Privacy Policy


  1. INTRODUCTION AND TERMS

    Jarrang Limited (“We” or “us”) are committed to protecting and respecting your personal data and privacy. This privacy policy relates to our use of any personal data we collect from you from any of our services. Whenever you provide such information, we are legally obliged to use your information in line with all applicable laws concerning the protection of personal data; including the Data Protection Act 1998 and 2018 (DPA), and The General Data Protection Regulation 2016 (GDPR) together, and with other subsequent laws “Data Protection Laws”.

  2. WHO WE ARE AND HOW TO CONTACT US

    1. For the purpose of the Data Protection Laws, the data controller is Jarrang Limited, registered company number 04715116. If you want to request more information about our privacy policy or information regarding data protection you should contact us using the details provided below:

      FAO: Privacy Officer
      Jarrang Limited
      Maritime House
      Discovery Quay
      Falmouth
      Cornwall
      United Kingdom
      TR11 3XA

      Email: dpm@jarrang.com
      Telephone: 01326 219540 and ask to speak to the Privacy Officer

  3. THE DATA WE COLLECT ABOUT YOU

    1. We collect and process Personal Data. We collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
      1. Identity Data includes first name, last name, username or similar identifier and company.
      2. Contact Data includes billing address, email address and telephone numbers.
      3. Financial Data includes bank account and payment card details.
      4. Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
      5. 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 the website.
      6. Profile Data includes your username and password, purchases or orders made by you, your preferences, feedback and survey responses.
      7. Usage Data includes information about how you use our website, products and services.
      8. Marketing and Communications Data includes your preferences in receiving marketing from us.
    2. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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 notice.
    3. 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.

  4. 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.

  5. HOW YOUR DATA WILL BE USED

    1. We use information held about you to:

      1. carry out our obligations arising from any contracts entered into between you and us;
      2. provide you with information, products or services that you request from us or which we feel may interest you (where you have consented to be contacted for such purposes or where we have identified a Legitimate Interest);
      3. to comply with a legal or regulatory obligation; and
      4. notify you about changes to our services
    2. We also embrace the use of social media and may wish to process any comments made public by you.

  6. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

    1. 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.
    2. 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 order including:
    (a) Manage payments, fees and charges
    (b) Collect and recover money owed to us
    (a) Identity
    (b) Contact
    (c) Financial
    (d) ransaction
    (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
    Necessary for our legitimate interests (to develop our products/services and grow our business)
  7. THIRD PARTIES

    1. We will keep your information within the organisation except where disclosure is required or permitted by law or when we use third party service providers (data processors) to supply and support our services to you. We have contracts in place with our data processors. This means that they cannot do anything with your personal data unless we have instructed them to do so. They will not share your personal data with any organisation apart from us. They will hold it securely and retain it for the period we instruct.
    2. Please see below the list which sets out the categories of recipients of personal data.

      SERVICE PROVIDED
      IT Support Services
      Email Service Platform provider
      Cloud Based Back-Up Services
      Secure document disposal service
      Cloud Based CRM provider
      Internal HR systems provider
      Banking & Card Payment Processing
      Payroll
      Accountants & Accounting Software
      Solicitors

    3. In addition third parties may provide us with Personal Data and they should only do so where the law allows them to.

  8. 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.

  9. WHERE YOUR DATA IS HELD

    We store any Personal Data in the UK, EEA or in a country where an adequacy decision has been made by Article 29 Working Party (e.g. EU-US Privacy Shield).

  10. DATA SECURITY

    1. 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.
    2. 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.

  11. LEGITIMATE INTEREST

    Where we use Legitimate Interests we will record our decision and our method on making this decision.

  12. APPLICATIONS TO WORK FOR US

    If you apply to work for us (directly or indirectly) in any role (including volunteers) we may receive data about you from third parties. In addition, we will keep the details of your application and any additional information provided to us by you or others for 90 days. If you do not wish for us to keep your details for this reason, please let us know by contacting us using the details provided in this policy.

  13. DATA RETENTION

    Our data retention policy is dictated by the Data Protection Laws and is available for inspection by submitting a written request using the contact details provided in this policy.

  14. YOUR RIGHTS

    1. Under the Data Protection Laws your rights are:

      1. To be informed – We must make this privacy policy (sometimes referred to as a privacy notice) available with the emphasis on transparency over how we process your data.
      2. Access – You are entitled to find out what details we may hold about you and why. We strive to be as open as we can be in terms of giving people access to their personal data. Individuals can find out if we hold any of their Personal Data by making a formal request under the Data Protection Laws. Such requests should be in writing to the contact details provided in this policy. In the instance that we do not hold information about you we will confirm this in writing at the earliest opportunity. If we do hold your personal data we will respond in writing within one calendar month of your request (where that request was submitted in accordance with this policy). The information we supply will:
        (a) confirm that your data is being processed;
        (b) verify the lawfulness and the purpose of the processing;
        (c) confirm the categories of personal data being processed;
        (d) confirm the type of recipient to whom the personal data have been or will be disclosed; and
        (e) let you have a copy of the data in an intelligible form.
      3. Rectification – We are obliged to correct or update your details. We will correct or update your data without delay provided you make the request in writing to the contact details provided in this policy, clearly specifying which data is incorrect or out of date.
      4. Erasure – This is also known as the request to be forgotten. Under Data Protection Laws you have the right to erasure under specific circumstances. A request for your personal data to be deleted will be decided on a case by case basis and should be submitted in writing to the contact details provided in this policy.
      5. Restrict processing – You have the right to ‘block’ or suppress the processing by us of your personal data.
      6. Portability – You have the right to obtain and reuse your personal data that you have provided to us.
      7. Object – You have the right to object to us processing your data in relation to direct marketing and or profiling.
      8. Rights in relation to automated decision making and profiling – We do not use automatic decision making or profiling.
    2. Please note that you may need to provide identification in order to prove who you are if you wish to invoke any of your rights as provided by the Data Protection Laws and as summarised above.
    3. If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.

  15. CHANGES

    We keep our privacy policy under regular review and you should check back regularly to ensure you are aware of changes to it. We may display this notice to you from time to time to help ensure you are aware of its contents.

  16. COMPLAINTS

    You have the right to complain about the processing of your personal data. Please contact us using the details provided above. If you are still unsatisfied you have the right to complain to the Information Commissioners Office. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.