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Privacy policy
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Studio
INTRODUCTION
Welcome to JonesMillbank Limited (“we”, ”us”, ”our” or “the Company”). We're a full-service video production company.
We respect your privacy and we are committed to protecting your personal data. We ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal data through your use of this website or in relation to the services we provide to our Clients, your rights in relation to your personal data, and on how to contact us and data protection authorities in the event you have a complaint.
What does this Privacy Notice cover?
Specifically, this privacy notice covers personal data we collect: (1) in connection with the services we provide to our Clients (“Services”) and our corporate activities, and (2) when you visit our website at jonesmillbank.com (“Website”). Our Website and Services are not intended for children and we do not knowingly collect data relating to children. It is important that you read this privacy notice together with any other privacy notice or fair processing notice 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 notice supplements the other notices and is not intended to override them.
Who collects information about you?
JonesMillbank Limited (“JonesMillbank”) collects, uses and is responsible for your personal data. When we do so, we are responsible as a ‘data controller’ of that information.
Our registered office is 4 Temple Studios, Bristol, BS1 6QA. You can contact us by writing to us at JonesMillbank, 4 Temple Studios, Bristol, BS1 6QA.
We have appointed a privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact our privacy manager
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. We are registered with the ICO with reference ZA916684. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Useful terms
“Clients” means any of our clients (including the individuals working for our clients) to whom we provide the Services. Clients also include prospective clients, such as contacts who we have communicated with but have not yet engaged us to provide services.
“Personal data” means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (i.e. anonymous data).
“Website Visitors” means individuals who visit our Website and who may opt to provide us with personal data where, for example, they sign up for our newsletter or contact us using the details provided on our Website.
Changes to the Privacy Notice and your duty to inform us of changes
We keep this privacy notice under regular review and may make changes to from time to time. When we do so, we will inform you by updating this section.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 notice of every website you visit.
Social media platforms
Communication, engagement and actions taken through external social media platforms that this Website and JonesMillbank participate on are subject to the terms and conditions as well as the privacy policies held with each social media platform respectively.
Users are advised to use social media platforms wisely and communicate/engage upon them with due care and caution in regard to their own privacy and personal details.
This Website may use social sharing buttons which help share web content directly from web pages to the social media platform in question. Users are advised before using such social sharing buttons that they do so at their own discretion and note that the social media platform may track and save your request to share a web page respectively through your social media platform account.
THE DATA WE COLLECT ABOUT YOU
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity data includes first name, last name, job title and company.
- Contact data includes business address, email address, telephone numbers, and professional and/or social network profile details.
- Financial data includes credit card and/or billing information so that we can charge you for the Services.
- Technical data includes internet protocol (IP) address, 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.
- Usage data includes information about how you use our Website.
- Marking 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 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.
Our Website does 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.
What Personal Data do we collect?
Clients
If you are a Client, we collect Identity Data, Contact Data, Financial Data and Marketing and Communications Data about you, or individuals at your organisation, in the course of providing the Services to you.
Website Visitors
Where you choose to provide us with such information, we collect Identity Data and Contact Data about you when you contact us using the details on our Website. We also collect Contact Data and Marketing and Communications Data where you sign up to receive newsletters from us.
We will also automatically collect Technical Data and Usage Data about you through our and our technology partners’ use of cookies and similar technologies.
How is your personal data collected?
We use different methods to collect data from and about you.
Clients
We may collect data about Clients from the following sources:
Directly from you: This is the information you or an individual at your organisation provide to us during the course of our engagement to provide the Services. It also includes any information you provide to us when you attend our events, interact with us at a conference or correspond with us in person, by phone, email or otherwise.
Third-party sources: This will include information about you or your colleagues that is available through publicly available sources, such as professional networking sites (including LinkedIn) and general market research.
Website Visitors
We may collect data about Website Visitors as follows:
Directly from you: This is the information you provide when you enquire about, or request a service directly from us. For example, when you contact us directly via email or telephone using the details provided on our Website.
Information we collect automatically: When you visit our Website, we collect certain technical and usage information automatically from your device.
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:
Clients
- To provide the Services to you or your organisation.
- To administer and manage our business relationship with you.
- For other business purposes, such as research and analysis, business development and planning, and to improve the Services.
- To send you information which we think you may find interesting (such as details about our Services, content, research, our newsletter, and other relevant news), in accordance with your marketing preferences.
- To comply with legal or regulatory requirements.
Website Visitors
- To respond to your enquiries, such as a request for information about our Services.
- To send you information which we think you may find interesting (such as our newsletter), in accordance with your marketing preferences.
- To administer and protect our Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
- To deliver relevant website content to you and to measure and understand the effectiveness of the content we serve to you.
- To use data analytics to improve our Website content, marketing and user experience.
What is our legal basis for processing your personal data?
Clients
Where we process your personal data in connection with providing the Services to you, we consider that this processing is necessary to perform the contract we have entered into with you.
Where we process your personal data to administer and manage our business relationship with you, for other business purposes and for marketing purposes, we consider this is necessary for our legitimate interests and that your interests and fundamental rights do not override those interests.
We will rely on compliance with a legal or regulatory obligation if we are legally required to hold your personal data to comply with legal or regulatory requirements, such as disclosure to regulators and for purposes of disputes or legal proceedings affecting us.
Website Visitors
Where we process your personal data for the purposes described above, we consider this is necessary for our legitimate interests and that your interests and fundamental rights do not override those interests.
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical and Usage 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 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, signed up for our email newsletter, or engaged us to provide Services and, in each case, you have not opted out of receiving that marketing.
We will never share your personal data with any company outside of our company for marketing purposes without your express opt-in consent.
Email newsletter
You can subscribe to our email newsletter by providing your email address on our Website.
Please note that our email marketing campaigns may include tracking facilities within the actual email. This means that your activity relating to a particular marketing email may be tracked and stored in a database by our email service provider for future analysis and evaluation. This could include information about whether or not you opened the email, forwarded the email, clicked links within the email content, and the times, dates and frequency of such activity. This information is used to inform our future email campaigns and ensure that you receive the most relevant content.
Opting out
You can ask us to stop sending you marketing messages at any time by following the unsubscribe links in any marketing message sent to you, or by contacting us at hello@jonesmillbank.com.Were you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of providing our Services to you.
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 using the details provided in this privacy notice.
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.
What happens if you fail to provide your personal data?
If you do not provide us with certain requested personal data or object to the processing of your personal data, this may limit our ability to provide the Services. You can still visit our Website and learn more about JonesMillbank without giving us your personal data but we will need your contact details to administer and respond to any enquiries you submit to us.
Who do we share your personal data with?
We may share and disclose your personal data with the following categories of third parties for the purposes described in this privacy notice:
- Suppliers, consultants and service providers: We use a number of suppliers, consultants and service providers (our Suppliers) who perform functions on our behalf and/or help us in providing the Services, such as cloud-based software and hosting suppliers, email marketing providers, email service providers and web analytics providers.
- Professional advisers: We use professional advisers (who act as processors or controllers), including lawyers, bankers, auditors and insurers, who provide legal, banking, accounting and insurance services.
- Business transfers: We may share personal data with third parties to whom we choose to sell, transfer, or merge part 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, the new owner may use your personal data in the same way as set out in this privacy notice.
- Compliance with laws: We may be required to share some personal data as required by law.
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 Suppliers 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. We will not disclose your personal data to any other third parties without your specific consent unless we are required to do so by law.
INTERNATIONAL TRANSFERS, SECURITY AND RETENTION
International data transfers
Some of our Suppliers are based outside of the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
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.
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.
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 requirements.
In some circumstances you can ask us to delete your data – please see below.
In some circumstances we may 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.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include rights to:
- Request access to your personal data (commonly known as a “data subject access request”) and to certain other supplementary information that this privacy notice is already designed to address. 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:
(a) if you want us to establish the data’s accuracy;
(b) where our use of the data is unlawful but you do not want us to erase it;
(c) 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
(d) 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.
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 may 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 and keep you updated.
If you would like to exercise any of these rights, please email our privacy manager at hello@jonesmillbank.com and let us have enough information to identify you.
SECTION 5 – GLOSSARY
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 or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Welcome to JonesMillbank Limited (“we”, ”us”, ”our” or “the Company”). We're a full-service video production company.
We respect your privacy and we are committed to protecting your personal data. We ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal data through your use of this website or in relation to the services we provide to our Clients, your rights in relation to your personal data, and on how to contact us and data protection authorities in the event you have a complaint.
What does this Privacy Notice cover?
Specifically, this privacy notice covers personal data we collect: (1) in connection with the services we provide to our Clients (“Services”) and our corporate activities, and (2) when you visit our website at jonesmillbank.com (“Website”). Our Website and Services are not intended for children and we do not knowingly collect data relating to children. It is important that you read this privacy notice together with any other privacy notice or fair processing notice 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 notice supplements the other notices and is not intended to override them.
Who collects information about you?
JonesMillbank Limited (“JonesMillbank”) collects, uses and is responsible for your personal data. When we do so, we are responsible as a ‘data controller’ of that information.
Our registered office is 4 Temple Studios, Bristol, BS1 6QA. You can contact us by writing to us at JonesMillbank, 4 Temple Studios, Bristol, BS1 6QA.
We have appointed a privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact our privacy manager
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. We are registered with the ICO with reference ZA916684. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Useful terms
“Clients” means any of our clients (including the individuals working for our clients) to whom we provide the Services. Clients also include prospective clients, such as contacts who we have communicated with but have not yet engaged us to provide services.
“Personal data” means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (i.e. anonymous data).
“Website Visitors” means individuals who visit our Website and who may opt to provide us with personal data where, for example, they sign up for our newsletter or contact us using the details provided on our Website.
Changes to the Privacy Notice and your duty to inform us of changes
We keep this privacy notice under regular review and may make changes to from time to time. When we do so, we will inform you by updating this section.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 notice of every website you visit.
Social media platforms
Communication, engagement and actions taken through external social media platforms that this Website and JonesMillbank participate on are subject to the terms and conditions as well as the privacy policies held with each social media platform respectively.
Users are advised to use social media platforms wisely and communicate/engage upon them with due care and caution in regard to their own privacy and personal details.
This Website may use social sharing buttons which help share web content directly from web pages to the social media platform in question. Users are advised before using such social sharing buttons that they do so at their own discretion and note that the social media platform may track and save your request to share a web page respectively through your social media platform account.
THE DATA WE COLLECT ABOUT YOU
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity data includes first name, last name, job title and company.
- Contact data includes business address, email address, telephone numbers, and professional and/or social network profile details.
- Financial data includes credit card and/or billing information so that we can charge you for the Services.
- Technical data includes internet protocol (IP) address, 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.
- Usage data includes information about how you use our Website.
- Marking 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 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.
Our Website does 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.
What Personal Data do we collect?
Clients
If you are a Client, we collect Identity Data, Contact Data, Financial Data and Marketing and Communications Data about you, or individuals at your organisation, in the course of providing the Services to you.
Website Visitors
Where you choose to provide us with such information, we collect Identity Data and Contact Data about you when you contact us using the details on our Website. We also collect Contact Data and Marketing and Communications Data where you sign up to receive newsletters from us.
We will also automatically collect Technical Data and Usage Data about you through our and our technology partners’ use of cookies and similar technologies.
How is your personal data collected?
We use different methods to collect data from and about you.
Clients
We may collect data about Clients from the following sources:
Directly from you: This is the information you or an individual at your organisation provide to us during the course of our engagement to provide the Services. It also includes any information you provide to us when you attend our events, interact with us at a conference or correspond with us in person, by phone, email or otherwise.
Third-party sources: This will include information about you or your colleagues that is available through publicly available sources, such as professional networking sites (including LinkedIn) and general market research.
Website Visitors
We may collect data about Website Visitors as follows:
Directly from you: This is the information you provide when you enquire about, or request a service directly from us. For example, when you contact us directly via email or telephone using the details provided on our Website.
Information we collect automatically: When you visit our Website, we collect certain technical and usage information automatically from your device.
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:
Clients
- To provide the Services to you or your organisation.
- To administer and manage our business relationship with you.
- For other business purposes, such as research and analysis, business development and planning, and to improve the Services.
- To send you information which we think you may find interesting (such as details about our Services, content, research, our newsletter, and other relevant news), in accordance with your marketing preferences.
- To comply with legal or regulatory requirements.
Website Visitors
- To respond to your enquiries, such as a request for information about our Services.
- To send you information which we think you may find interesting (such as our newsletter), in accordance with your marketing preferences.
- To administer and protect our Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
- To deliver relevant website content to you and to measure and understand the effectiveness of the content we serve to you.
- To use data analytics to improve our Website content, marketing and user experience.
What is our legal basis for processing your personal data?
Clients
Where we process your personal data in connection with providing the Services to you, we consider that this processing is necessary to perform the contract we have entered into with you.
Where we process your personal data to administer and manage our business relationship with you, for other business purposes and for marketing purposes, we consider this is necessary for our legitimate interests and that your interests and fundamental rights do not override those interests.
We will rely on compliance with a legal or regulatory obligation if we are legally required to hold your personal data to comply with legal or regulatory requirements, such as disclosure to regulators and for purposes of disputes or legal proceedings affecting us.
Website Visitors
Where we process your personal data for the purposes described above, we consider this is necessary for our legitimate interests and that your interests and fundamental rights do not override those interests.
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical and Usage 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 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, signed up for our email newsletter, or engaged us to provide Services and, in each case, you have not opted out of receiving that marketing.
We will never share your personal data with any company outside of our company for marketing purposes without your express opt-in consent.
Email newsletter
You can subscribe to our email newsletter by providing your email address on our Website.
Please note that our email marketing campaigns may include tracking facilities within the actual email. This means that your activity relating to a particular marketing email may be tracked and stored in a database by our email service provider for future analysis and evaluation. This could include information about whether or not you opened the email, forwarded the email, clicked links within the email content, and the times, dates and frequency of such activity. This information is used to inform our future email campaigns and ensure that you receive the most relevant content.
Opting out
You can ask us to stop sending you marketing messages at any time by following the unsubscribe links in any marketing message sent to you, or by contacting us at hello@jonesmillbank.com.Were you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of providing our Services to you.
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 using the details provided in this privacy notice.
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.
What happens if you fail to provide your personal data?
If you do not provide us with certain requested personal data or object to the processing of your personal data, this may limit our ability to provide the Services. You can still visit our Website and learn more about JonesMillbank without giving us your personal data but we will need your contact details to administer and respond to any enquiries you submit to us.
Who do we share your personal data with?
We may share and disclose your personal data with the following categories of third parties for the purposes described in this privacy notice:
- Suppliers, consultants and service providers: We use a number of suppliers, consultants and service providers (our Suppliers) who perform functions on our behalf and/or help us in providing the Services, such as cloud-based software and hosting suppliers, email marketing providers, email service providers and web analytics providers.
- Professional advisers: We use professional advisers (who act as processors or controllers), including lawyers, bankers, auditors and insurers, who provide legal, banking, accounting and insurance services.
- Business transfers: We may share personal data with third parties to whom we choose to sell, transfer, or merge part 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, the new owner may use your personal data in the same way as set out in this privacy notice.
- Compliance with laws: We may be required to share some personal data as required by law.
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 Suppliers 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. We will not disclose your personal data to any other third parties without your specific consent unless we are required to do so by law.
INTERNATIONAL TRANSFERS, SECURITY AND RETENTION
International data transfers
Some of our Suppliers are based outside of the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
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.
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.
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 requirements.
In some circumstances you can ask us to delete your data – please see below.
In some circumstances we may 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.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include rights to:
- Request access to your personal data (commonly known as a “data subject access request”) and to certain other supplementary information that this privacy notice is already designed to address. 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:
(a) if you want us to establish the data’s accuracy;
(b) where our use of the data is unlawful but you do not want us to erase it;
(c) 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
(d) 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.
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 may 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 and keep you updated.
If you would like to exercise any of these rights, please email our privacy manager at hello@jonesmillbank.com and let us have enough information to identify you.
SECTION 5 – GLOSSARY
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 or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
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