We are committed to safeguarding the privacy of those who visit our website; this policy has been prepared to meet the requirements of the UK and EU Data Protection Act 1998, (the “Act”) and it relates to our treatment of the collection, protection, disclosure and use of your personal information.
If you register from within the United Kingdom/from a United Kingdom location to use the our website, your contract and account will be with Jennis & Warmann Limited.
A chosen merchant service provider may also access your personal data for purposes of processing payments.
Jennis & Warmann is committed to providing its customers with exceptional service. As providing this service involves the collection, use and disclosure of some Personal Information about customers, protecting their Personal Information is one of our highest priorities.
“Personal Information” or “personal data” -means information from which an individual can be identified; for example Jennis & Warmann collects cell/mobile phone number, and credit or debit card details. Personal Information does not necessarily include Contact Information (described below).
Policy 1 – Collecting Personal Information
1.1 Unless the purposes for collecting Personal Information are obvious and the customer voluntarily provides his or her Personal Information for those purposes, we will communicate the purposes for which Personal Information is being collected, either orally or in writing, before or at the time of collection.
1.2 We will only collect and process customer Personal Information that is necessary to fulfil the following purposes:
- To allow customers to pay for services or products with their electronic device, including the following details:
- Cell Phone Number
- Visa or MasterCard credit cards or Maestro or Delta debit cards number or any of such.
- Billing and Shipping Address
- For our own records, dealing with customer requests, providing customer services, administration, statistical analysis, marketing our services, assessing financial standing, recovery and collection of debts, dealing with regulatory and compliance issues, transfer of the Jennis & Warmann business
- For processing payments, for which we currently use WorldPay and PayPal.
Policy 2 – Consent
2.1 We will obtain customer consent to collect, use or disclose Personal Information (except where, as noted below, we are authorized to do so without consent).
2.2 Consent can be provided orally through an authorized representative or it can be implied where the purpose for collecting using or disclosing the Personal Information would be considered obvious and the customer voluntarily provides personal information for that purpose.
2.3 Subject to laws applicable in the Country you register from which may require you to “opt-in” to unsolicited communications or other processing of Personal Information consent may also be implied where a customer is given notice and a reasonable opportunity to opt-out of his or her Personal Information being used for mail-outs, the marketing of new services or products, fundraising and the customer does not opt-out.
2.4 Subject to certain allowable exceptions (e.g., the Personal Information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), customers can withhold or withdraw their consent for Jennis & Warmann to use their Personal Information in certain ways. A customer’s decision to withhold or withdraw their consent to certain uses of Personal Information may restrict our ability to provide a particular service or product.
2.5 Subject to DPA we may collect, use or disclose Personal Information without the customer’s knowledge or consent in the following limited circumstances:
- When such collection, use or disclosure of Personal Information is permitted or required by law;
- In an emergency that threatens an individual’s life, health, or personal security;
- When the Personal Information is available from a public source (e.g. a telephone directory);
- When we require legal advice from a lawyer;
- For the purposes of collecting a debt;
- To protect ourselves from fraud;
- To investigate an anticipated breach of an agreement or a contravention of law or, in the United Kingdom, as otherwise permitted under the DPA.
Policy 3 – Using and Disclosing Personal Information
3.1 We will only use or disclose customer Personal Information where necessary to fulfil the purposes identified herein or otherwise identified at the time of collection or for a purpose reasonably related to those purposes such as:
- To conduct customer surveys in order to enhance the provision of our services;
- To contact our customers directly about Jennis & Warmann products and services that may be of interest;
3.2 We will not use or disclose customer Personal Information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell customer lists or Personal Information to other parties, although we have a commercial arrangement with Jennis & Warmann.
Policy 4 – Retaining Personal Information
4.1 If we use customer Personal Information to make a decision that directly affects the customer, we will retain that Personal Information for at least one year unless the DPA requires us to dispose of or destroy this information earlier than that so that the customer has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain customer Personal Information only as long as is reasonably necessary to fulfil the identified purposes or a legal requirement.
Policy 5 – Ensuring Accuracy of Personal Information
5.1 We will make reasonable efforts to ensure that customer Personal Information is kept accurate and complete.
5.2 Customers may request correction to their Personal Information in order to ensure its accuracy and completeness. A request to correct Personal Information must be made in writing and provide sufficient detail to identify the Personal Information and the correction being sought.
5.3 If the Personal Information is demonstrated by the customer to be inaccurate or incomplete, we will so far as practicable correct the information as required and send the corrected information to any organization to which we disclosed the Personal Information in the previous year. If the correction is not made, we will note the customer’s correction request in the file.
Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security of customer Personal Information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
6.2 Jennis & Warmann undertakes that the following security measures will be followed to ensure that customer Personal Information is appropriately protected:
- All Personal Information data will be stored electronically on an encrypted database of Jennis & Warmann protected by a firewall. Physical access to the database will be protected by 24/7 guards who will only allow authorised personnel access to the database, such personnel will be limited to those that need access.
6.3 Jennis & Warmann will use appropriate security measures when destroying customer’s Personal Information such as deleting electronically stored information.
6.4 Jennis & Warmann will continually review and update our security policies and controls as technology changes to ensure ongoing Personal Information security.
Policy 7 – Providing Customers Access to Personal Information
7.1 Customers have a right to access their Personal Information, subject to limited exceptions. We will take all reasonable steps to assist customers in any legitimate access requests but the actual control of Personal Information and other customer data will be with Jennis & Warmann.
7.2 A request to access Personal Information must be made to Jennis & Warmann in writing and provide sufficient detail to identify the Personal Information being sought.
7.3 Upon request, we will also tell customers how Jennis & Warmann use their Personal Information and to whom it has been disclosed if applicable.
7.4 Jennis & Warmann will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfil the request.
7.5 A minimal fee may be charged for providing access to Personal Information. Where a fee may apply, Jennis & Warmann will inform the customer of the cost and request further direction from the customer on whether or not we or Jennis & Warmann should proceed with the request.
7.6 If a request is refused in full or in part, we or Jennis & Warmann will notify the customer in writing, providing the reasons for refusal and the recourse available to the customer.
Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual
8.2 Customers should direct any complaints, concerns or questions regarding Jennis & Warmann compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the customer may also write to the Information and Privacy Commissioner of British Columbia or the Information Commissioner in the United Kingdom.
Policy 9 – Cookies
Policy 10 – Access
You can access information held about you and request changes by accessing your personal Account on the Jennis & Warmann website (currently at www.jennisandwarmann.uk).
Policy 11 – Export and transfer
In order to provide our services to you, if you are using the service outside of United Kingdom, as well as being processed in the country where you are located, we will transfer your Personal Information to Jennis & Warmann in United Kingdom.
If you communicate with us via email your Personal Information may also be transferred to and via our service provider located the United Kingdom.
We may also transfer your Personal Information to service providers acting on our behalf in the UK.
We take steps to ensure that any service providers provide adequate protection for your Personal Information.
Your personal information may be accessible to regulatory, law enforcement and national security authorities of those jurisdictions, and may be subject to disclosure in accordance with the laws of those countries.
Contact information for Jennis & Warmann Privacy Officer:
Jennis & Warmann Ltd
115 Stoke Newington Road
What Do We Collect?
We may collect, store and use the following kinds of personal data:
(a) information about your visits to and use of this website;
(b) information about any transactions carried out between you and us on or in relation to this website, including information relation to any purchases you make of our goods or services
(c) information that you provide to us for the purpose of registering with us and/or subscribing to our website services and/or email notification
We may collect information about your computer and your visits to this website such as your IP address, geographical location, browser type, referral source, the length of visit and number of page views. we may use this information in the administration of this website, to improve the website’s usability, and for marketing purposes.
We may send a cookie which may be stored by your browser on your computer’s hard drive. We may use the information we obtain from the cookie in the administration of this website, to improve the website’s usability and for marketing purposes. We may also use that information to recognise your computer when you visit our website and to personalise our website for you. Our advertisers may also send you cookies.
Most browsers allow you to refuse to accept cookies. (For example, in Internet Explorer you can refuse all cookies by clicking “Tools”, “Internet Options”, “Privacy”, and selecting “Block all cookies” using the sliding selector.) This will, however, have a negative impact upon the usability of many websites, including this one.
How Do We Use You Information?
(a) improve your browsing experience by personalising the website:
(b) send information (other than marketing communications) to you which we think may be of interest to you by post or by email or similar technology;
We will not without your express consent provide your personal information to any third parties for the purpose of direct marketing.
(a) to the extent that we are required to do so by law;
(b) in connection with any legal proceedings or prospective legal proceedings;
(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk): and
(d) to the purchaser or seller (or prospective purchaser or seller) of any business or asset which we are (or are contemplating) selling or purchasing.
We will take reasonable precautions to prevent the loss, misuse or alteration of your personal information. However, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to try to prevent unauthorised access.
We will store all the personal information you provide on our secure servers. All electronic transactions you make to or receive from us will be encrypted using SSL technology.
We may record calls made to us for quality monitoring and training purposes.
The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £15 to meet our costs in providing you with details of the information we hold about you. You have the right to ask us not to process your personal data for marketing purposes. In practice, you will usually either expressly agree in advance to our use of your personal data for marketing purposes, or we will provide you with an opportunity to opt-out of the use of your personal data for marketing purposes. You can also instruct us not to use your personal data for marketing purposes by emailing us