Website
Privacy Policy
INTRODUCTION
Welcome to J4L Group
Limited's privacy policy.
J4L
Group Limited respects your privacy and is committed to protecting
your personal data. This privacy policy will inform you as to how we
look after your personal data when you visit our website (regardless
of where you visit it from) and tell you about your privacy rights
and how the law protects you.
You
can download a pdf version of the policy here: [INSERT LINK]. Please
also use the Glossary to understand the meaning of some of the terms
used in this privacy policy.
1. IMPORTANT
INFORMATION AND WHO WE ARE
PURPOSE
OF THIS PRIVACY POLICY
This
privacy policy aims to give you information on how J4L Group Limited
collects and processes your personal data through your use of this
website, including any data you may provide through this website when
you subscribe to our services.
This website is not intended
for children and we do not knowingly collect data relating to
children.
It is
important that you read this privacy policy together with any other
privacy policy or fair processing policy we may provide on specific
occasions when we are collecting or processing personal data about
you so that you are fully aware of how and why we are using your
data. This privacy policy supplements other notices and privacy
policies and is not intended to override them.
CONTROLLER
J4L
Group Limited is the controller and responsible for your personal
data (collectively referred to as ”the COMPANY”, “we”,
“us” or “our” in this privacy policy).
We
have appointed a data privacy manager who is responsible for
overseeing questions in relation to this privacy policy. If you have
any questions about this privacy policy, including any requests to
exercise your
legal rights,
please contact the data privacy manager using the details set out
below.
CONTACT
DETAILS
If you have any questions
about this privacy policy or our privacy practices, please contact
our data privacy manager in the following way:
J4L
Group limited
Email address:
admin@contractfinderpro.com.
You
have the right to make a complaint at any time to the Information
Commissioner’s Office (ICO), the UK supervisory authority for
data protection issues (www.ico.org.uk).
We would, however, appreciate the chance to deal with your concerns
before you approach the ICO so please contact us in the first
instance.
CHANGES
TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
We
keep our privacy policy under regular review. This version was last
updated on [INSERT DATE].
It is important that the
personal data we hold about you is accurate and current. Please keep
us informed if your personal data changes during your relationship
with us.
THIRD-PARTY
LINKS
This
website may include links to third-party websites, plug-ins and
applications. Clicking on those links or enabling those connections
may allow third parties to collect or share data about you. We do not
control these third-party websites and are not responsible for their
privacy statements. When you leave our website, we encourage you to
read the privacy policy of every website you visit.
2. THE
DATA WE COLLECT ABOUT YOU
Personal
data, or personal information, means any information about an
individual from which that person can be identified. It does not
include data where the identity has been removed (anonymous data).
We may
collect, use, store and transfer different kinds of personal data
about you which we have grouped together as follows:
Identity
Data
includes first name, maiden name, last name, username or similar
identifier, marital status, title, date of birth and gender.
Contact
Data
includes billing address, delivery address, email address and
telephone numbers.
Financial
Data
includes bank account and payment card details.
Transaction
Data
includes details about payments to and from you and other details of
products and services you have purchased from us.
Technical
Data
includes internet protocol (IP) address, your login data, browser
type and version, time zone setting and location, browser plug-in
types and versions, operating system and platform, and other
technology on the devices you use to access this website.
Profile
Data includes
your username and password, purchases or orders made by you, your
interests, preferences, feedback and survey responses.
Usage
Data
includes information about how you use our website, products and
services.
Marketing
and Communications Data includes
your preferences in receiving marketing from us and our third
parties and your communication preferences.
We
also collect, use and share Aggregated
Data
such as statistical or demographic data for any purpose. Aggregated
Data could be derived from your personal data but is not considered
personal data in law as this data will not
directly or indirectly reveal your identity. For example, we may
aggregate your Usage Data to calculate the percentage of users
accessing a specific website feature. However, if we combine or
connect Aggregated Data with your personal data so that it can
directly or indirectly identify you, we treat the combined data as
personal data which will be used in accordance with this privacy
policy.
We do
not collect any Special
Categories of Personal Data
about you (this includes details about your race or ethnicity,
religious or philosophical beliefs, sex life, sexual orientation,
political opinions, trade union membership, information about your
health, and genetic and biometric data). Nor do we collect any
information about criminal convictions and offences.
IF
YOU FAIL TO PROVIDE PERSONAL DATA
Where
we need to collect personal data by law, or under the terms of a
contract we have with you, and you fail to provide that data when
requested, we may not be able to perform the contract we have or are
trying to enter into with you (for example, to provide you with goods
or services). In this case, we may have to cancel a product or
service you have with us but we will notify you if this is the case
at the time.
3. HOW
IS YOUR PERSONAL DATA COLLECTED?
We use different methods to
collect data from and about you including through:
Direct
interactions.
You may give us your Identity, Contact and Financial Data by filling
in forms or by corresponding with us by post, phone, email or
otherwise. This includes personal data you provide when you:
apply
for our products or services;
create
an account on our website;
subscribe
to our service or publications;
request
marketing to be sent to you;
enter
a competition, promotion or survey; or
give
us feedback or contact us.
Automated
technologies or interactions.
As you interact with our website, we will automatically collect
Technical Data about your equipment, browsing actions and patterns.
We collect this personal data by using cookies, server logs and
other similar technologies. We may also receive Technical Data about
you if you visit other websites employing our cookies. Please see
our cookie policy for further details.
Third
parties or publicly available sources.
We may receive personal data about you from various third parties
and public sources as set out below:
Technical
Data from the following parties:
(a) analytics
providers such as Google based outside the EU;
(b) advertising
networks such as Linkedin based outside the EU; and
(c) search
information providers such as Google based outside the EU.
Contact,
Financial and Transaction Data from providers of technical, payment
and delivery services such as Stripe based outside the EU.
Identity
and Contact Data from data brokers or aggregators such as Linkedin
based outside the EU.
Identity
and Contact Data from publicly available sources such as Companies
House, the Electoral Register and HMG based inside the EU.
4. HOW
WE USE YOUR PERSONAL DATA
We
will only use your personal data when the law allows us to. Most
commonly, we will use your personal data in the following
circumstances:
Where
we need to perform the contract we are about to enter into or have
entered into with you.
Where
it is necessary for our legitimate interests (or those of a third
party) and your interests and fundamental rights do not override
those interests.
Where
we need to comply with a legal obligation.
To
find out more about the types of lawful basis that we will rely on to
process your personal data please see Lawful Basis in the Glossary
below.
Generally,
we do not rely on consent as a legal basis for processing your
personal data although we will get your consent before sending third
party direct marketing communications to you via email or text
message. You have the right to withdraw consent to marketing at any
time by contacting us.
PURPOSES
FOR WHICH WE WILL USE YOUR PERSONAL DATA
We
have set out below, in a table format, a description of all the ways
we plan to use your personal data, and which of the legal bases we
rely on to do so. We have also identified what our legitimate
interests are where appropriate.
Note
that we may process your personal data for more than one lawful
ground depending on the specific purpose for which we are using your
data. Please contact us if you need details about the specific legal
ground we are relying on to process your personal data where more
than one ground has been set out in the table below.
|
Purpose/Activity
|
Type of data
|
Lawful
basis for processing including basis of legitimate interest
|
|
To register you as a new
customer
|
(a) Identity
(b) Contact
|
Performance of a contract
with you
|
|
To process and deliver
your subscription including:
(a) Manage payments, fees
and charges
(b)
Collect and recover money owed to us
|
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and
Communications
|
(a) Performance of a
contract with you
(b) Necessary for our
legitimate interests (to recover debts due to us)
|
|
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)
|
|
To enable you to partake
in a prize draw, competition or complete a survey
|
(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)
|
|
To
administer and protect our business and this website (including
troubleshooting, data analysis, testing, system maintenance,
support, reporting and hosting of data)
|
(a)
Identity
(b)
Contact
(c)
Technical
|
(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 reorganisation or
group restructuring exercise)
(b)
Necessary to comply with a legal obligation
|
|
To
deliver relevant website content and advertisements to you and
measure or understand the effectiveness of the advertising we
serve to you
|
(a)
Identity
(b)
Contact
(c)
Profile
(d)
Usage
(e)
Marketing and Communications
(f)
Technical
|
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)
|
|
To use data analytics to
improve our website, products/services, marketing, customer
relationships and experiences
|
(a)
Technical
(b)
Usage
|
Necessary
for our legitimate interests (to define types of customers for our
products and services, to keep our website updated and relevant,
to develop our business and to inform our marketing strategy)
|
|
To
make suggestions and recommendations to you about goods or
services that may be of interest to you
|
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and
Communications
|
Necessary for our
legitimate interests (to develop our products/services and grow
our business)
|
MARKETING
We
strive to provide you with choices regarding certain personal data
uses, particularly around marketing and advertising. We have
established the following personal data control mechanisms:
We
store personal records (as provided at registration) in a database
which we can delete; backups of this data are destroyed after 30
days. If you cancel your subscription and account then your personal
data will be deleted as a result. Data will be stored for all live
accounts to enable effective processing of your contract with us.
If
you would like us to delete your information at any point, please
email help@contractfinderpro.com
PROMOTIONAL
OFFERS FROM US
We may
use your Identity, Contact, Technical, Usage and Profile Data to form
a view on what we think you may want or need, or what may be of
interest to you. This is how we decide which products, services and
offers may be relevant for you (we call this marketing).
You
will receive marketing communications from us if you have requested
information from us or purchased services from us and you have not
opted out of receiving that marketing.
THIRD-PARTY
MARKETING
We
will get your express opt-in consent before we share your personal
data with any third party for marketing purposes.
OPTING
OUT
You can ask us or third
parties to stop sending you marketing messages at any time by
contacting us by email using the email address set out above, at any
time.
Where
you opt out of receiving these marketing messages, this will not
apply to personal data provided to us as a result of purchasing a
subscription or any other transactions.
COOKIES
You
can set your browser to refuse all or some browser cookies, or to
alert you when websites set or access cookies. If you disable or
refuse cookies, please note that some parts of this website may
become inaccessible or not function properly. For more information
about the cookies we use, please see our Cookie Policy.
CHANGE
OF PURPOSE
We
will only use your personal data for the purposes for which we
collected it, unless we reasonably consider that we need to use it
for another reason and that reason is compatible with the original
purpose. If you wish to get an explanation as to how the processing
for the new purpose is compatible with the original purpose, please
contact us.
If we need to use your
personal data for an unrelated purpose, we will notify you and we
will explain the legal basis which allows us to do so.
Please
note that we may process your personal data without your knowledge or
consent, in compliance with the above rules, where this is required
or permitted by law.
5. DISCLOSURES
OF YOUR PERSONAL DATA
We may
share your personal data with the parties set out below for the
purposes set out in the table (Purposes
for which we will use your personal data)
above.
External
Third Parties as set out in the [Glossary].
Specific
third parties listed in the table [Purposes
for which we will use your personal data]
above.
Third
parties to whom we may choose to sell, transfer or merge parts of
our business or our assets. Alternatively, we may seek to acquire
other businesses or merge with them. If a change happens to our
business, then the new owners may use your personal data in the same
way as set out in this privacy policy.
We
require all third parties to respect the security of your personal
data and to treat it in accordance with the law. We do not allow our
third-party service providers to use your personal data for their own
purposes and only permit them to process your personal data for
specified purposes and in accordance with our instructions.
6. INTERNATIONAL
TRANSFERS
We do
not transfer your personal data outside the European Economic Area
(EEA),
although some providers (e.g. Stripe) may host such data in non-EU
data centres.
7. DATA
SECURITY
We
have put in place appropriate security measures to prevent your
personal data from being accidentally lost, used or accessed in an
unauthorised way, altered or disclosed. In addition, we limit access
to your personal data to those employees, agents, contractors and
other third parties who have a business need to know. They will only
process your personal data on our instructions and they are subject
to a duty of confidentiality.
We
have put in place procedures to deal with any suspected personal data
breach and will notify you and any applicable regulator of a breach
where we are legally required to do so.
8. DATA
RETENTION
HOW
LONG WILL YOU USE MY PERSONAL DATA FOR?
We
will only retain your personal data for as long as reasonably
necessary to fulfil the purposes we collected it for, including for
the purposes of satisfying any legal, regulatory, tax, accounting or
reporting requirements. We may retain your personal data for a longer
period in the event of a complaint or if we reasonably believe there
is a prospect of litigation in respect to our relationship with you.
To
determine the appropriate retention period for personal data, we
consider the amount, nature and sensitivity of the personal data, the
potential risk of harm from unauthorised use or disclosure of your
personal data, the purposes for which we process your personal data
and whether we can achieve those purposes through other means, and
the applicable legal, regulatory, tax, accounting or other
requirements.
Details
of retention periods for different aspects of your personal data are
set out in the table [Purposes
for which we will use your personal data]
above.
9. YOUR
LEGAL RIGHTS
Under
certain circumstances, you have rights under data protection laws in
relation to your personal data. Please find further information
outlined in the Glossary in relation to the following rights:
Request
access to your personal data.
Request
correction of your personal data.
Request
erasure of your personal data.
Object
to processing of your personal data.
Request
restriction of processing your personal data.
Request
transfer of your personal data.
Right
to withdraw consent.
If you
wish to exercise any of the rights set out above, please contact us.
NO
FEE USUALLY REQUIRED
You
will not have to pay a fee to access your personal data (or to
exercise any of the other rights). However, we may charge a
reasonable fee if your request is clearly unfounded, repetitive or
excessive. Alternatively, we could refuse to comply with your request
in these circumstances.
WHAT
WE MAY NEED FROM YOU
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). This is a security measure to
ensure that personal data is not disclosed to any person who has no
right to receive it. We may also contact you to ask you for further
information in relation to your request to speed up our response.
TIME
LIMIT TO RESPOND
We try
to respond to all legitimate requests within one month. Occasionally
it could 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.
10. GLOSSARY
LAWFUL
BASIS
Legitimate
Interest
means the interest of our business in conducting and managing our
business to enable us to give you the best service/product and the
best and most secure experience. We make sure we consider and balance
any potential impact on you (both positive and negative) and your
rights before we process your personal data for our legitimate
interests. We do not use your personal data for activities where our
interests are overridden by the impact on you (unless we have your
consent or are otherwise required or permitted to by law). You can
obtain further information about how we assess our legitimate
interests against any potential impact on you in respect of specific
activities by contacting us.
Performance
of Contract
means processing your data where it is necessary for the performance
of a contract to which you are a party or to take steps at your
request before entering into such a contract.
Comply
with a legal obligation
means processing your personal data where it is necessary for
compliance with a legal obligation that we are subject to.
THIRD
PARTIES
EXTERNAL
THIRD PARTIES
We
use Stripe for our payment processing services.
HM
Revenue & Customs, regulators and other authorities may act as
processors or joint controllers based in the United Kingdom, if they
require reporting of processing activities in certain circumstances.
YOUR
LEGAL RIGHTS
You have the right to:
Request
access to
your personal data (commonly known as a “data subject access
request”). This enables you to receive a copy of the personal
data we hold about you and to check that we are lawfully processing
it.
Request
correction of
the personal data that we hold about you. This enables you to have
any incomplete or inaccurate data we hold about you corrected, though
we may need to verify the accuracy of the new data you provide to us.
Request
erasure of
your personal data. This enables you to ask us to delete or remove
personal data where there is no good reason for us continuing to
process it. You also have the right to ask us to delete or remove
your personal data where you have successfully exercised your right
to object to processing (see below), where we may have processed your
information unlawfully or where we are required to erase your
personal data to comply with local law. Note, however, that we may
not always be able to comply with your request of erasure for
specific legal reasons which will be notified to you, if applicable,
at the time of your request.
Object
to processing of
your personal data where we are relying on a legitimate interest (or
those of a third party) and there is something about your particular
situation which makes you want to object to processing on this ground
as you feel it impacts on your fundamental rights and freedoms. You
also have the right to object where we are processing your personal
data for direct marketing purposes. In some cases, we may demonstrate
that we have compelling legitimate grounds to process your
information which override your rights and freedoms.
Request
restriction of processing of
your personal data. This enables you to ask us to suspend the
processing of your personal data in the following scenarios:
If
you want us to establish the data’s accuracy.
Where
our use of the data is unlawful but you do not want us to erase it.
Where
you need us to hold the data even if we no longer require it as you
need it to establish, exercise or defend legal claims.
You
have objected to our use of your data but we need to verify whether
we have overriding legitimate grounds to use it.
Request
the transfer of
your personal data to you or to a third party. We will provide to
you, or a third party you have chosen, your personal data in a
structured, commonly used, machine-readable format. Note that this
right only applies to automated information which you initially
provided consent for us to use or where we used the information to
perform a contract with you.
Withdraw
consent at any time where
we are relying on consent to process your personal data. However,
this will not affect the lawfulness of any processing carried out
before you withdraw your consent. If you withdraw your consent, we
may not be able to provide certain products or services to you. We
will advise you if this is the case at the time you withdraw your
consent.