Privacy Policy

 

BACKGROUND:

 

JMO ONLINE LIMITED understands that your privacy is important to you and that you care about how your personal data is used. [We] OR [I] respect and value the privacy of everyone who visits this website, www.akaroo.com (“[Our] OR [My] Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with [our] OR [my] obligations and your rights under the law.

 

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy [is deemed to occur upon your first use of [Our] OR [My] Site] AND/OR [You will be required to read and accept this Privacy Policy when signing up for an Account]. If you do not accept and agree with this Privacy Policy, you must stop using [Our] OR [My] Site immediately.

 

1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

 

“Account”	means an account required to access and/or use certain areas and features of [Our] OR [My] Site;
“Cookie”	means a small text file placed on your computer or device by [Our] OR [My] Site when you visit certain parts of [Our] OR [My] Site and/or when you use certain features of [Our] OR [My] Site. Details of the Cookies used by [Our] OR [My] Site are set out in Part 14, below; and
[“Cookie Law”	means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;]

 

1. Information About [Us] OR [Me]

[Our] OR [My] Site is [owned and] operated by JMO Online Limited, a limited company [registered in England under company number 09745550

].

[Registered address: 133 Harrison Road, Leicester, LE4 6NP, United Kingdom.]

[Main trading address:] OR [Address:] 137a Harrison Road, Leicester, LE4 6NP, United Kingdom.

[VAT number: GB221242463.]

[Data Protection Officer: Deepen Pau.

Email address: enquiries@akaroo.com.

Telephone number: +44 (0) 116 2666206.

Postal Address: 137a Harrison Road, Leicester, LE4 6NP, United Kingdom.]

You can also contact us through our customer contact page.

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 (https://ico.org.uk). In the UK, please read: https://ico.org.uk/for-the-public/raising-concerns/ for details of how to do this. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

 

1. What Does This Policy Cover?

This Privacy Policy applies only to your use of [Our] OR [My] Site. [Our] OR [My] Site may contain links to other websites. Please note that [we] OR [I] have no control over how your data is collected, stored, or used by other websites and [we] OR [I] advise you to check the privacy policies of any such websites before providing any data to them.

 

1. What is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

 

1. What Are My Rights?

Under the GDPR, you have the following rights, which [we] OR [I] will always work to uphold:

a)            The right to be informed about [our] or [my] collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact [us] OR [me] to find out more or to ask any questions using the details in Part 15.

b)            The right to access the personal data [we] OR [I] hold about you. Part 13 will tell you how to do this.

c)            The right to have your personal data rectified if any of your personal data held by [us] OR [me] is inaccurate or incomplete. Please contact [us] OR [me] using the details in Part 15 to find out more.

d)            The right to be forgotten, i.e. the right to ask [us] OR [me] to delete or otherwise dispose of any of your personal data that [we] OR [I] have. Please contact [us] OR [me] using the details in Part 15 to find out more.

e)            The right to restrict (i.e. prevent) the processing of your personal data.

f)             The right to object to [us] OR [me] using your personal data for a particular purpose or purposes.

g)            The right to data portability. This means that, if you have provided personal data to [us] OR [me] directly, [we] OR [I] am using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask [us] OR [me] for a copy of that personal data to re-use with another service or business in many cases.

h)            Rights relating to automated decision-making and profiling. [[We] OR [I] do not use your personal data in this way.]

For more information about [our] OR [my] use of your personal data or exercising your rights as outlined above, please contact [us] OR [me] using the details provided in Part 15.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about [our] OR [my] use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

 

1. What Data Do We Collect?

Depending upon your use of [Our] OR [My] Site, [we] OR [I] may collect some or all of the following personal [and non-personal] data (please also see Part 14 on [our] OR [my] use of Cookies and similar technologies [and [our] OR [my] Cookie Policy https://www.akaroo.com/pages/information/cookie-policy.html]):

• [Name;]
• [Date of birth;]
• [Gender;]
• [Address;]
• [Email address;]
• [Telephone number;]
• [Business name;]
• [Job title;]
• [Profession;]
• [Payment information;]
• [Information about your preferences and interests;]
• [IP address];
• [Web browser type and version;]
• [Operating system;]
• [A list of URLs starting with a referring site, your activity on [Our] OR [My] Site, and the site you exit to;]

 

1. How Do You Use My Personal Data?

Under the GDPR, [we] OR [I] must always have a lawful basis for using personal data. This may be because the data is necessary for [our] OR [my] performance of a contract with you, because you have consented to [our] OR [my] use of your personal data, or because it is in [our] OR [my] legitimate business interests to use it. Your personal data [will] OR [may] be used for [one of] the following purposes:

• [Providing and managing your Account;]
• [Providing and managing your access to [Our] OR [My] Site;]
• [Personalising and tailoring your experience on [Our] OR [My] Site;]
• [Supplying [our] OR [my] [products] AND/OR [services] to you. Your personal details are required in order for [us] OR [me] to enter into a contract with you.]
• [Personalising and tailoring [our] OR [my] [products] AND/OR [services] for you.]
• [Communicating with you. This may include responding to emails or calls from you.]
• [Supplying you with information by [email] AND/OR [post] that you have opted-in to (you may unsubscribe or opt-out at any time by clicking the unsubscribe button on any of our marketing emails..]

 

[With your permission and/or where permitted by law, [we] OR [I] may also use your personal data for marketing purposes, which may include contacting you by [email] AND/OR [telephone] AND/OR [text message] AND/OR [post] with information, news, and offers on [our] OR [my] [products] AND/OR [services]. You will not be sent any unlawful marketing or spam. [We] OR [I] will always work to fully protect your rights and comply with [our] OR [my] obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.]

[[We] OR [I] use the following automated system[s] for carrying out certain kinds of [decision-making] AND/OR [profiling]. If at any point you wish to query any action that [we] OR [I] take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the GDPR gives you the right to do so. Please contact [us] OR [me] to find out more using the details in Part 15.

• [The following automated decision-making method(s) may be used:
  • We use an external provider to run our store, BigCommerce. BigCommerce is based in the US and is a participant in the EU-US Privacy Shield Framework and committed to providing best-in-class service and data protection. You can check its participation in the Privacy Shield here on the official site of The International Trade Administration (ITA), U.S. Department of Commerce..

[The following automated profiling may take place:

• Through BigCommerce, we also use other, highly specialized external providers to provide the most competitive services. For example: ● Payment: ​Our store is PCI-DSS compliant (a very strict industry standard with requirements for the security of credit card information), but we want to use accredited companies to process your credit card information. Stripe ● Shipping: ​We integrate with a number of shipping companies to fulfill your orders. Hermes, DPD, Royal Mail, Yodel, DHL & Parcel Force

 

1. How Long Will You Keep My Personal Data?

[We] OR [I] will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

• We keep your data for as long as you have an account with us. We also keep some data for security investigation. Most importantly, we have specific obligations for fraud detection and tax reasons. Therefore, we might need to retain certain data even if you ask to delete it.;

 

1. How and Where Do You Store or Transfer My Personal Data?

[[We] OR [I] will only store or transfer your personal data in the UK. This means that it will be fully protected under the GDPR.]

 

OR

 

[[We] OR [I] will only store or transfer your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the GDPR or to equivalent standards by law.]

 

OR

 

[[We] OR [I] may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that [we] OR [I] will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR as follows.

[[We] OR [I] share your data within the group of companies of which [we are] OR [I am] a part. Where this involves the transfer of personal data outside the EEA, [our] OR [my] group ensures that personal data is protected by requiring all companies within the group to follow the same rules with respect to personal data usage. These are known as “binding corporate rules”. More information on binding corporate rules is available from the European Commission.]

OR

[[We] OR [I] share your data with external third parties, as detailed below in Part 10, that are based outside of the EEA. The following safeguard[s] [is] OR [are] applied to such transfers:

[[We] OR [I] will only transfer your personal data to countries that the European Commission has deemed to provide an adequate level of personal data protection. More information is available from the European Commission.]

OR

[[We] OR [I] use specific contracts with external third parties that are approved by the European Commission for the transfer of personal data to third countries. These contracts ensure the same levels of personal data protection that would apply under the GDPR. More information is available from the European Commission.]

AND/OR

[Where [we] OR [I] transfer your data to a third party based in the US, this may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar to those in Europe. More information is available from the European Commission.]]

Please contact [us] OR [me] using the details below in Part 15 for further information about the particular data protection mechanism used by [us] OR [me] when transferring your personal data to a third country.]

The security of your personal data is essential to [us] OR [me], and to protect your data, [we] OR [I] take a number of important measures, including the following:

• We use an external provider to run our store, BigCommerce. BigCommerce is based in the US and is a participant in the EU-US Privacy Shield Framework and committed to providing best-in-class service and data protection. You can check its participation in the Privacy Shield here on the official site of The International Trade Administration (ITA), U.S. Department of Commerce.

 

1. Do You Share My Personal Data?

[[We] OR [I] will not share any of your personal data with any third parties for any purposes, subject to one important exception.

In some limited circumstances, [we] OR [I] may be legally required to share certain personal data, which might include yours, if [we are] OR [I am] involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.]

 

OR

 

[[[We] OR [I] may share your personal data with other companies in [our] OR [my] group for Payment, Shipping & Marketing. This includes [subsidiaries] AND/OR [[our] OR [my] holding company and its subsidiaries.]]

[[We] OR [I] may sometimes contract with the following third parties to supply certain [products] AND/OR [services]. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that [we] OR [I] hold.

• Stripe Payments, Mail Chimp Marketing & Shipping Providers: Hermes, DPD, Royal Mail, Yodel, DHL & Parcel Force

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  (c) Profile	Performance of a contract with you.
To process and deliver your order, including:	(a) Identity  (b) Contact (c) Financial  (d) Transaction  (e) Marketing and Communications	Performance of a contract with you. We may also use some of the data related to your queries for our legitimate interests of ensuring our customer service quality standards are met.
To collect and recover money owed to us in respect of your order	(a) Identity  (b) Contact  (c) Financial  (d) Transaction	Necessary for our legitimate interests (to recover debts due to us).
To carry out fraud assessments	(a) Identity  (b) Contact  (c) Financial  (d) Transaction (e) Technical	Necessary for our legitimate interests of ensuring payments are not fraudulent
To process your purchase of a gift voucher from us	(a) Identity  (b) Contact  (c) Financial  (d) Transaction	Performance of a contract with you.
To notify you in relation to our legal obligations and documents, including changes to our terms or Privacy Policy	(a) Identity  (b) Contact  (c) Profile	Necessary for our legitimate interests of ensuring our customers are updated on these changes.
To help us improve our offering to our customers, including asking you to leave a review or take a survey, or provide customer insights	(a) Identity  (b) Contact  (c) Profile  (d) Marketing and Communications	Necessary for our legitimate interests (to study how customers use our products/services, to improve our offering to our customers, to develop them and grow our business).
To enable you to partake in a prize draw or competition	(a) Identity  (b) Contact  (c) Profile  (d) Usage  (e) Marketing and Communications	Performance of a contract with you to fulfil the promotion and run the competition/prize draw. We may also subsequently use your entries for the legitimate interests of understanding our customer base more effectively.
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) Profile (d) Technical	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).
To deliver relevant website content, advertisements and other marketing material 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 to inform our marketing strategy and to improve our offering to you). Please note that where cookies are used for this purpose, this is covered separately by our Cookies Policy.
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). Please note that where cookies are used for this purpose, this is covered by our Cookies Policy.
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, and to improve our offering to you).

•  

If any of your personal data is required by a third party, as described above, [we] OR [I] will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, [our] OR [my] obligations, and the third party’s obligations under the law, as described above in Part 9.]

[If any personal data is transferred outside of the EEA, [we] OR [I] will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 9.]

In some limited circumstances, [we] OR [I] may be legally required to share certain personal data, which might include yours, if [we are] OR [I am] involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.]

 

1. How Can I Control My Personal Data?

11.1       In addition to your rights under the GDPR, set out in Part 5, whenyou submit personal data via [Our] OR [My] Site, you may be given options to restrict [our] OR [my] use of your personal data. In particular, [we] OR [I] aim to give you strong controls on [our] OR [my] use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from [us] OR [me] which you may do by unsubscribing using the links provided in [our] OR [my] emails [and] OR [,] at the point of providing your details [and by managing your Account]).

11.2       You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

 

1. Can I Withhold Information?

You may access [certain areas of] [Our] OR [My] Site without providing any personal data at all. [However, to use all features and functions available on [Our] OR [My] Site you may be required to submit or allow for the collection of certain data.]

You may restrict [our] OR [my] use of Cookies. For more information, see Part 14 [and [our] OR [my] Cookie Policy https://www.akaroo.com/pages/information/cookie-policy.html].

 

1. How Can I Access My Personal Data?

If you want to know what personal data [we] OR [I] have about you, you can ask [us] OR [me] for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. [To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell [us] OR [me] everything [we] OR [I] need to know to respond to your request as quickly as possible.]

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover [our] OR [my] administrative costs in responding.

[We] OR [I] will respond to your subject access request within [less than one month and, in any case, not more than] one month of receiving it. Normally, [we] OR [I] aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date [we] OR [I] receive your request. You will be kept fully informed of [our] OR [my] progress.

 

1. How Do You Use Cookies?

[[Our] OR [My] Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by [us] OR [me] and are used only by [us] OR [me]. [We] OR [I] use Cookies to facilitate and improve your experience of [Our] OR [My] Site and to provide and improve [our] OR [my] [products] AND/OR [services]. [We] OR [I] have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

All Cookies used by and on [Our] OR [My] Site are used in accordance with current Cookie Law.

Before Cookies are placed on your computer or device, you will be shown a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling [us] OR [me] to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of [Our] OR [My] Site may not function fully or as intended.

[Certain features of [Our] OR [My] Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that [Our] OR [My] Site may not work properly if you do so. [We] OR [I] have taken great care to ensure that your privacy is not at risk by allowing them.]

The following first-party Cookies may be placed on your computer or device:

 

Name of Cookie	Purpose	Strictly Necessary
Google Adwords; MSN/Bing; Double Click; Yahoo (Right Media); Facebook, Pinterest, Taboola, Rakuten (LinkShare) Google Adwords, MSN/Bing, Double Click,Yahoo, Facebook, Pinterest, Taboola and Rakuten (LinkShare) use cookies (or, if applicable, anonymous identifiers) to track our own paid advertising activity. We use the information collected by these cookies to help us determine where our ads will be most effective online. Each individual advertiser uses its own tracking cookies and the data taken is not confidential data or interchangeable. Yes Google Analytics (including Universal Analytics and Google Analytics for Display Advertisers) Google Analytics use cookies (or, if applicable, anonymous identifiers) to collect data that helps us understand how people are using the site. We use this information to identify how and where we can improve the customer experience, and to help us determine where our ads will be most effective online. The data collected through these cookies is anonymous, does not collect specific customer data and is never shared with other third parties, other than Double Click Campaign Manager, which is a fully owned Google product. Yes Akaroo Akaroo uses cookies to enable some of the basic functionality that is required for you to browse and shop on our website, such as remembering which products you have added to your basket. The information collected through these cookies is only used for this purpose and is never shared or sold on to third parties. Yes Social Media plugins Sites such as Facebook and Pinterest, serve cookies in order to be able to share and discuss Notonthehighstreet’s products on social networks. Yes Share This Share This allows customers to share content, products and web pages from our website with other websites and social networking sites. The cookies used by Share This allow us to track the type of content, products and pages that our users are sharing to help us better understand which content is most engaging for our customers so that we can improve the content and customer experience in other areas of the website. Yes	<<insert description>>	<<yes / no>>

 

In addition to the controls that [we] OR [I] provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.

It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.]

 

OR

[[Our] OR [My] Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by [us] OR [me] and are used only by [us] OR [me]. [We] OR [I] use Cookies to facilitate and improve your experience of [Our] OR [My] Site and to provide and improve [our] OR [my] [products] AND/OR [services]. For more details, please refer to [our] OR [my] Cookie Policy https://www.akaroo.com/pages/information/cookie-policy.html

 

1. How Do I Contact You?

To contact [us] OR [me] about anything to do with your personal data and data protection, including to make a subject access request, please use the following details [(for the attention of GDPR Representative)]:

Email address: enquiries@akaroo.com.

Telephone number: +44 (0)116 2666206.

Postal Address: 137a Harrison Road, Leicester, LE4 6NP, United Kingdom.

 

1. Changes to this Privacy Policy

[We] OR [I] may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if [we] OR [I] change [our] OR [my] business in a way that affects personal data protection.

Any changes will be immediately posted on [Our] OR [My] Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of [Our] OR [My] Site following the alterations. [We] OR [I] recommend that you check this page regularly to keep up-to-date.