Data Protection Notice
Last Updated: Feb 2020
This privacy notice provides you with details of how we collect and process your personal data through your use of our online services provided by Just Ask Max Ltd.
By providing us with your data, you warrant to us that you are over 18 years of age.
Just Ask Max Ltd. is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
Legal entity: Just Ask Max Ltd
Email address: email@example.com
Postal address: 7 Barnes Street, London, E147NW
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at the email above.
2. WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND WE PROCESS IT
Personal data means any information capable of identifying an individual. It does not include anonymised data. We may process the following categories of personal data about you:
* Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
* Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details, your card details and the forenames (only) of your children. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
* User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back-ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.
* Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.
We don’t believe in sending out irritating marketing emails and as such, as a paying customer you won’t receive any marketing emails or materials in any form. As a non-customer (prospect), if you have started the account creation process we may send you emails reminding you that you did not complete the setup process and outlining the benefits of doing so.
Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.
We do not collect any Sensitive Data about you. Sensitive data refers to data that 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. We do not collect any information about criminal convictions and offences.
We do collect the forenames (only) of any children you want to include under our service so that you can identify them and tailor the service for them. The Just Ask Max online platform is for adults only and the legal ground for processing this child data is consent. A child data privacy notice has been created (see end of this notice) for children to help them understand how and why we are processing their forenames.
Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.
We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at firstname.lastname@example.org. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
We do not carry out automated decision making or any type of automated profiling.
3. HOW WE COLLECT YOUR PERSONAL DATA
We may receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as Facebook based outside the EU, such as search information providers such as Google based outside the EU, providers of technical, payment and delivery services, such as data brokers or aggregators.
We may also receive data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
4. MARKETING COMMUNICATIONS
Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).
Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. You can opt out of receiving marketing emails from us at any time.
Before we share your personal data with any third party for their own marketing purposes we will get your express consent.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you OR by emailing us at email@example.com at any time.
If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below:
* Service providers who provide IT and system administration services.
* Professional advisers including lawyers, bankers, auditors and insurers
* Government bodies that require us to report processing activities.
6. DATA SECURITY
We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to. For more info on our security practices see our information security page.
7. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
When deciding what the correct time is to keep the data for, we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.
When deciding what the correct time is to keep the data for, we look at its amount, nature and sensitivitaFor tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.y, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.
In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
8. YOUR RIGHTS
Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.
You can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
If you wish to exercise any of the rights set out above, please email us at firstname.lastname@example.org
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 or refuse to comply with your request in these circumstances.
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.
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.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
9. 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 notice of every website you visit.
What’s this about?
Certain laws help keep your information safe – things like your address, date of birth and phone number. Your parents use our service (Just Ask Max) to help protect you online and to allow us to do that we need your forenames (first names only).
It’s our job to tell you how we will collect the information, how we will record it and how we will use it.
Who looks after your information?
Just Ask Max is the responsible owner (Data Controller) of the personal information you give us – we look at how and why your information is collected and used).
Sometimes we have to give your information to other people, such as the government, but it will only give away your information when you say it’s ok or when the law says that they have to. When your data is given to someone else, they must look after it and keep it safe.
Why do we collect and use your information?
We will only collect your information when we need it to help us do our job or to follow the law. When we’ve collected it, here’s how we use it:
- To provide a personalised service to your parents from our website (web application)
- To record the technology (devices, social media and email accounts) you use so we can help your parents protect you online
Do you have to give us your information?
No – your parents can choose to exclude you from our service (by simply not entering your first name when they create their account with us. We will ask for your parent’s permission. If you don’t want us to have the information, please ask your parents to inform us or inform us directly by emailing email@example.com.
How long will we keep your information?
We don’t keep it forever, only for as long as we need it to help us do the thing we needed it for. We have a policy that tells us when to keep it and when to bin it.
Will your information be shared?
We won’t share your information with anyone else without your permission, unless the law says we can or should. We may share information with:
- Law enforcement
- Third parties where it is necessary to provide our fundamental service
What are your rights?
You and your parents have the right to:
- Be told how we use your information.
- Ask to see the information we hold.
- Ask us to change information you think is wrong.
- Ask us to remove information when it’s not needed anymore.
- Ask us to only use your information in certain ways.
- Tell us you don’t want your information to be processed.
If the information we are collecting is information that you can choose not to give, you can tell us to stop collecting it at any time.
Would you like to know more?
If you’re worried about how we get and use your information, please email us anytime at firstname.lastname@example.org and we’ll be able to help you and answer any questions that you have.
Four important things to understand
Now you’ve read this, we hope you understand that:
- The law allows us to get and use your information to help us do our job.
- We may share your information with others, but only when we really need to.
- We will ask for your parent’s permission to share your information whenever you have a choice.
- You can tell us not to share your information, even when your parent’s have said yes before.