PRIVACY POLICY
INTRODUCTION
This privacy policy sets out how Jaga Heating Products (UK) Limited (referred to as “Jaga”, “we”, “us” or “our” in this privacy policy) uses and protects your personal data when you use this website or interact with us in any other way.
This website is not intended for children and we do not knowingly collect data relating to children.
CONTROLLER
Jaga is the controller and responsible for the personal data collected by Jaga from you.
We have appointed a data protection 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 protection manager on marketing@jaga.co.uk.
1. The types of personal data we collect about you
Personal data means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes name, address, company, job title, email address and phone number.
- Contact Data includes billing address, delivery address, company, email address and phone number.
- Financial Data includes bank account (BACS) and payment card details.
- Transaction Data includes details about payments to and from you (within in individual ledger accounts) and details of products and services you have purchased from us or that we have ordered from you.
- Technical Data includes IP address, geographical location, browser type and version, operating system, device, referral source, length of visit, page views and website navigation paths, as well as information about timing, frequency and pattern of your visit.
- Survey Data includes your feedback and survey responses.
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
We also collect, use and share aggregated data such as statistical or demographic data which is not personal data (as it does not directly or indirectly reveal your identity).
2. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Your interactions with us. You may give us your personal data in meetings with you, through CPDs, events, webinars, quote requests, account applications, orders, contact forms on our website, subscription to our newsletters, posting on our social media channels, telephone calls and email correspondence. This includes personal data you provide when you:
- apply for our products or services;
- contact us through our website or use our website;
- subscribe to our service or publications and newsletters;
- request marketing to be sent to you;
- attend our exhibitions and events;
- 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, and other similar technologies, subject to your consent, which you can give or refuse using our cookie banner, where you will also find details about the cookies used on our website.
- Third parties or publicly available sources. We may receive personal data about you from third parties, including your employer, any third party referrer or introducer or data broker or aggregator.
3. How we use your personal data
LEGAL BASIS
The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
- Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
- Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) 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).
- Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
- Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.
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 the various categories of 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.
Purpose/Use | Type of data | Legal basis |
To register you as a new customer | (a) Identity (b) Contact | Performance of a contract with you or pre-contractual enquiries and negotiations
|
To process and deliver your order 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 manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Dealing with your requests, complaints and queries | (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 manage our relationship with you)
|
To enable you to partake in a prize draw, competition or complete a survey | (a) Identity (b) Contact (c) Survey (d) 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 use data analytics to improve our website, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing | (a) Technical
| 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 send you relevant marketing communications, newsletters and make personalised suggestions and recommendations to you about goods or services that may be of interest to you based on your previous interactions and interests | (a) Identity (b) Contact (c) Technical (d) Survey (e) Marketing and Communications | Necessary for our legitimate interests (to carry out direct marketing, develop our products/services and grow our business) OR Consent, having obtained your prior consent to receiving direct marketing communications |
To carry out market research through your voluntary participation in surveys | (a) Marketing and Communications | Necessary for our legitimate interests (to study how customers use our products/services and to help us improve and develop our products and services). |
DIRECT MARKETING
When we collect your personal data, you will be asked to indicate your preferences for receiving direct marketing communications (including but not limited to our newsletters) and you may receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving the marketing.
We may also analyse your Identity, Contact, Technical and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.
THIRD-PARTY MARKETING
We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.
OPTING OUT OF MARKETING
You can ask to stop sending you marketing communications at any time by contacting us on marketing@jaga.co.uk.
If you opt out of receiving communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to order confirmations or updates to our Terms and Conditions, or checking that your contact details are correct.
4. Disclosures of your personal data
We may share your personal data where necessary with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.
Our partners and suppliers (with whom we have contracts). For example to provide technical assistance, delivery services and references. This may include other companies within our group of companies.
Our professional advisors, but only as necessary for managing risks, obtaining professional advice and resolving legal disputes.
To comply with legal obligations (including tax and accounting obligations).
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 written instructions.
We do not transfer your personal data outside the UK and the EU.
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.
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. We regularly review our databases.
We process card details (as Financial Data) at the time of payment and all card details are destroyed on successful processing of the payment.
In order to satisfy legal and tax requirements, we keep basic information about our customers (including Contact, Identity, Transaction Data) for seven years after they cease being customers (calculated from the date of last contact).
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
You have a number of rights under data protection laws in relation to your personal data.
In respect of your own Personal Data that we hold about you, you have the right to:
- Request access (commonly known as a “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. 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. 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 where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
- You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes.
- 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.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of 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; or
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
If you wish to exercise any of the rights set out above, you can contact us on marketing@jaga.co.uk.
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.
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.
You have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). However, before doing so please make sure you have first made your complaint to us or asked us for clarification if there is something you do not understand. The ICO will expect you to have done this before reviewing your complaint.
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.