Introduction
Joolz Joseph (JJ) is committed to protecting privacy and providing a safe online experience. For offline privacy policy statements, please find the relevant section below.
GDPR stands for “The General Data Protection Regulation”, the new EU Data Protection Legislation.
The aim of the GDPR is to unify all EU member states’ approach to data regulation to ensure all data protection laws are applied identically in every country within the EU. It further directs that all organisations must use individuals’ data responsibly and gives the individual a voice as to what information is recorded and how it is shared.
The Data Protection Act 2018 supplements the GDPR and covers to certain types of processing to which the GDPR does not apply.
Privacy Summary
What do I collect and why?
Contact information so that I can communicate with you about any services I am providing to you or send you emails if you have consented to them.
How do I keep it safe?
Any 3rd party services are protected with a secure password.
Other data is stored on password protected computer with additional security software.
More Information
Please read the privacy policy in full.
Concerns?
For questions, a request for information held or deletion please call Joolz Joseph on 01707 258 959 or email hello@joolzjoseph.com
The detail
Terms
The following are the terms used in this document, including referenced legislations.
“Data” generally means information which are computerised or in a structured hard copy form.
“Personal Data” ‘ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
“special categories of personal data” is personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation shall be prohibited.
“Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
“Data Controller” means the natural or legal person, public authority, agency or other bodies which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;
The “Data Processor” means a natural or legal person, public authority, agency or other bodies which processes personal data on behalf of the controller.
“Data Subject” means an individual who is the subject of personal data. In other words, the data subject is the individual whom particular personal
About Us
Joolz Joseph (JJ) is the data controller and responsible for your personal data (collectively referred to as Joolz Joseph, The Virtual Marketeer, ‘we’, ‘us’ or ‘our’ in this privacy notice). In some circumstances, JJ also acts as a data processor (please see our data processing statement).
My contact details can be found on our website www.joolzjoseph.com/contact/
We use third-party organisations as defined below.
Use of Our Website
You can visit and read information on our website without giving us any personally identifiable information.
In order to provide you with the most efficient and enhanced personalised service and attention and to accommodate certain requests which you make, we request information about you in certain circumstances and collect certain information automatically.
Information We Collect
We may collect and/or receive the following types of information from you:
Personal Information
We do not collect any personal information from visitors who simply visit the Website, unless they provide such information voluntarily by registering at our Website or signing up for information.
You may be asked to provide personal information including your name, address, email address and phone number when you sign up for any of our newsletters, respond to a survey, register for a class, or purchase a product or service. Visitors are not required to provide this information. This information is collectively called “Personal Information.”
Order and Billing Information
If you place an order through our Website, we track certain information about the products and services you purchase. This is called the Order Information. At checkout, you may also be required to provide additional information including a debit or credit card or other payment information, expiration dates, card security codes, your billing address or similar information (collectively called the Billing Information). This information is provided to us, and it will also be collected and processed by third-party payment vendors pursuant to the terms and conditions of their Privacy Policies and terms of use.
Data We Store on Our Website
We do not store any personal data on our website.
When you contact us, your complete message is sent via email to us and not saved on the server on which your website is hosted.
Technical Information
In addition to the information described above, we may collect other information as follows:
- Internet Protocol (“IP”) addresses – which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or device;
- Web browser type, version and language;
- Referring and exit (web) pages and URLs;
- Date and time;
- The pages of our Website that you visit;
- The time spent on those pages and other statistics;
- Information about your device, operating system and version, carrier and country location, hardware and processor information, network type, and similar data.
Cookies
Our website may use cookies in order to deliver a better experience for you. Cookies are files with small amounts of data that a website stores on your computer or mobile device’s hard drive so that certain information about your visit and web-browsing preferences will be recognised upon a return visit. Cookies serve functions such as “remembering” log-in names (and sometimes passwords), or enabling or saving shopping basket contents. Like many websites, we may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to help us improve the experience you have with our Website. Most web browsers have a function that allows you to delete existing cookies on your device or you can set your browser options so that your device does not receive or accept cookies. Doing this may interfere with your ability to use the Website.
Third-Party Analytics
We use third-party analytics services (such as Google Analytics) to evaluate and aggregate visitor data. These services help us evaluate visitors’ use of the Website including time spent on certain pages, which areas of the Website receive the most traffic, how often visitors visit pages within the Website, provide general geographic location about visitors and the source of referred traffic (from other websites or via search engines, etc). These third party analytic services use cookies and other technologies to help analyze and provide us with the data. By visiting and using the Website, you consent to the collection and review of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy.
For more information on Google Analytics, including how to opt out from certain data collection, please visit https://www.google.com/analytics.
Please be aware that If you opt out of any service, you may not enjoy the full functionality of the Website.
Accessing Your Personal Information & Communication Preferences
If you have provided personal, billing or other voluntarily provided information, you may access, review and make changes to it via instructions found on the Website.
To manage your receipt of marketing and non-transactional communications, you may unsubscribe by clicking the “unsubscribe” link located on the bottom of any related email from the Company.
Emails relating to the purchase or delivery of orders are provided automatically – customers are not able to opt out of transactional emails. We will use commercially reasonable efforts to process any requests related to the management of Personal Information in a timely manner. However, it is not always possible to completely remove or modify information in our subscription databases.
Marketing emails that you have opted into will be sent via a 3rd party provider and may included a tracking pixel, enabling us to determine whether you opened or clicked on such emails.
How We Use & Share your data
We use the collected information to evaluate and administer our Website, fulfil your requests, respond to any problems that may arise, such as difficulties in navigating our Website or accessing certain features, and to gauge user trends.
We may also utilise and share information collected as required to process Customer Orders and provide necessary support.
As in any transaction, when you purchase products, services, or programs, your credit card company will have all relevant information about the name of the vendor, item(s) purchased, date, total cost and other information necessary to process the transaction. We will not otherwise provide any personal data to your credit card company without your permission. We may also access or utilise information collected to provide our services, process orders, administer our programs, maintain and improve our Website and services to you, solicit your feedback, and to inform you about our products and services and those of our third-party marketing partners.
We may share Information collected with joint venture partners, businesses under common control, third-party businesses or partners participating in administering our programs or services, or to those providing business functions such as technical support, customer service, marketing assistance, etc. These businesses will only have access to information as necessary to perform their functions and to the extent permitted by law. We may also analyse Order Information and other information in aggregate in order to improve our business products and services, and operate, maintain and manage the Website. Where necessary, we may share this aggregate data with our affiliates, agents and business partners. We may also disclose aggregated statistics in describing our products and services to current and prospective business partners and to other third parties for other lawful purposes.
Under certain circumstances we may be obligated or compelled to disclose the Information:
- When required by law, court order, or other government or law enforcement authority or regulatory agency;
- Whenever we believe that disclosing such Information is necessary or advisable to protect the rights, property or safety of the Company or others.
Please see the section Offline/how we use your data for examples of how your data may be used by us in various cases.
Data we collect and how we use it
We may collect personal data in a number of ways:
- Via our website;
- Via email;
- Via written communications;
- Via conversation.
We may collect the following data:
- Your name, email address, phone number;
- Names of guests/attendees of events that we provide services to you;
- Name and summary allergy condition – in the unlikely event of a HSE report being required.
- Behaviour and interactions with email communications.
How We Apply Data Protection
We comply with the data protection best practices by:
- Ensuring that data is collected and used fairly and lawfully;
- Processing personal data only in order to meet our operational needs or fulfil legal requirements;
- Taking steps to ensure that personal data is up to date and accurate;
- Establishing appropriate retention periods for personal data longer:
- than we need to provide you with our services and products;
- than the statutory requirement;
- Ensuring that data subjects’ rights can be appropriately exercised;
- Providing adequate security measures to protect personal data:
- IT systems are secured by passwords;
- IT systems are physically secured as part of standard operations;
- Hard copies of correspondence/documents are secured in a locked location;
- Informing ourselves and associates about privacy and data protection;
- Ensuring that all queries about data protection are dealt with effectively and promptly;
- Regularly reviewing data protection procedures and guidelines within the organisation.
We record the following to process your enquiries and orders:
- Full name;
- Address;
- Contact phone number;
- Contact email address;
- Requirements
We don’t record:
- Dates of birth or notable other dates (i.e. wedding anniversaries etc.);
- Sensitive information.
Security of Your Information
The security of your Personal Information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we incorporate standard industry practices internally and with our services providers, which we believe suits the degree of sensitivity of the information involved, we cannot guarantee its absolute security. Because we work with third-party businesses and vendors in various aspects of our business including operating this website, database management, website security, etc., we cannot guarantee the absolute security of our databases, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mail sent to or from the Website may not be secure, and you should therefore take special care in deciding what information you send to us via email.
External Websites
We do not control and are not responsible for the privacy practices or content of third-party websites, including those of affiliates, business partners, sponsors, advertisers, or other websites to which we may link from time to time. When visiting any third-party websites, you are responsible for reviewing the Privacy Policy and terms of use applicable to each site. They may be different than those that you see here.
Offline Data Processing
As part of our standard operations in running our business, the table below defines how and why we plan to use your personal data.
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Purpose/Activity
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Type of data
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Lawful basis for processing
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To register you as a new customer
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(a) Identity (b) Contact
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Performance of a contract with you
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To process/deliver your services including: (a) Manage payments, fees and charges (b) Collect/recover money owed to us
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(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications
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(a) Performance of a contract with you (b) Necessary for our legitimate interests to recover debts owed to us
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To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services |
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To enable you to partake in a prize draw, competition or complete a survey
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(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests to study how customers use our products/services, to develop them and grow our business
|
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To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
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(a) Identity (b) Contact (c) Technical
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(a) Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business re-organisation or group restructuring exercise (b) Necessary to comply with a legal obligation
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To deliver relevant content and advertisements to you and measure and understand the effectiveness of our advertising
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(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical
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Necessary for our legitimate interests to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy
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To use data analytics to improve our website, products/services, marketing, customer relationships, email communications and experiences
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(a) Technical (b) Usage
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Necessary for our legitimate interests to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy
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To make suggestions and recommendations to you about goods or services that may be of interest to you
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(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile
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Necessary for our legitimate interests to develop our products/services and grow our business
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Changes to This Privacy Policy
JJ may update this Privacy Policy from time to time as necessary to protect our users and to comply with a changing environment. We recommend that you check the Privacy Policy when you visit our Website to be sure that you are aware of and understand our current policy.
We have no intentions of making any changes to our Privacy Policy and practices to make them less protective of personal information collected in the past. By accessing the Website and/or using our services after making any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, our use of the information is governed by the Privacy Policy in effect at the time we collect the information. You are advised to review this Privacy Policy periodically for any changes.
Data Protection Controller
JJ is registered as a Data Processor with the Information Commissioners Office (ICO) under the Data Protection Act 1998 and The General Data Protection Regulation.
JJ’s Data Protection Officer (DPO) is Julie Joseph who also performs the role of Compliance Manager.
Responsibility for updating and dissemination of this policy rests with DPO. The policy is subject to regular review to reflect changes in legislation. All staff are required to understand, apply and abide by the policy and if in any doubt to seek advice.