create a culture of security awareness and responsibility throughout the organization.
Security Governance Structure: The Company has established a comprehensive security governance structure that includes a dedicated Chief Information Security Officer (CISO) with direct reporting authority to executive management, a security steering committee comprising senior leaders from all business units, specialized security teams responsible for different aspects of the security program and clear escalation procedures for security issues and incidents.
Security governance includes regular board level reporting on security posture and incidents, comprehensive security risk management frameworks, security strategy development and implementation oversight, security budget planning and resource allocation and coordination with business units on security requirements and initiatives.
Personnel Security Controls: All personnel with access to personal data undergo comprehensive background verification procedures appropriate to their level of access and responsibilities.
This includes employment history verification, criminal background checks where legally permitted, reference verification from previous employers, educational credential verification and ongoing monitoring for security relevant changes in circumstances.
Security awareness and training programs ensure that all personnel understand their responsibilities for protecting personal data and are equipped with the knowledge and skills necessary to identify and respond to security threats.
Training programs include initial security orientation for new employees, regular refresher training for all personnel, specialized training for employees with elevated access privileges, phishing simulation and response training, incident response training and exercises and security awareness communications and updates.
Access Control and Privilege Management: RJV Technologies implements comprehensive access control frameworks based on the principles of least privilege, separation of duties and need to know access.
Access control measures include role-based access control systems with granular permissions, regular access reviews and recertification procedures, automated provisioning and deprovisioning of access rights, privileged access management for administrative accounts and comprehensive access logging and monitoring.
All access to personal data is subject to formal authorization procedures that include business justification for access needs, approval by appropriate managers and data stewards, regular review of access appropriateness and prompt removal of access when no longer required.
The Company maintains detailed access logs and conducts regular access audits to ensure compliance with access control policies.
Vendor and Third Party Security Management: All vendors and third parties with access to personal data undergo comprehensive security assessments before engagement and are subject to ongoing monitoring throughout the business relationship.
Security assessments include evaluation of the vendor’s security policies and procedures, technical security controls and infrastructure, compliance certifications and audit reports, incident history and response capabilities and financial stability and business continuity planning.
Contractual security requirements for vendors include mandatory implementation of specific security controls, regular security reporting and certification, notification requirements for security incidents, audit rights and compliance monitoring and liability provisions for security breaches or non compliance.
Section 7.3: Incident Response and Business Continuity Framework
RJV Technologies has developed comprehensive incident response and business continuity frameworks designed to ensure rapid detection, containment and remediation of security incidents while maintaining business operations and protecting personal data throughout the incident response process.
Incident Detection and Classification: The Company implements advanced security monitoring and detection capabilities that provide real time visibility into potential security threats and incidents.
Detection capabilities include security information and event management (SIEM) systems with custom correlation rules, user and entity behaviour analytics (UEBA) for anomaly detection, threat intelligence integration and automated indicator matching, endpoint detection and response with behavioural analysis and network traffic analysis and threat hunting capabilities.
All detected security events undergo systematic classification based on their potential impact on personal data, business operations, and regulatory compliance.
Classification criteria include the types and volumes of personal data potentially affected, the nature and severity of the security threat, the potential for ongoing or expanded compromise, the likelihood of regulatory notification requirements and the potential impact on data subjects and business operations.
Incident Response Procedures: Upon detection and classification of security incidents RJV Technologies activates comprehensive incident response procedures that include immediate containment measures to prevent further compromise, detailed forensic investigation to understand the scope and nature of the incident, evidence preservation and documentation for potential legal proceedings, communication and notification procedures for internal stakeholders and external parties and remediation activities to address vulnerabilities and prevent recurrence.
The Company maintains a dedicated incident response team with clearly defined roles and responsibilities including incident commanders responsible for overall response coordination, technical analysts responsible for investigation and remediation, legal counsel responsible for regulatory and legal considerations, communications specialists responsible for internal and external communications and business continuity coordinators responsible for maintaining operations during incidents.
Regulatory Notification and Communication: RJV Technologies has implemented comprehensive procedures for evaluating regulatory notification requirements and communicating with supervisory authorities, data subjects and other stakeholders following security incidents.
Notification procedures include rapid assessment of notification requirements under applicable data protection laws, preparation of detailed incident notifications including all required information elements, coordination with legal counsel and regulatory specialists and ongoing communication with authorities throughout the incident response process.
Data subject notification procedures include assessment of individual notification requirements, development of clear and comprehensive notification content, selection of appropriate communication channels and methods and provision of assistance and support to affected individuals including identity monitoring services, credit monitoring services and dedicated support resources.
Business Continuity and Disaster Recovery: The Company maintains comprehensive business continuity and disaster recovery capabilities designed to ensure continued protection of personal data and maintenance of essential business operations during and following security incidents, natural disasters or other disruptive events.
Business continuity measures include redundant processing and storage systems across geographically distributed locations, automated failover and recovery procedures, regular backup and restoration testing, alternative communication and collaboration systems, remote work capabilities and procedures and comprehensive business continuity training and exercises.
Recovery procedures include systematic assessment of system integrity and data security following incidents, validation of data backup integrity and completeness, step by step restoration procedures with security verification, post recovery monitoring and validation and lessons learned analysis and improvement implementation.
CHAPTER VIII: PRIVACY BY DESIGN AND DATA PROTECTION IMPACT ASSESSMENTS
Section 8.1: Privacy by Design Implementation Framework
RJV Technologies has embedded privacy by design principles into every aspect of its business operations, technology development and service delivery processes.
This comprehensive approach ensures that privacy protection is not an afterthought but rather a fundamental consideration that guides decision making from the earliest stages of planning through implementation and ongoing operations.
Proactive Privacy Integration: The Company implements proactive privacy measures that anticipate and prevent privacy invasions before they occur rather than responding to privacy concerns after they arise.
This includes conducting privacy assessments during the conceptual design phase of new products and services, integrating privacy considerations into business process design and optimization, implementing privacy protective technologies and methodologies as default operational practices and establishing privacy review requirements for all business initiatives that may involve personal data processing.
Privacy integration extends to vendor selection and management processes, where privacy capabilities and commitments are evaluated as essential criteria for partnership decisions.
The Company requires privacy impact assessments for all new vendor relationships and technology implementations that may affect personal data processing activities.
Default Privacy Protection: All systems, processes and services developed or implemented by RJV Technologies are designed to provide maximum privacy protection by default without requiring action from data subjects to activate privacy protections.
Default privacy measures include implementing the most privacy protective settings as standard configurations requiring explicit user action to reduce privacy protections rather than to enhance them, designing data collection processes to capture only essential information unless users specifically choose to provide additional data and implementing automatic data minimization and retention limit enforcement.
Default privacy protection extends to user interface design where privacy protective choices are presented as the primary options and privacy invasive alternatives require additional user actions and explicit confirmation.
The Company regularly reviews default settings and configurations to ensure they continue to provide optimal privacy protection as technologies and business practices evolve.
Privacy Embedded in Technology: RJV Technologies integrates privacy enhancing technologies throughout its technical infrastructure to provide technical privacy protection that does not rely solely on procedural controls or user actions.
This includes implementing encryption by default for all data processing and storage activities utilizing anonymization and pseudonymization techniques where feasible to reduce identification risks, deploying differential privacy mechanisms for analytics and research activities, and implementing zero knowledge proof systems where appropriate to minimize data exposure.
Technical privacy measures also include privacy preserving authentication mechanisms that minimize the collection of identifying information, secure multi party computation systems for collaborative data processing, homomorphic encryption for computation on encrypted data and federated learning approaches that enable machine learning without centralizing personal data.
Comprehensive Privacy Documentation: All privacy by design implementations are supported by comprehensive documentation that describes the privacy measures implemented, the rationale for specific privacy design decisions, the effectiveness of privacy protections in different operational scenarios and the procedures for maintaining and updating privacy protections over time.
Documentation includes privacy design specifications for all systems and processes, privacy impact assessments for business initiatives, privacy engineering guidelines for technical development activities and privacy compliance verification procedures that ensure ongoing adherence to privacy by design principles.
Section 8.2: Data Protection Impact Assessment Methodology
RJV Technologies has developed a sophisticated Data Protection Impact Assessment (DPIA) methodology that ensures systematic evaluation of privacy risks and implementation of appropriate mitigation measures for all processing activities that may pose high risks to individual privacy rights and freedoms.
DPIA Triggering Criteria: The Company conducts DPIAs for all processing activities that meet specific criteria indicating potential high privacy risks.
These criteria include processing of sensitive personal data on a large scale, systematic monitoring of publicly accessible areas, systematic and extensive evaluation or scoring of individuals including profiling and prediction activities, processing of personal data of vulnerable individuals including children, processing involving innovative technologies or novel applications of existing technologies and processing that may result in high individual or societal privacy risks.
Additional DPIA triggers include cross border data transfers to countries without adequacy decisions, processing activities that combine datasets from multiple sources, automated decision making with significant individual impact, processing for purposes that differ substantially from original collection purposes and processing activities that have generated privacy concerns or complaints in the past.
Comprehensive Risk Assessment Framework: DPIA risk assessments evaluate privacy risks from multiple perspectives, including the likelihood and severity of potential privacy harms, the effectiveness of proposed mitigation measures, the proportionality of processing activities relative to the purposes pursued and the potential cumulative impact of processing activities on individual privacy rights and societal privacy norms.
Risk assessment methodologies include quantitative risk scoring systems that enable consistent evaluation and comparison of different privacy risks, qualitative risk analysis that considers contextual factors and stakeholder perspectives, scenario based risk modelling that evaluates privacy risks under different operational conditions and stakeholder consultation processes that incorporate external perspectives on privacy risks and mitigation strategies.
Stakeholder Consultation Procedures: All DPIAs include comprehensive stakeholder consultation processes designed to ensure that diverse perspectives are considered in privacy risk assessment and mitigation planning.
Stakeholder consultation includes engagement with data subjects or their representatives to understand privacy concerns and preferences, consultation with privacy advocates and civil society organizations, engagement with technical experts and privacy researchers and coordination with supervisory authorities where appropriate.
Consultation procedures are designed to be inclusive and accessible, providing multiple channels for stakeholder input and ensuring that consultation processes do not create barriers to meaningful participation.
The Company maintains detailed documentation of consultation activities and demonstrates how stakeholder input has been incorporated into DPIA outcomes and mitigation measures.
Mitigation Strategy Development: Based on DPIA risk assessments and stakeholder consultation RJV Technologies develops comprehensive mitigation strategies that address identified privacy risks through technical, organizational and procedural measures.
Mitigation strategies prioritize measures that eliminate or substantially reduce privacy risks while maintaining the ability to achieve legitimate business objectives.
Technical mitigation measures may include implementation of privacy enhancing technologies, modification of system architectures to reduce data exposure, implementation of additional encryption or anonymization measures, and development of privacy protective user interfaces and interaction mechanisms.
Organizational mitigation measures may include additional staff training and awareness programs, enhanced oversight and monitoring procedures, implementation of additional approval and review requirements and establishment of specialized privacy roles and responsibilities.
Procedural mitigation measures may include modification of data collection and processing procedures, implementation of additional consent or notification mechanisms, enhancement of individual rights exercise procedures and establishment of additional audit and compliance verification activities.
Section 8.3: Continuous Privacy Monitoring and Improvement
RJV Technologies recognizes that privacy protection requires ongoing monitoring and continuous improvement rather than one-time implementation of privacy measures.
The Company has established comprehensive privacy monitoring and improvement frameworks that ensure privacy protections remain effective and adapt to changing circumstances, emerging threats and evolving regulatory requirements.
Privacy Performance Monitoring: The Company implements comprehensive privacy performance monitoring systems that track key privacy indicators across all business operations and processing activities.
Privacy performance metrics include data minimization effectiveness measures, consent management and withdrawal rates, individual rights request processing times and satisfaction scores, privacy incident frequency and severity indicators and compliance assessment results across different regulatory frameworks.
Performance monitoring includes automated monitoring systems that provide real time visibility into privacy performance indicators, regular privacy audits and assessments conducted by internal and external auditors, privacy risk assessments that evaluate emerging privacy threats and vulnerabilities and stakeholder feedback collection and analysis to understand privacy performance from external perspectives.
Continuous Improvement Processes: Privacy monitoring results are systematically analysed to identify opportunities for privacy protection enhancement and operational efficiency improvement.
Improvement processes include regular review of privacy policies and procedures to ensure continued effectiveness and relevance, evaluation of emerging privacy enhancing technologies and methodologies, assessment of industry best practices and regulatory guidance updates and implementation of privacy enhancement initiatives based on monitoring results and stakeholder feedback.
The Company maintains privacy improvement roadmaps that outline planned privacy enhancements and their implementation timelines ensuring that privacy protection continues to evolve and improve over time.
Improvement initiatives are prioritized based on their potential impact on privacy protection, feasibility of implementation, resource requirements and alignment with business objectives and regulatory expectations.
Privacy Innovation and Research: RJV Technologies actively engages in privacy innovation and research activities to advance the state of privacy protection technology and methodology.
Innovation activities include collaboration with academic researchers and privacy experts, participation in industry privacy research initiatives, development and testing of experimental privacy enhancing technologies and contribution to privacy standards development and best practice sharing.
Research activities are conducted with appropriate ethical oversight and privacy protection measures to ensure that research activities themselves do not compromise individual privacy or create new privacy risks.
The Company shares research results and privacy innovations with the broader privacy community to advance collective understanding and capability in privacy protection.
Conclusion and Commitment
This privacy policy represents RJV Technologies Ltd’s comprehensive commitment to protecting personal information and respecting individual privacy rights in all aspects of our operations.
We recognize that privacy protection is not a destination but an ongoing journey that requires continuous attention, improvement and adaptation to changing circumstances and evolving expectations.
We are committed to maintaining the highest standards of transparency, accountability and responsiveness in our privacy practices and we welcome feedback, questions and suggestions from individuals, customers, partners and other stakeholders who share our commitment to privacy protection.
Through ongoing dialogue and collaboration we will continue to enhance our privacy protections and contribute to the development of industry best practices that benefit everyone.
Our privacy policy is a living document that will be updated regularly to reflect changes in our practices, applicable laws, emerging technologies and stakeholder expectations.
We will provide clear notice of material changes to this policy and will seek additional consent when required by applicable law or when changes materially affect individual rights or our processing activities.
Thank you for taking the time to review our privacy policy and for entrusting RJV Technologies Ltd with your personal information.
We are honoured by that trust and are committed to earning and maintaining it through our actions, decisions and unwavering dedication to privacy protection.
IN WITNESS WHEREOF the parties have executed this Agreement as of the date first written above.
RJV TECHNOLOGIES LTD
Founder, Chairman & CEO
Ricardo Jorge do Vale
07/02/2025
Global Headquarters
RJV TECHNOLOGIES LTD
21 Lipton Road London United Kingdom E10 LJ
Company No: 11424986 | Status: Active
Type: Private Limited Company
Incorporated: 20 June 2018
Email: contact@rjvtechnologies.com
Phone: +44 (0)7583 118176
Branch: London (UK)
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