Privacy Policy

This is the privacy notice of JG42 Limited, company number 15436592, trading as [website trade name] (‘we’, ‘our’ or ‘us’).

Our registered business address at which you should contact us is 39 St Nicholas Road, Wallingford, United Kingdom, OX10 8HX.

Introduction

This notice sets out our privacy policy regarding personal data about you that we collect, store, transfer, use or otherwise act on. It tells you about your privacy rights and how the law protects you.

Our legal responsibility is to comply with the Data Protection Act 2018 (‘DPA’), as amended by the UK General Data Protection Regulation (‘UK GDPR’) and subsequent legislation. However, our privacy policy also complies with legislation in other jurisdictions, including with the California Consumer Privacy Act (‘CCPA’) and the California Privacy Rights Act (‘CPRA’).

In the context of the law and this notice, ‘personal data’ is information that clearly identifies you as an individual person or which could be used to identify you as such if combined with other information. Acting in any way on personal data is referred to as ‘processing’.

This notice applies to visitors to our website and subscribers to our courses.

Except as set out below, we do not share, or sell, or disclose your personal data to any third party.

  1.  How we obtain personal data

We obtain information about you:

  • directly from you
  • as a result of monitoring how you use our website and complete our courses
  1.  Types of personal data we collect directly

When you use subscribe to a course, we ask for, and you provide to us, personal data that includes:

  • personal identifiers, such your first and last names, and your date of birth; and
  • contact information, such as your email address.
  1.  Types of personal data we collect from your use of our services

From your use of our website, we might process:

  • communication between us, such as email messages you send us and our replies;
  • technical information about the hardware and the software you use to access our website and use our services, including your Internet Protocol (IP) address, your browser type and version and your device’s operating system;
  • usage information, including the frequency you access our website and courses, and the pages of our website that you visit;
  • your preferences to receive marketing from us; how you wish to communicate with us; and responses and actions in relation to your use of our services.
  1.  Our use of aggregated information

We may aggregate anonymous information such as statistical or demographic data for any purpose. Anonymous information is that which does not identify you as an individual person. Aggregated information may be derived from your personal data but is not considered as such in law because it does not reveal your identity.

For example, we may aggregate usage information to assess whether certain functionality of our website could be improved.

If we combine or connect aggregated information with your personal data so that it can identify you in any way, we treat the combined information as personal data, and it will be used in accordance with this privacy notice.

  1.  If you do not provide personal data we need

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform that contract.

In that case, we may have to stop providing a service to you. If so, we will notify you of this at the time.

  1.  The bases on which we process information about you

The law requires us to determine under which of six defined bases we process different categories of your personal data, and to notify you of the basis for each category.

If a basis on which we process your personal data is no longer relevant then we shall immediately stop processing your data.

If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.

  1.  Where we have a contractual obligation to you

When you subscribe to a course, you agree to our terms and conditions and a contract is formed between you and us.

In order to carry out our contractual obligations to you (provide our courses) we must process information you give us. Some of this information is personal data.

We shall continue to process this information until the contract between us ends.

  1.  Where you have provided your consent

Through other actions you might provide your consent to us to process information that may be personal data. For example, you might subscribe to a newsletter.

Wherever possible, we aim to obtain your explicit consent to process this information. But there may circumstances where we can imply your consent from your action.

We continue to process personal data on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.

You may withdraw your consent at any time by telling us. However, if you do so, you may not be able to use our website or our services further.

In all circumstances where we process your personal data (even those where we process under a different basis), we aim to obtain and keep your consent to do so.

However, you should be aware that the withdrawal of your consent might not necessarily prevent us from continuing to process your personal data if we use another basis to do so. For example, we may have a legal obligation to do so.

  1.  Where we determine there is a legitimate interest

We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.

Where we process your information on this basis, we do after having given careful consideration to:

  • whether the same objective could be achieved through other means;
  • whether processing (or not processing) might cause you harm; and
  • whether you would expect us to process your personal data, and
  • whether you would, in the round, consider it reasonable to do so.

As examples, we may process your data on this basis for the purposes of:

  • improving our services for you;
  • record-keeping for the proper and necessary administration of our business;
  • preventing fraudulent use of our website;
  • exercising our legal rights, including to detect and prevent fraud and to protect our intellectual property;
  • insuring against or obtaining professional advice that is required to manage business risk; and
  • protecting your interests where we believe we have a duty to do so.
    1.  Where we have a legal obligation

Sometimes we must process personal data in order to comply with a statutory obligation.

For example, we may be required to keep personal data for tax reasons for a certain number of years.

  1.  Payment information

Payment information is never taken by us or transferred to us either through our website or otherwise. Our employees and contractors never have access to it.

At the point of payment, you are transferred to a secure page on the website of our payment service provider. That page may be branded to look like a page on our website, but it is not controlled by us.

  1.  Cookies

Cookies are small text files that are placed on your computer's hard drive by your web browser when you visit a website that uses them. They allow information gathered on one web page to be stored until it is needed for use at a later date.

They are commonly used to provide you with a personalised experience while you browse a website, for example, allowing your preferences to be remembered.

They can also provide core functionality such as security, network management, and accessibility; record how you interact with the website so that the owner can understand how to improve the experience of other visitors; and serve you advertisements that are relevant to your browsing history.

Some cookies may last for a defined period of time, such as one visit (known as a session), one day or until you close your browser. Others last indefinitely until you delete them.

Your web browser should allow you to delete any cookie you choose. It should also allow you to prevent or limit their use. Your web browser may support a plug-in or add-on that helps you manage which cookies you wish to allow to operate.

The law requires you to give explicit consent for use of any cookies that are not strictly necessary for the operation of a website.

When you first visit our website, we ask you whether you wish us to use cookies. If you choose not to accept them, we shall not use them for your visit except to record that you have not consented to their use for any other purpose.

If you choose not to use cookies or you prevent their use through your browser settings, you may not be able to use all the functionality of our website.

We use Kajabi’s platform to host our website and to deliver our courses. Their cookie notice, at https://legal.kajabi.com/policies/cookie-notice, explains in detail what cookies they use and how they use them.

  1.  Personal identifiers from your browsing activity

Requests by your web browser to our servers for web pages and other content on our website are recorded.

We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.

We may use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.

If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.                     

  1.  Your rights

The law requires us to tell you about your rights and our obligations to you in regard to the processing and control of your personal data.

We do this now, by requesting that you read the information provided at https://www.knowyourprivacyrights.org

  1.  Use of our services by young people

If you are under 18, you may use our website only with consent from a parent or guardian.

We collect data about all users of and visitors to these areas regardless of age, and we anticipate that some of those users and visitors will be under the age of 18.

  1.  Encryption of data sent between us

We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.

Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.

  1.  Data may be processed outside the UK

Our business is incorporated as a limited company in the UK.

The headquarters of our website hosting provider, Kajabi, are in the United States of America.

Because Kajabi serves our website from a location closest to you, depending on from where you access it, it might be provided from a jurisdiction other than the UK.

Kajabi complies with the with the EU-US Data Privacy Framework (‘EU-US DPF’) and the UK Extension to the EU-US DPF. In other words, Kajabi abides by the same rules for processing personal data as a UK company would be required to follow.

Kajabi’s privacy policy (including information about its use of cookies) can be viewed at: https://legal.kajabi.com/policies/privacy

We may also use outsourced services in other countries outside the UK from time to time in other aspects of our business.

Accordingly data obtained within the UK or any other country could be processed outside the UK.

For example, we might use a data analytics platform, whose data may be stored in the United States of America.

If data may be transferred to a third party outside the UK then we ensure that the organisation that processes the data applies safeguards to the processing, and in particular, that the contracts between us and them require them to do so to the same standards as UK law requires.

  1.  Control over your own information

It is important that the personal data we hold about you is accurate and up to date. Please inform us if your personal data changes.

At any time you may review or update personally identifiable information that we hold about you, by signing in to your account on our website.

To obtain a copy of any information that is not provided on our website you should contact us to make that request.

When we receive any request to access, edit or delete personal data we first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

Please be aware that we are not obliged by law to provide you with all personal data we hold about you, and that if we do provide you with information, the law allows us to charge for such provision if doing so incurs costs for us. After receiving your request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.

  1.  Communicating with us

When you contact us, whether by telephone, through our website or by email, we may process personal data you have given to us in order to respond.

We record your request and our reply in order to increase the efficiency of our business.

We may keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.

  1.  Complaining

If you are not happy with our privacy policy, or if you have any complaint, then you should tell us.

When we receive a complaint, we record the information you have given to us on the basis of consent. We use that information to resolve your complaint.

If your complaint reasonably requires us to notify some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion whether we do give information, and if we do, what that information is.

We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.

If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.

If you are in any way dissatisfied about how we process your personal data, you have a right to lodge a complaint with the Information Commissioner's Office (ICO). This can be done at https://ico.org.uk/make-a-complaint/. We would, however, appreciate the opportunity to talk to you about your concern before you approach the ICO.

  1.  Retention period

Except as otherwise mentioned in this privacy notice, we keep your personal data only for as long as required by us:

  • to provide you with the services you have requested
  • to comply with other law, including for the period demanded by our tax authorities
  • to support a claim or defence in court
  1.  Compliance with the law

Our privacy policy complies with the law in the United Kingdom, specifically the DPA, as amended by the UK GDPR and the Privacy and Electronic Communications Regulations (‘PECR’).

  1.  Review of this privacy notice

We shall update this privacy notice from time to time as necessary.