Privacy Policy

Intelligent Counting Ltd is as part of the Jonas Family of Companies (“Jonas,” “we,” “us,” ”our”) are committed to protecting your privacy. There are various ways that you might interact with Intelligent Counting Ltd, and the information you provide when doing so allows us to improve our services.

This website, our related websites and any mobile site or mobile application that link to this policy (individually, the “Site” and collectively “Sites”) are owned and operated by Intelligent Counting Ltd is as part of the Jonas Family of Companies. with its principal place of business at Hogwood Lane Industrial Estate, Reading, Berkshire, RG40 4QQ, United Kingdom.

This policy explains:


You should review this policy carefully, and be sure you understand it, prior to using the Site.  Your use of the Site is deemed to be acceptance of this policy.  If you do not agree to this policy, you should not use, and should immediately terminate your use of the Site.  For purposes of this policy, accessing the Site only to review this policy is not deemed to be use of the Site.

This Privacy Policy applies to Intelligent Counting Ltd is as part of the Jonas Family of Companies and their subsidiaries and affiliates and covers our processing activities as a data controller.

We do not sell our services to children and the Site is not intended for or directed at children under the age of 13 years. As such, our Sites are designed for adult user interaction. We do not intentionally collect personally identifiable information from children under the age of 13.

We are not required to appoint a formal data protection officer under data protection laws. However, we have appointed a Data Protection Contact who you can reach out to about any queries you may have in relation to this Privacy Policy. If you are located in the EEA, you can contact our representative(s) in the EEA about any data protection queries, using the contact details below.

Jonas adheres to Canadian and international statutes and regulations which govern the protection of personal information. In Canada Jonas adheres to the Personal Information and Protection of Electronic Documents Act (“PIPEDA”). In the United States, Jonas adheres to statutes of general application and statutes of specific application such as the Health Insurance Portability and Accountability Act (“HIPPA”) where applicable. In Australia, Jonas complies with the Privacy Act, 1988, a federal statute as well as with State and Territory laws pertaining to protection of personal information, including the Health Records Act 2001(VIC) where applicable. In New Zealand, Jonas follows the Privacy Act, 1993. In Europe, Jonas adheres to i) until 25 May 2018, EU Directive 95/46/EC, as transposed into domestic legislation of each Member State; ii) on and from 25 May 2018 the General Data Protection Regulation (EU) 2016/679 (“GDPR”); iii) as and when enacted in the United Kingdom, the Data Protection Act [2018], supplementing and amending the GDPR; iv) EU Directive 2002/58/EC on privacy and electronic communications, as transposed into domestic legislation of each Member State; and v) any applicable decisions, guidelines, guidance notes and codes of practice issued from time to time by courts, supervisory authorities and other applicable government authorities; in each case together with all laws implementing, replacing or supplementing the same.

Contacting Us

If you have any questions about our Privacy Policy or your information, or to exercise any of your rights as described in this Privacy Policy or under data protection laws, you can contact us as follows:

In the EEA

By post:

Intelligent Counting Ltd, Hogwood Lane Industrial Estate, Reading, Berkshire, RG40 4QQ, UK.

By telephone:

+44 (0) 118 932 4660

By email:


Information We Collect

Information Voluntarily Provided

We may collect or record basic personal data which you voluntarily provide through completing forms on the Site, through questions you send to us, or through other means of communication between you and us. The categories of personal information you provide may include:


Information from Site Visits

We collect, store, and use information about your visits to the Sites and about your computer, tablet, mobile or other device through which you access the Sites. This includes the following information:


Purposes for which we will Process Information Legal Basis under the UK GDPR, if applicable, for Processing
  • To provide you with information and materials that you request from us.
It is in our legitimate interests to respond to your queries and provide any information and materials requested in order to generate and develop business. To ensure we offer an efficient service, we consider this use to be proportionate and will not be prejudicial or detrimental to you.
  • To personalise our services and products and the Sites to you.
It is in our legitimate interests to improve the Site in order to enhance your experience on the Site, to facilitate system administration and better our services. We consider this use to be proportionate and will not be prejudicial or detrimental to you.
  • To update you on services, products and benefits we offer.
It is in our legitimate interests to market our services and products. We consider this use to be proportionate and will not be prejudicial or detrimental to you.

For direct marketing sent by email to new contacts (i.e. individuals who we have not previously engaged with), we need your consent to send you unsolicited direct marketing. Known as Opting in.

  • To send you information regarding changes to our policies, other terms and conditions and other administrative information.
It is in our legitimate interests to ensure that any changes to our policies, other terms and administrative information are communicated to you.  We consider this use to be necessary for our legitimate interests and will not be prejudicial or detrimental to you.
  • To administer the Sites including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • To help keep the Sites safe and secure.
For all these categories, it is in our legitimate interests to continually monitor and improve our services and your experience of the Sites and to have network security. We consider this use to be necessary for our legitimate interests and will not be prejudicial or detrimental to you.
  • To measure or understand the effectiveness of any marketing we provide to you and others, and to deliver relevant marketing to you.
It is in our legitimate interests to continually improve our offering and to develop our business. We consider this use to be necessary in order to effectively generate business and will not be prejudicial or detrimental to you.

For direct marketing sent by email to new contacts (i.e. individuals who we have not previously engaged with), we need your consent to send you unsolicited direct marketing. Known as Opting in.

  • To enforce the terms and conditions and any contracts entered into with you.
It is in our legitimate interests to enforce our terms and conditions of service. We consider this use to be necessary for our legitimate interests and proportionate.


Intelligent Counting Ltd as a Data Controller

As a data controller, we will only use your personal data in compliance with applicable law.  For example, under the UK GDPR, we may be required to have a legal basis for processing your personal data. The purpose for which we use and process your information and the legal basis on which we carry out each type of processing is explained in the table below.  Note that we may process your personal data for more than one legal basis.

Updating Your Information and Opting Out

If you do not wish to provide us with your personal data and processing such data is necessary for the performance of a contract with you and to fulfil our contractual obligations to you, we may not be able to perform our obligations under the contract between us. Where you provide consent, you can withdraw your consent at any time and free of charge, but without affecting the lawfulness of processing based on consent before its withdrawal.  No withdrawal of consent will be effective until we receive it and have had a reasonable period of time to act on it.  You can update your details or change your privacy preferences by contacting us as provided in “Contacting Us” below.

To review, correct, update, delete, object, or otherwise limit our use of your personal data that has been provided to us, or request portability and/or details of your personal data that is held by us, please contact us using the contact information listed below in the “Contacting Us” section and clearly describe your request.

You may unsubscribe from marketing communications at any time by clicking the “Unsubscribe” button available at the bottom of any electronic communication we may send to you. You may also unsubscribe from any medium of communication by contacting us using the information set out in the “Contacting Us” section below.

Jonas Software as a Data Processor

In certain cases, we also operate as a data processor and we collect, process, and transfer personal data on behalf of our business customers in the provision of our services and products. In these circumstances, Jonas Software is acting as a data processor and our business customers remain the data controller in respect of personal data they provide to us.

Our business customers remain the data controllers with respect to any personal data that they provide to us for our provision of services. To the extent that we are acting as data processor, we act in accordance with the instructions of such customers regarding the collection, processing, storage, deletion, and transfer of customer data, as well as other matters such as the provision of access to and rectification of personal data. We will only use such personal data for the purposes of providing the services and products for which our business customers have engaged us.

Our business customers are responsible for ensuring that these individuals’ privacy is respected, including communicating to the individuals in their own privacy policies who their personal data is being shared with and processed by. Where Jonas Software is acting as a data processor, we will refer any request from an individual for access to personal data which we hold about them to our customer. We will not usually respond directly to the request.

As a data processor, we may share personal data where instructed by our business customer. Where authorised by the business customer, we may also share personal data with third party service providers who work for us and who are subject to security and confidentiality obligations.

We will retain personal data which we process on behalf of our customers for as long as appropriate to provide services and products to our customers and in accordance with any agreement with our customers or as permitted by applicable law.

Disclosure Of Your Personal Data to Third Parties

We may share your personal data with our group companies, affiliates, subsidiaries, or contractors as appropriate to carry out the purposes for which the information was supplied or collected (i.e. to provide the services and products you have requested from us) or as otherwise provided in this policy. Personal data will also be shared with our third-party service providers and business partners who assist with the running of the Sites and our services and products (including hosting providers, email service providers and payment processing partners). Our third-party service providers and business partners are subject to security and confidentiality obligations and are only permitted to process your personal data for specified purposes and in accordance with our instructions.

In addition, we may disclose personal data about you when we believe that such use or disclosure is reasonably appropriate to: comply with any legal or regulatory obligation; enforce the terms of our agreements; establish, exercise or defend the rights of Jonas Software, our staff, customers or others; protect our rights, property, safety or vital interests, or the rights, property, safety or vital interests of our users or other third parties; and implement the purchase of all or substantially all of our assets, a merger, or other similar transaction that results in a change of control.

Changes to GDPR post Brexit

On top of the existing legislation, the UK government has issued a statutory instrument titled ‘The Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019’. In simple terms, this amends the original law and merges it with the requirements of GDPR. The outcome will be a new data protection framework known as the ‘UK GDPR’.

Once the UK leaves the EU, as a non-member state it will be reclassified as a ‘third country’.

Under GDPR (the EU version), transferring personal data from the European Economic Area (EAA) to third countries is permitted under the following agreement.

The ‘Trade and Cooperation Agreement’ contains a provision allowing data flows between the EU and UK to continue as they were pre-Brexit for a maximum of six months. In other words, data can still be transferred in the way it was pre-January 2021 until June this year.

The ICO will remain the independent supervisory body regarding the UK’s data protection legislation.

The UK government will continue to work towards maintaining close working relationships between the ICO and other countries’ supervisory authorities once the transition period ends.


International Transfers

If you are based in the EU or EEA

We may share your personal data within the Jonas group of companies. This involves transferring your data outside the European Economic Area (EEA) to Jonas’ affiliates and third-party service providers in Canada, United States, Australia, New Zealand, South Africa, and Malaysia. Canada and New Zealand have been deemed by the EU as having an adequate level of protection for personal data.

Whenever we transfer your personal data outside the EEA to the countries identified above which have not been deemed by the EU to have an adequate level of protection for personal data, and specifically to the United States, we ensure a similar degree of protection is afforded to it by using standard data protection clauses approved by the European Commission (as permitted under Article 46(2)(c)) that are designed to help safeguard your privacy rights or by certifying under the E.U.-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield.

Security Of Your Personal Data

The security of your personal data is important to us. We follow generally accepted industry standards to protect the personal data received by us. We use commercially reasonable measures to safeguard personal data, which measures are appropriate to the type of information maintained and follow applicable laws regarding the safeguarding of any such information under our control. No method of transmission over the Internet, or method of electronic storage, can be 100% secure. Therefore, we cannot guarantee the absolute security of your personal data. The Internet by its nature is a public forum, and we encourage you to use caution when disclosing information online. Often, you are in the best situation to protect yourself online. You are responsible for protecting your username and password from third party access, and for selecting passwords that are secure.

Data Retention: How Long We Keep Your Personal Data

We will retain personal data which we process on behalf of our customers for as long as appropriate to provide services and products to our customers in accordance with any agreement in place with our customers and for other legitimate purposes. When you contact us, we may keep a record of personal data contained in your communication to help solve any issues that you might be facing. Your personal data may be retained for as long as appropriate to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirement, and for other legitimate purposes.  In determining how long we will retain personal data; we will consider all relevant factors.

Your Rights

You may request from us access to, correction of, blocking of and/or deletion of your personal data in line with applicable law. You may also withdraw your consent for us to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. Where your personal data is processed by us with your consent or for the performance of a contract by automated means, we will, to the extent required by applicable law, provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format upon request.

Responding To Requests

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights) under applicable law. This is a security measure to protect personal data from being disclosed to any person who has no right to receive it. We may also contact you to ask for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. You will not have to pay a fee to access your personal data (or to exercise any of your other rights) under applicable law. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances. Also, please note that we may refuse a request for blocking and/or deletion where continued processing is necessary to comply with a legal obligation or necessary for the establishment, exercise, or defence of legal claims or for other purposes permitted by applicable law.

Use Of Cookies

We may collect data in connection with your use of the Sites using small files commonly known as “cookies”. A cookie is a small amount of data which often includes a unique identifier that is sent to your computer, mobile phone or other device from the Sites and is stored on your device’s browser or hard drive. We may also collect data that your browser sends to us, such as your IP address, browser type, location, language, access time and referring website addresses. Such data may be used to analyse trends, to administer the Site, to track your movements around the Site and to gather demographic data about our visitor base as a whole. The data gathered by these cookies is in the form of aggregated anonymous data.

By continuing to browse the Sites, you are agreeing to our use of cookies.

If you don’t want us to use cookies when you use the Sites, you can set your browser to not accept cookies or notify you when you receive a cookie, giving you the chance to decide whether to accept it or decline at any time. However, if you block cookies some of the features on the Sites may not function as a result.

You can find more information about how to do manage cookies for all the commonly used internet browsers by visiting This website will also explain how you can delete cookies which are already stored on your device.

The Sites’ use Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the Sites analyse how users use the Sites. The information generated by the cookie about your use of the Sites (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Sites, compiling reports on website activity for website operators 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 your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however, please note that if you do this you may not be able to use the full functionality of the Sites. By using the Sites, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

IP Addresses and Aggregate Information

An Internet Protocol (“IP”) address is associated with your computer’s connection to the internet. We may use your IP address to help diagnose problems with our server, to administer the Site and to maintain contact with you as you navigate through the Site. Your computer’s IP address also may be used to provide you with information based upon your navigation through the Site. Aggregate information is used to measure the visitors’ interest in, and use of, various areas of the Site and the various programs that we administer. We will rely upon aggregate information, which is information that does not identify you, such as statistical and navigational information. With this aggregate information, we may undertake statistical and other summary analyses of the visitors’ behaviours and characteristics. Although we may share this aggregate information with third parties, none of this information will allow anyone to identify you, or to determine anything else personal about you.

Links To Third Parties

Our Sites may contain links to third party websites. These third-party websites are operated by companies that are outside of our control, and your activities at those third-party websites will be governed by the policies and practices of those third parties. Jonas Software does not in any way endorse or make any representations about such third-party websites and applications. As such, Jonas Software is not responsible for the privacy practices or content of such third-party websites and applications that are subject to their own privacy policies. If you choose to access such links, we encourage you to review all third-party site privacy policies before submitting any of your personal data.

Social Media and Online Engagement

We occasionally use a variety of new technologies and social media options to communicate and interact with customers, potential customers, employees, and potential employees. These sites and applications include popular social networking and media sites, open source software communities and more. To better engage the public in ongoing dialog, certain of our businesses use certain third-party platforms including, but not limited to, Facebook, Twitter, LinkedIn, Instagram, Pinterest, and Google+. Third-Party Websites and Applications (TPWA) are Web-based technologies that are not exclusively operated or controlled by us. When interacting on those websites, you may reveal certain personal data to us or to third parties. Other than when used by our employees for the purpose of responding to a specific message or request, we will not use, share, or retain your personal data.


For the UK: You have the right to make a complaint at any time with a supervisory authority, in particular in the EU (or EEA) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at or telephone: 0303 123 1113.

If we receive formal written complaints, we will follow up with the person making the complaint. We work with the appropriate regulatory authorities to resolve any complaints that cannot be resolved directly. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us, as outlined in “Contacting us” above, in the first instance.

Changes to this policy

We regularly review our compliance with our privacy policy. We also adhere to several self-regulatory frameworks in addition to complying with applicable law.

We may change this privacy policy from time to time. If this privacy policy changes, the revised privacy policy will be posted at the “Privacy Policy” link on the Site’s home page. In the event that the change is significant or material, we will notify you of such a change by revising the link on the home page to read “Newly Revised Privacy Policy.” Please check the privacy policy frequently. Your continued use of the Site constitutes acceptance of such changes in the privacy policy, except where further steps are required by applicable law. This privacy policy was last updated on the date set out at the end of the policy.

LAST UPDATED: 04 March 2024