Privacy Policy

Effective Date: March 1, 2026 | Last Updated: March 30, 2026

1. Introduction

New Kingston Janitorial ("NKJ," "the Company") is a commercial and residential cleaning service operated by Biznitos LTD, located at 5 Balmoral Ave, Suite J, Kingston, Jamaica. This Privacy Policy explains how NKJ collects, uses, stores, and protects your personal and business information when you use our website (newkingstonjanitorial.com), engage our cleaning services, or communicate with us through any channel.

Because NKJ staff physically enter your business premises, this policy goes beyond standard website privacy practices. It also covers how your facility information, physical access credentials, and on-site confidentiality are protected.

This policy is governed by the Jamaica Data Protection Act, 2020 (the "DPA"), enforced by the Office of the Information Commissioner of Jamaica. By engaging NKJ services or using our website, you acknowledge that you have read and understood this policy.

2. Information We Collect

2.1 Business Contact Information

When you request a quote, sign a contract, or communicate with NKJ, we collect:

Your name and job title
Business name, address, and type of facility
Email address, phone number, and WhatsApp number
Preferred method of communication

2.2 Facility Information

To provide accurate quotes and deliver cleaning services, we collect:

Facility size (square footage or number of rooms)
Floor plans, layout descriptions, and special cleaning areas
Cleaning schedule preferences and frequency
Special requirements (e.g., medical-grade cleaning, restricted areas, sensitive zones)

2.3 Physical Access Credentials

When you provide NKJ staff with access to your premises, we may receive and store:

Keys to your building, offices, or specific rooms
Alarm codes and security system instructions
Access cards, key fobs, or electronic credentials
Gate codes, parking instructions, and after-hours entry procedures
Contact information for on-site security personnel

2.4 Photographs and Visual Documentation

NKJ staff may take photographs of your premises for:

Before-and-after quality control documentation
Training materials for cleaning staff
Limited marketing purposes (only with your written consent and only after identifying information has been removed)

Section 4 of this policy covers photography practices in detail.

2.5 Communication Records

We retain records of communications between NKJ and your organization, including:

Emails and email attachments
WhatsApp messages and voice notes
Phone call logs (date, time, duration, but not recordings unless disclosed)
Written correspondence and signed documents

2.6 Website Usage Data

When you visit newkingstonjanitorial.com, we may collect:

IP address and approximate geographic location
Browser type, device type, and operating system
Pages visited, time spent on each page, and referral source
Cookies and similar tracking technologies (see Section 2.8)

2.7 Payment and Billing Information

For invoicing and payment processing, we collect:

Billing contact name and address
Tax registration number (TRN) for Jamaican businesses
Payment method details (bank transfer information or cheque details)
Invoice history and payment records

NKJ does not store credit card numbers. If you pay by card, the transaction is processed by a third-party payment processor that maintains its own privacy and security standards.

2.8 Cookies

Our website uses cookies to improve your browsing experience. These include:

Essential cookies: Required for the website to function (e.g., form submissions)
Analytics cookies: Help us understand how visitors use the site (e.g., Google Analytics)

You can disable cookies in your browser settings. Disabling essential cookies may affect website functionality.

2.9 What We Do NOT Collect

NKJ does not intentionally collect, record, or retain:

Information visible on your computer screens, documents, or files
Patient records, medical information, or health data visible at medical facilities
Financial records, account numbers, or transaction details visible at your premises
Legal documents, case files, or privileged communications visible at law firms
Personal information about your employees, customers, or visitors
Any confidential or proprietary business information observed during cleaning

Our staff are trained to disregard all such information. See Section 6 for our full confidentiality protocols.

3. How We Use Your Information

3.1 Providing Cleaning Services

Your facility information, access credentials, and contact details are used to:

Prepare accurate service quotes and proposals
Schedule and dispatch cleaning teams to your premises
Provide your cleaning team with the access information needed to enter and secure your building
Tailor cleaning procedures to your facility's specific needs

3.2 Quality Control and Supervision

Photographs and inspection notes are used to:

Verify that cleaning standards are met
Document issues that need attention or follow-up
Train staff on proper cleaning techniques for specific facility types
Resolve disputes about service quality

3.3 Marketing (With Your Consent)

With your explicit written consent, NKJ may use:

Before-and-after photographs with all identifying information removed or blurred
Your business name in a client list or testimonial (only if you have given specific permission)

You may withdraw marketing consent at any time by contacting us.

3.4 Communication

Your contact information is used to:

Confirm appointments and schedule changes
Send service reminders and follow-ups
Respond to your inquiries and service requests
Notify you of changes to your service agreement or this privacy policy

3.5 Billing and Invoicing

Your billing information is used to:

Generate and send invoices
Process payments and maintain financial records
Comply with Jamaican tax and accounting requirements

3.6 Legal Compliance

We may process your information to:

Comply with the Jamaica Data Protection Act, 2020
Comply with tax, employment, and business regulations in Jamaica
Respond to lawful requests from government authorities or courts
Establish, exercise, or defend legal claims

4. Photography and Visual Documentation

4.1 Purpose

NKJ takes photographs of client premises strictly for:

Quality control: Documenting the condition of your facility before and after cleaning
Training: Teaching staff proper cleaning methods for specific surfaces, equipment, or facility types
Marketing: Showcasing our work on our website, social media, or promotional materials (only with your written consent)

4.2 What We Photograph

Photos are limited to floors, surfaces, fixtures, windows, and other areas relevant to cleaning work. NKJ staff are instructed to avoid capturing:

Computer screens, monitors, or digital displays
Documents, files, folders, or paperwork
Whiteboards, notice boards, or internal communications
Personal belongings of your employees or visitors
Any area you have designated as a no-photography zone

4.3 Removing Identifying Information

Before any photograph is used externally (on our website, social media, or marketing materials), NKJ will:

Blur or crop out company logos, signage, and branding
Remove or obscure any visible names, text, or identifying details
Ensure the photo cannot reasonably be used to identify your business or location

4.4 Your Right to Opt Out

You may opt out of marketing photography entirely. Simply notify us in writing (email is acceptable), and NKJ will not use any photographs of your premises for marketing purposes. This does not affect our ability to take photos for internal quality control.

4.5 Photo Storage and Deletion

Quality control photos are stored on secure, access-restricted devices and cloud storage
Access is limited to NKJ supervisors and management
Quality control photos are retained for no longer than 6 months, then permanently deleted
Marketing photos (where consent has been given) may be retained for the duration of your service contract
You may request deletion of any or all photographs of your premises at any time by contacting us

4.6 Restricted Areas

NKJ will not photograph areas that contain confidential or sensitive information unless you have specifically agreed in writing. If your facility includes areas where photography is prohibited (e.g., server rooms, records archives, patient areas), please inform us and we will mark those zones as no-photography areas in our internal records.

5. Physical Access and Security Credentials

5.1 Secure Storage

Keys, access cards, alarm codes, and other physical or digital credentials entrusted to NKJ are:

Stored in a locked, access-controlled key safe at our office
Logged with a chain-of-custody record showing who has possession at all times
Never duplicated without your written authorization
Never shared with anyone outside NKJ without your written authorization

5.2 Access Restrictions

Your credentials are accessible only to:

The cleaning team assigned to your premises
NKJ supervisors and management responsible for your account

Alarm codes and electronic access credentials are stored digitally using password-protected systems. Paper-based credentials (written codes, instructions) are kept in sealed envelopes inside our key safe.

5.3 Credential Return and Destruction

Upon termination or expiration of your service contract:

All physical keys, access cards, and fobs will be returned to you within 7 business days
All stored alarm codes, gate codes, and digital credentials will be permanently deleted within 7 business days
You will receive written confirmation that all credentials have been returned or destroyed

5.4 Breach Notification

If NKJ becomes aware that your physical access credentials have been lost, stolen, or compromised:

We will notify you immediately (within 24 hours of discovery) by phone and email
We will notify the Office of the Information Commissioner within 72 hours, as required by the DPA
We will cooperate fully with you to re-secure your premises (e.g., changing locks, resetting alarm codes)
We will conduct an internal investigation and provide you with a written incident report

5.5 Staff Training

All NKJ staff who handle client credentials are trained on:

Proper handling and storage of keys and access devices
The confidentiality of alarm codes and security procedures
Immediate reporting of any lost or compromised credentials
Prohibition on sharing credentials with unauthorized persons

6. Confidentiality of Client Premises

6.1 General Confidentiality Obligation

NKJ recognizes that our cleaning staff enter private spaces where confidential information may be visible. All NKJ employees sign a confidentiality agreement as a condition of employment. This agreement requires staff to:

Disregard and never record, copy, photograph, or discuss any confidential information observed on client premises
Refrain from reading documents, screens, files, or correspondence
Report immediately to NKJ management if they are inadvertently exposed to highly sensitive information
Never remove any item (documents, media, equipment, or personal belongings) from a client's premises

6.2 Mobile Phone and Camera Policy

NKJ staff are prohibited from using personal mobile phones or cameras on client premises except when specifically authorized by an NKJ supervisor for quality control photography. Staff found in violation of this policy are subject to disciplinary action, up to and including termination.

6.3 Medical Facilities

If your facility is a medical office, clinic, hospital, or any healthcare-related environment, NKJ staff receive additional training on:

Avoiding areas where patient records, charts, or medical files are visible
Never reading, discussing, or recording any patient information
Handling medical waste areas only as specifically instructed by your facility manager
Compliance with your facility's own privacy and confidentiality requirements

NKJ will work with your compliance team to establish cleaning protocols that respect patient confidentiality.

6.4 Financial Institutions

For banks, credit unions, accounting firms, and other financial institutions, NKJ applies additional protocols:

Cash-handling areas, vaults, and teller stations are cleaned only under supervision or according to your specified procedures
Staff are trained never to touch, move, or handle cash, cheques, financial instruments, or sensitive financial documents
Cleaning of ATM areas, safe deposit areas, and restricted zones follows your institution's security guidelines

6.5 Law Firms and Legal Offices

For law firms and legal offices, NKJ recognizes the importance of attorney-client privilege and applies these protocols:

Staff are trained never to read, photograph, or discuss any documents, files, or case materials
Desks with open files or documents are cleaned around (not moved) unless you provide other instructions
Confidential waste bins and shredder areas are handled per your firm's instructions

6.6 Reporting Obligations

NKJ staff are instructed to report to NKJ management if they witness illegal activity on client premises (e.g., evidence of a crime). NKJ will comply with any legal obligations to report such activity to the appropriate authorities. Except where required by law, NKJ will not voluntarily disclose information about your premises to third parties.

7. WhatsApp and Electronic Communications

7.1 Use of WhatsApp

NKJ uses WhatsApp Business for day-to-day communication with clients, including:

Scheduling confirmations and appointment reminders
Service updates and follow-up messages
Sharing quality control photos (sent directly to you, not posted publicly)
Responding to your inquiries

7.2 WhatsApp Data Handling

WhatsApp messages are end-to-end encrypted by default through WhatsApp's platform
NKJ may retain WhatsApp message history for service record-keeping and dispute resolution
NKJ will not share your WhatsApp conversations with third parties unless required by law
NKJ will not add your number to WhatsApp broadcast lists or group chats without your consent

7.3 Opting Out of WhatsApp

If you prefer not to communicate via WhatsApp, you may request that all communication be conducted by email or phone. Contact us at [email protected] to update your communication preferences.

7.4 Third-Party Platform Disclaimer

WhatsApp is owned and operated by Meta Platforms, Inc. NKJ does not control WhatsApp's data collection, storage, or privacy practices. For information about how WhatsApp handles your data, please review WhatsApp's Privacy Policy.

8. Data Sharing

8.1 We Do Not Sell Your Data

NKJ does not sell, rent, or trade your personal or business information to third parties for marketing or any other purpose.

8.2 Limited Sharing

NKJ may share your information with the following parties, only to the extent necessary:

Insurance providers: In the event of a claim related to services performed at your premises
Subcontractors: If NKJ engages a subcontractor to assist with your cleaning services, they will receive only the information needed to perform the work and will be bound by confidentiality obligations
Professional advisors: Our accountants, attorneys, or auditors, who are bound by professional confidentiality obligations
Payment processors: To process your payments securely

8.3 Legal Disclosure

NKJ will disclose your information to law enforcement, government authorities, or courts only when:

Required by a valid court order, subpoena, or other legal process under Jamaican law
Necessary to comply with the Jamaica Data Protection Act, 2020 or other applicable legislation
Required to protect the safety of NKJ staff, your employees, or the public

9. Data Security

9.1 Physical Security

Client keys and access devices are stored in a locked key safe with restricted access
Paper records containing client information are kept in locked filing cabinets
Our office premises are secured with locks and alarm systems

9.2 Digital Security

Client data is stored on password-protected devices and cloud platforms
Access to client records is restricted to authorized NKJ personnel
Our website uses HTTPS encryption for all data transmissions
We use reputable, security-compliant cloud storage providers

9.3 Staff Training

All staff receive privacy and confidentiality training upon hiring and annually thereafter
Staff sign confidentiality agreements covering client data and premises
Violations of privacy or confidentiality policies result in disciplinary action, up to and including termination

9.4 Incident Response

In the event of a data breach or security incident:

NKJ will contain the breach and assess its scope immediately
Affected clients will be notified within 72 hours, as required by the DPA
The Office of the Information Commissioner will be notified within 72 hours
NKJ will take corrective action to prevent recurrence and will provide a written incident report to affected clients

10. Data Retention

10.1 Active Client Data

Your business contact information, facility details, and service records are retained for the duration of your service contract plus 12 months after the contract ends.

10.2 Photographs

Quality control photographs are retained for a maximum of 6 months, then permanently deleted. Marketing photographs (where you have given consent) are retained for the duration of your service contract. All photos are deleted within 30 days of your withdrawal of consent or contract termination, whichever comes first.

10.3 Physical Access Credentials

All keys, access cards, and security codes are returned or destroyed within 7 business days of contract termination, as described in Section 5.3.

10.4 Billing and Financial Records

Invoices, payment records, and tax-related documents are retained for 7 years, as required by the Jamaica Revenue Administration Act and the Income Tax Act for business record-keeping.

10.5 Communication Records

Emails, WhatsApp messages, and other correspondence are retained for the duration of your contract plus 12 months, unless a longer retention period is required for legal or regulatory purposes.

10.6 Website Data

Website analytics data is retained in aggregated, anonymized form. Cookies expire according to their individual settings (typically 30 days to 12 months).

11. Your Rights Under the Jamaica Data Protection Act, 2020

As a data subject under the DPA, you have the following rights:

Right of access: You may request a copy of all personal data NKJ holds about you or your organization.
Right to rectification: You may request correction of any inaccurate or incomplete data.
Right to erasure: You may request deletion of your personal data, subject to our legal obligations to retain certain records (e.g., tax records).
Right to withdraw consent: You may withdraw consent for marketing photography or any other consent-based processing at any time.
Right to object: You may object to the processing of your data under certain circumstances.
Right not to be subject to automated decision-making: NKJ does not use automated decision-making or profiling systems.
Right to opt out of marketing photography: You may instruct NKJ not to use any photographs of your premises for marketing purposes.
Right to credential return: You may request the immediate return of all physical access credentials at any time, regardless of contract status.
Right to complain: If you believe NKJ has violated your data protection rights, you have the right to file a complaint with the Office of the Information Commissioner of Jamaica.

To exercise any of these rights, contact us at [email protected] or call 876-676-6994. We will respond to your request within 30 days.

12. Children's Privacy

NKJ's services are directed at businesses and adults. We do not knowingly collect personal information from children under the age of 18. If you operate a childcare facility, school, or similar premises, NKJ staff follow the same confidentiality protocols described in Section 6, with particular care not to photograph, record, or interact with children on the premises.

13. Changes to This Policy

NKJ may update this Privacy Policy from time to time to reflect changes in our practices, Jamaican law, or regulatory guidance. When changes are made:

The "Last Updated" date at the top of this page will be revised
Active clients will be notified of material changes by email
The updated policy will be posted on our website at newkingstonjanitorial.com/privacy

Your continued use of NKJ services after a policy update constitutes your acceptance of the revised policy.

14. Contact Information

If you have questions about this Privacy Policy, wish to exercise your data rights, or need to report a privacy concern, please contact us:

New Kingston Janitorial (operated by Biznitos LTD)
Address: 5 Balmoral Ave, Suite J, Kingston, Jamaica
Email: [email protected]
Phone: 876-676-6994
Website: newkingstonjanitorial.com

If you are not satisfied with our response, you may contact the Office of the Information Commissioner of Jamaica:

Website: oic.gov.jm
Address: Office of the Information Commissioner, 58-60 Grenada Crescent, Kingston 5, Jamaica