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Privacy Policy


Introduction


This Privacy Notice explains in detail the types of personal data we may collect about you when you
interact with us. It also explains how we’ll store and handle that data, and keep it safe.

We want you to be fully informed about your rights, and how JN Jewellery Ltd uses your data; for
example, we will explain things such as our credit checking procedure, and how we combine data to
build a picture of you.

We hope the following sections will answer any questions you have but if not, please do get in touch
with us.

It’s likely that we’ll need to update this Privacy Notice from time to time. We will notify you of any
significant changes, but you are welcome to come back and check it whenever you wish.

Consent


In specific situations, we can collect and process your data with your consent.

For example, when you tick a box to receive email newsletters.

Contractual obligations


In certain circumstances, we need your personal data to comply with our contractual obligations.

For example, if you order an item from us for delivery, we’ll collect your address details to deliver
your purchase, and pass them to our courier.

Legal compliance

If the law requires us to, we may need to collect and process your data.

For example, we can pass on details of people involved in fraud or other criminal activity affecting JN
Jewellery Ltd

Legitimate interest


In specific situations, we require your data to pursue our legitimate interests in a way which might
reasonably be expected as part of running our business and which does not materially impact your
rights, freedom or interests.

For example, we will use your purchase history to send you or make available personalised offers.

We also combine the ordering history of many customers to identify trends and ensure we can keep
up with demand, or develop new products.

We will also use your address details to send you marketing information by post, telling you about
products that we think might interest you.

When do we collect your personal data?


  • When you visit any of our websites, and use your account to buy products on the phone, by
    fax in person or online.
  • When you create an account with us.
  • When you purchase a product in person or by phone but don’t have an account.
  • When you engage with us on social media.
  • When you download or install one of our apps.
  • When you contact us by any means with queries, complaints etc.
  • When you ask our team to email you information about a product.
  • When you book any kind of appointment with us.
  • When you choose to complete any surveys we send you.
  • When you comment on or review our products and services.
  • Any individual may access personal data related to them, including opinions. So if your
    comment or review includes information about a member of staff who provided that service,
    it may be passed on to them if requested.
  • When you fill in any forms we may collect your personal data.
  • When you’ve given a third party permission to share with us the information they hold about
    you.
  • We collect data from publicly-available sources (such as Companies House) when you have
    given your consent to share information or where the information is made public as a matter
    of law.
  • When you visit our showroom and offices which have CCTV systems operated for the security
    of both customers and staff. These systems may record your image during your visit.

What sort of personal data do we collect?


If you have a web account with us: your name, gender, date of birth, billing/delivery address,
orders, receipts and payment details, email and telephone number. For your security, we’ll
also keep a record of your login password.

Details of your interactions with us by telephone, email and online.

For example, we collect notes from our conversations with you, details of any complaints or
comments you make, details of purchases you made, items viewed or added to your basket, brands
you show interest in, web pages you visit and how and when you contact us.

Copies of documents you provide to prove your age or identity where the law requires this.
(including your passport and driver's licence). This will include details of your full name,
address, date of birth and facial image. If you provide a passport, the data will also include
your place of birth, gender and nationality.

Details of your visits to our websites or apps, and which site you came from to ours.

Information gathered by the use of cookies in your web browser

Payment card information.

Your comments and product reviews.

Your image may be recorded on CCTV when you visit our showroom and offices.

To deliver the best possible web experience, we collect technical information about your
internet connection and browser as well as the country and telephone code where your
computer is located, the web pages viewed during your visit, the advertisements you clicked
on, and any search terms you entered.

Your social media username, if you interact with us through those channels, to help us
respond to your comments, questions or feedback.

How and why do we use your personal data?


We want to give you the best possible customer experience. One way to achieve that is to get the
richest picture we can of who you are by combining the data we have about you.

We then use this to offer you promotions, products and services that are most likely to interest you.

The data privacy law allows this as part of our legitimate interest in understanding our customers
and providing the highest levels of service.

Of course, if you wish to change how we use your data, you’ll find details in the ‘What are my
rights?’ section below.

Remember, if you choose not to share your personal data with us, or refuse certain contact
permissions, we might not be able to provide some services you’ve asked for.

For example, if you’ve asked us to let you know when an item comes back into stock, we can’t do
that if you’ve withdrawn your general consent to hear from us.

Here’s how we’ll use your personal data and why:


To process any orders that you make by using our websites, apps or showroom. If we don’t
collect your personal data during checkout, we won’t be able to process your order and
comply with our legal obligations.

For example, your details may need to be passed to a third party to supply or deliver the product or
service that you ordered, and we may keep your details for a reasonable period afterwards in order
to fulfil any contractual obligations such as refunds, guarantees and so on.

To respond to your queries, refund requests and complaints. Handling the information you
sent enables us to respond. We may also keep a record of these to inform any future
communication with us and to demonstrate how we communicated with you throughout. We
do this on the basis of our contractual obligations to you, our legal obligations and our
legitimate interests in providing you with the best service and understanding how we can
improve our service based on your experience.

To protect our business and your account from fraud and other illegal activities. This includes
using your personal data to maintain, update and safeguard your account. We’ll also monitor
your browsing activity with us to quickly identify and resolve any problems and protect the
integrity of our websites. We’ll do all of this as part of our legitimate interest.


For example, by checking your password when you login and using automated monitoring of IP
addresses to identify possible fraudulent log-ins from unexpected locations.

To protect our customers, premises, assets and staff from crime, we operate CCTV systems in
our showroom and offices which record images for security. We do this on the basis of our
legitimate business interests.

To process payments and to prevent fraudulent transactions. We do this on the basis of our
legitimate business interests. This also helps to protect our customers from fraud.

If we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud
monitoring and suspicious transaction monitoring, we will process this data for the purposes
of preventing or detecting unlawful acts. We aim is to protect the individuals we interact with
from criminal activities.

With your consent, we will use your personal data, preferences and details of your
transactions to keep you informed by email, web, text, telephone and through our contact
centres about relevant products and services including tailored special offers, discounts,
promotions, events and so on.


Of course, you are free to opt out of hearing from us by any of these channels at any time.

To send you relevant, personalised communications by post in relation to updates, offers,
services and products. We’ll do this on the basis of our legitimate business interest.

You are free to opt out of hearing from us by post at any time.

To send you communications required by law or which are necessary to inform you about our
changes to the services we provide you. For example, updates to this Privacy Notice, product
recall notices, and legally required information relating to your orders. These service messages
will not include any promotional content and do not require prior consent when sent by email
or text message. If we do not use your personal data for these purposes, we would be unable
to comply with our legal obligations.

To display the most interesting content to you on our websites or apps, we’ll use data we hold
about your favourite brands or products and so on. We do so on the basis of your consent to
receive app notifications and/or for our website to place cookies or similar technology on your
device.

For example, we might display a list of items you’ve recently looked at, or offer you
recommendations based on your purchase history and any other data you’ve shared with us.

To develop, test and improve the systems, services and products we provide to you. We’ll do
this on the basis of our legitimate business interests.

For example, we’ll record your browser’s Session ID to help us understand more when you leave us
online feedback about any problems you’re having

To comply with our contractual or legal obligations to share data with law enforcement.

To send you survey and feedback requests to help improve our services. These messages will
not include any promotional content and do not require prior consent when sent by email or
text message. We have a legitimate interest to do so as this helps make our products or
services more relevant to you.

Of course, you are free to opt out of receiving these requests from us at any time by updating your
preferences in your online account.

Combining your data for personalised direct marketing


We want to bring you offers and promotions that are most relevant to your interests at
particular times. To help us form a better, overall understanding of you as a customer, we
combine your personal data, for example your ordering history. For this purpose, we also
combine the data that we collect directly from you with data that we obtain from third parties to
whom you have given your consent to pass that data onto us – such as Companies House
mentioned above.

How we protect your personal data

We know how much data security matters to all our customers. With this in mind we will treat
your data with the utmost care and take all appropriate steps to protect it.

We secure access to all transactional areas of our websites and apps using ‘https’ technology.

Access to your personal data is password-protected, and sensitive data (such as payment card
information) is secured by SSL encryption.

We regularly monitor our system for possible vulnerabilities and attacks, and we carry out
penetration testing to identify ways to further strengthen security.

How long will we keep your personal data?

Whenever we collect or process your personal data, we’ll only keep it for as long as is
necessary for the purpose for which it was collected.


At the end of that retention period, your data will either be deleted completely or anonymised,
for example by aggregation with other data so that it can be used in a non-identifiable way for
statistical analysis and business planning.

Some examples of customer data retention periods:

Orders

When you place an order, we’ll keep the personal data you give us for seven years so we can
comply with our legal and contractual obligations.

Who do we share your personal data with?

We sometimes share your personal data with trusted third parties.

For example, delivery couriers, for fraud management, to handle complaints, to help us personalise
our offers to you and so on.

Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:

We provide only the information they need to perform their specific services.

They may only use your data for the exact purposes we specify in our contract with them.

We work closely with them to ensure that your privacy is respected and protected at all times.

If we stop using their services, any of your data held by them will either be deleted or
rendered anonymous.

Examples of the kind of third parties we work with are:

  • IT companies who support our website and other business systems.
  • Operational companies such as delivery couriers.
  • Direct marketing companies who help us manage our electronic communications with
    you.
  • Google/Facebook to show you products that might interest you while you’re browsing
    the internet. This is based on either your marketing consent or your acceptance of
    cookies on our websites.


For fraud management, we may share information about fraudulent or potentially fraudulent
activity in our premises or systems. This may include sharing data about individuals with law
enforcement bodies.

We may also be required to disclose your personal data to the police or other enforcement,
regulatory or Government body, in your country of origin or elsewhere, upon a valid request
to do so. These requests are assessed on a case-by-case basis.

Where your personal data may be processed


International orders

If you are based outside the UK and place an order with us, we will transfer the personal data that
we collect from you to the UK.

Protecting your data outside the EEA

The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway. We may
transfer personal data that we collect from you to third-party data processors in countries that are
outside the EEA.

For example, this might be required in order to fulfil your order, process your payment details or
provide support services.

If we do this, we have procedures in place to ensure your data receives the same protection as if it
were being processed inside the EEA. For example, our contracts with third parties stipulate the
standards they must follow at all times. If you wish for more information about these contracts,
please contact our Customer Service Team.


Any transfer of your personal data will follow applicable laws and we will treat the information
under the guiding principles of this Privacy Notice.

What are your rights over your personal data


An overview of your different rights

You have the right to request:

  • Access to the personal data we hold about you, free of charge in most cases.
  • The correction of your personal data when incorrect, out of date or incomplete.
  • For example, when you withdraw consent, or object and we have no legitimate overriding
    interest, or once the purpose for which we hold the data has come to an end (such as the end
    of a warranty).
  • That we stop using your personal data for direct marketing (either through specific channels,
    or all channels).
  • That we stop any consent-based processing of your personal data after you withdraw that
    consent.
  • Review by a staff member of any decision made based solely on automatic processing of your
    data (i.e. where no human has yet reviewed the outcome and criteria for the decision).
  • You have the right to request a copy of any information about you that JN Jewellery Ltd holds at any
    time, and also to have that information corrected if it is inaccurate. To ask for your information,
    please contact our Customer Service Team. If we choose not to action your request, we will explain
    to you the reasons for our refusal.

    Your right to withdraw consent

    Whenever you have given us your consent to use your personal data, you have the right to change
    your mind at any time and withdraw that consent, by doing so JN Jewellery Ltd will be unable to
    continue trading with you.

    Where we rely on our legitimate interest

    In cases where we are processing your personal data on the basis of our legitimate interest, you can
    ask us to stop for reasons connected to your individual situation. We must then do so unless we
    believe we have a legitimate overriding reason to continue processing your personal data.

    Direct marketing

    You have the right to stop the use of your personal data for direct marketing activity through all
    channels, or selected channels. We must always comply with your request.

    Checking your identity

    To protect the confidentiality of your information, we will ask you to verify your identity before
    proceeding with any request you make under this Privacy Notice. If you have authorised a third party
    to submit a request on your behalf, we will ask them to prove they have your permission to act.

    How can you stop the use of your personal data for direct marketing?

    There are several ways you can stop direct marketing communications from us:

    • Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop
      any further emails from that particular division.
    • Write to Customer Service Team, JN Jewellery Ltd, 18 St Cross Street, London, EC1N 8UN,
      United Kingdom

    Please note that you may continue to receive communications for a short period after changing your
    preferences while our systems are fully updated.

    Contacting the Regulator


    If you feel that your data has not been handled correctly, or you are unhappy with our response to
    any requests you have made to us regarding the use of your personal data, you have the right to
    lodge a complaint with the Information Commissioner’s Office.

    You can contact them by calling 0303 123 1113.
    Or go online to www.ico.org.uk/concerns (opens in a new window; please note we can't be
    responsible for the content of external websites)

     

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