The ownership of this website belongs to JNE Software and Marketing Services Ltd, registered at 14 Antim I Str., Office 3 on the 3th floor., Sofia, 1303, Bulgaria, www.jnesoftware.com („the company”, „company”, „we”, „us” or „our”). It is our policy to respect the confidentiality of information and the privacy of individuals. We are also bound by principles contained in the Law on Processing of Personal Data (Protection of the Individual), the EU e-Privacy Directive.

At JNE Software, we fully understand how important it is to protect our clients’ personal information. This document sets out our Privacy Policy / “the Policy” / commitment in respect to the information that we hold about our clients and what we do with such information. We recognize that any personal information we collect about the client will only be used for the purposes we have collected it for, or as allowed under the applicable acts of legislation.

JNE Software respects the privacy of any user that accesses its website, therefore, we are committed to taking all reasonable steps in order to safeguard information related to any existing or prospective clients, applicants or visitors. Before submitting any personal data, a person should examine the given terms and should only continue by agreeing with the Terms in the given Privacy Policy with principles set for data transfer, storage and processing.

JNE Software is entitled to unilaterally amend the given principles at any time by notifying the clients no later than 14 days prior to any significant amendments via the JNE Software website or emails.

  • Definitions

  • Client – means any natural or legal person who has entered into a client relationship with JNE Software and is actively using, or has used, the services of JNE Software until the termination of the client relationship. A prospective client is a natural or legal person who intends to use the services of JNE Software and has contacted JNE Software by the contact form on our website including by giving his name (without concluding the client relationship).
  • Client Data – means information that is known to JNE Software about the client and that is processed by JNE Software. When this document refers to ‘personal information’, it means information from which the client’s identity is reasonably apparent. The various categories of client data are specified in point 5 of this document.
  • Processing of Client Data – means any action that is performed with the client data, including gathering, recording, structuring, safe keeping, changing, forwarding, deleting, archiving, etc.
  • Data Processor – JNE Software provides software products and services and is the data processor of client’s personal information in relation to those services.
  • Authorized Processor – JNE Software may also use authorized external processors for client data processing, based on concluded service agreements, which are governed by instructions from JNE Software for the protection of client related data. Such external processors might be identity check providers or payment providers, credit institutions /in this case your personal data will be given for the payment of the services and products we provide to you or for refund in case that you are unhappy with our products or services/.

    Consent to Process Data

  • Initial registration – In order to contact us, a person must fill the contact form on our website and to agree with the terms listed in the given Privacy Policy. The Client confirms acceptance of these terms by ticking the corresponding box on the “Contact us” form. If such consent is not given, JNE Software cannot process a persons’ data, nor provide any services to the person in question.
  • Attending courses and participating in campaigns – The client’s data will be processed when registering for the offered webinars or seminars, or when landing on any of JNE Softwares’ campaign pages that require registration – as JNE Software will need to use a client’s personal information to perform its services and comply with its obligations. In all such cases, a client’s consent for data processing will be gathered through the registration form that they use to sign up.
  • Cancellation of the initial contact – When a person cancels the contact process and does not complete it, that person ‘s data will not be retrieved by JNE Software and will, therefore, not be saved for further processing in the future.
  • Declining the option to be contacted via phone – A person always has the right to request not to be contacted via telephone by a JNE Software representative. This request will be saved within JNE Software internal systems and acts as a separate restriction which JNE Software will, of course, be respected. The request to not to be contacted via telephone does not affect a client from using JNE Software’s services. Additionally, this does not restrict said person to contact JNE Software by their own initiative.

    Subscription to Marketing Related Emails

  • A person has the right to choose whether or not to receive marketing related emails (such as company news, information about campaigns and other similar updates to enhance client knowledge related to the financial software, etc.) to their submitted email address. Such a preference can also be changed at any time through the email or by contacting us and requesting so. It’s also possible to unsubscribe from these marketing emails by clicking the link within the emails that have already been received.

    The Purposes of the Collection of Client Data

JNE Software needs to collect various data in order to set a person up as a client, as well as provide various aspects of its services. This data is collected for the below mentioned reasons.

  • Verification of identify. JNE Software has to verify a person’s identity before entering into a client relationship according to the money laundering and fraud prevention checks. For this, JNE Software can use third parties which carry out identity checks on its behalf.
  • Internal business purposes and record keeping. JNE Software needs to process clients’ personal information for internal business and record keeping purposes. Such processing is in JNE Software’s own legitimate interests to comply with its legal obligations. This may include any communications that JNE Software has with a client in relation to the services it provides. JNE Software will also keep records that ensure that a client complies with its obligations.
  • Marketing. JNE Software may use client data, such as location or log history to deliver tailored content, such as news, analysis, research, reports, campaigns and training opportunities that may interest the client, to their registered email address. A client always retains the ability to change their preference if they wish or no longer wish to receive such communications.
  • Improvement of JNE Software products and services. JNE Software may, from time to time, use client data to help it analyse and improve its products and services.
  • To investigate or settle enquiries or disputes. JNE Software ts may need to use collected client data in order to comply with applicable laws, court orders, or other judicial process or requirements of any applicable regulatory authorities. Personal data can also be processed to settle disputes with the client.
  • To send client surveys. JNE Software may send client surveys as part of its customer feedback process as it is in its legitimate interest to ask for feedback to ensure that it provide the best service to its clients.
  • Website data analysis. Please find here detailed review about website data analysis which is also included in our Cookie Disclosure.

JNE Software may obtain information about a person by accessing cookies (text files which are stored on your computer or other access device) when a person visit our website or use our services. Cookies store small pieces of information, such as names and email addresses. We are able to do this by using web beacons (also known as clear GIFS or web bugs). Web beacons do not store additional information on your computer but, by communicating with our cookies on a person computer, they can remember things about our website, which we use to improve a person user experience. We use functionality cookies to analyze how visitors use our website and to monitor website performance and functions. This allows us to provide a high-quality customer experience by quickly identifying and fixing any issues that arise. For example, we might use performance cookies to keep track which pages are most popular and which method of linking between website pages is most effective. Functionality cookies are used by our website to allow us to remember a person preferences and identify a person as a user, ensure a person information is secure and to operate more reliably and efficiently. For example, cookies save you the trouble of typing in a person username every time he access his user profile on our website, and recall his preferences, such as which language he wishes to see when he log in. A person can delete cookies any time he want by using the settings in his web browser. A person can also use his web browser to disable cookies, although this and other websites may not function properly if he do this and he may not be able to sign in. Further information on deleting or controlling cookies is available at www.AboutCookies.org. This website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses “analytical cookies” placed on your computer to help the website analyze a user’s use of the site. The information generated by the cookie about a person use of the website (including IP address) may be transmitted to and stored by Google on their servers. Google may use this information for evaluating the use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate a person IP address with any other data held. By using this website, a person consent to the processing of data about him by Google in the manner and for the purposes set out above.

  • Security. If a client enters into any JNE Software premises, JNE Software may record the client’s image on its cameras, for security purposes. JNE Software may also use client details to keep a record of who has entered JNE Software premises on any given day. It is in JNE Softwares’ legitimate interest to do this to maintain a safe and secure working environment.

    Categories of Client Data

Client data may be collected from the client, from the client’s use of the services and from external sources, such as public and private registers. When the client visit our website or use our services, we may also log his IP address, a unique identifier for his computer or other access device (such as an iPad or iPhone). JNE Software has the right and the duty by virtue of its area of activity to check the accuracy of the client data contained in the databases by periodically asking the client to review and/or correct or confirm the accuracy of the client data pertaining to the client. JNE Software does  not collect sensitive information about the client. Client data categories which are primarily collected and processed by JNE Software consist of the following:

  • Identification data – such as name, date of birth, personal identification code and data regarding the identification document (such as copy of the passport or ID card).
  • Contact data – such as physical address, email address, telephone number and language of communication.
  • Data about the origin of assets– such as data regarding the client’s transaction partners and business activities (for the prevention of, for example, money laundering or the financing of terrorism).
  • Data that enables JNE Software to perform its due diligence measures regarding the prevention of money laundering and terrorist financing and to ensure compliance with international sanctions.
  • Data related to JNE Software’ services – such as the used services, bought products,, submitted applications, requests, complaints and applied service fees.
  • Data about habits, preferences and satisfaction – such as data about preferences, satisfaction and activeness of using the services, services used, personal settings, survey responses, etc.
  • Data about participation in campaigns – such as the points gained and prizes won in games or campaigns.

    Contacting JNE Software by Email /Contact form

When you email JNE Software (via the ‘Contact Us’ page), a person will be requested to provide some additional personal data, like their name or email address. Such data will be used to respond to their query and verify their identity. Emails are stored on JNE Software standard internal contact systems which are secure and cannot be accessed by unauthorized external parties.

  • Recipients of Client Data

If necessary, client data is shared with other recipients, such as:

  • Authorities, such as law enforcement authorities, notary offices, tax authorities, supervision authorities and financial intelligence units.
  • Institutions providing financial services, for example banks, payment systems, institutions.
  • Auditors, legal and financial consultants, or any other processor authorized by JNE Software.
  • Third parties maintaining registers (such as to credit registers, population registers, commercial registers, securities registers or other registers holding or intermediating client data).
  • Debt collectors upon assignment of claims, courts and bankruptcy or insolvency administrators.
  • Other persons related to the provision of services of JNE Software, such as service providers of archiving and postal services.
  • JNE Software may use other external authorized processors for processing client data. In such cases, JNE Software takes the needed steps to ensure that such data processors process client data under the instructions of JNE Software with adequate security measures.
  • JNE Software may share client data in the event of a merge, sale, restructure, acquisition, joint venture, assignment, transfer or other disposition of all or any portion of JNE Software’ business, assets or stock (including in connection with any bankruptcy or similar proceedings).

    Client Rights

JNE Software respects clients’ rights to access and control their personal data. JNE Software will respond to requests concerning personal data processing and, when applicable, JNE Software will give access to, correct or delete such personal data.

  • Review of client data processing. Upon request by the client, JNE Software shall provide a review of the gathered client data which is available in its client database. Before providing such a review, JNE Software will ask the individual to prove their identity in order to reduce the risks of identity fraud.
  • Correction of data. If the personal information JNE Software holds concerning the client is inaccurate or incomplete, the client is entitled to have it corrected by JNE Software. JNE Software may request additional information and documentation required to validate the need for the requested change of data.
  • Restrict processing. A client may ask JNE Software to restrict the use of client data for marketing purposes.
  • Deletion. A client may ask JNE Software to delete the personal data that it holds. The request to delete an individual’s personal data will result in removal of their data from active processing and a termination of the client relationship. However, JNE Software is required to maintain the client’s personal data to comply with its legal requirements. JNE Software shall preserve data for at least five years following the termination of the client relationship, unless other terms for the preservation of data or documents are prescribed by law. Unnecessary client data shall be deleted or destroyed.

    Organizational, Physical and IT Security Measures

JNE Software ensures, within the framework of applicable laws, that client data is safeguarded with the appropriate technical and organizational measures to prevent unauthorized access, unlawful processing or disclosure, accidental loss, modification or destruction. JNE Software shall implement the organizational, physical, IT and other necessary security measures to ensure the protection of Client Data and to monitor the processing of Client Data. Among other things, such security measures shall include the following activities:

  • implementation by JNE Software through its internal rules of the requirements for processing, registering and recording client data as well as procedures for checking the compliance with those requirements.
  • authorization of JNE Software employees to access only necessary client data in a client database, which is strictly in accordance with the job duties performed.
  • imposing an obligation of confidentiality on JNE Software employees responsible for handling client data.
  • unauthorized processing of data (including recording, alteration, deletion, reading, copying, (transmission), unauthorized transportation of records and any other unauthorized use of data (not prescribed by official duties) shall be prohibited.
  • Adequate security measures, including encryption of data where necessary, shall be implemented upon transmission of data by means of data communication equipment or in the transport of records.
  • Every user of the client database shall be issued a personal means of authentication, enabling them to use the database.
  • JNE Software shall implement adequate and sufficient measures to ensure that every data processing operation leaves a trace, which would afterwards enable identification of the person who performed the operation, the nature and time of the operation and any other relevant facts, including when, by whom and which data were recorded, altered or deleted, or when, by whom and which data in the data processing system were accessed, as well as information on any transmission of data. A possibility for restoring the content of the data before modifications shall be available when any modifications are made to the data or documents.
  • Transmission of information via regular email exchange is not always completely secure. JNE Software however exercises all endeavors to protect clients’ personal data, yet it cannot guarantee the security of client data that is transmitted via email; any transmission is at the clients’ own risk. Once JNE Software has received the client information it will use procedures and security features in an attempt to prevent unauthorized access.

    The Geographical Area of Processing

  • As a general rule, the client data is processed within the European Union/European Economic Area (EU/EEA), but in some cases it is transferred to and processed in countries outside the EU/EEA.
  • The transfer and processing of client data outside the EU/EEA can take place provided there are appropriate safeguards in place and the actions are made based on a legal basis only.
  • Upon request, the client may receive further details on client data transfers to countries outside the EU/EEA.

    Data Portability

The client has the right to obtain personal information held by JNE Software,  provided that JNE Software has this in a structured, commonly used and machine-readable format, and to reuse it elsewhere or ask JNE Software to transfer this to a third party of the client’s choice. In case of the forwarding of data to a third party, a clear written consent from the client must be received and verified.

  • Contact Details

  • In case of questions about the content of this JNE Software, if an individual would like a copy of the data JNE Software has collected on them, or would like to raise a complaint or other comment with regards to data processing, please contact us on: info@jnesoftware.com
  • The client has the right go to court or to escalate their complaint to the data protection regulator in their jurisdiction for the protection of rights, unless the applicable laws prescribe a different procedure for handling such claims.