1. YOUR INFORMATION
Njorun Active Limited (“we” and “us”) is committed to protecting your privacy.
As a customer or a visitor to our website we, and the companies that work on our behalf, collect information on you. This includes your personal information.
We also collect information on your use of our website and how you arrived at our website in the first place by using cookies or other tracking technologies.
Some other companies also collect certain information on you when you use our website, such as social networking sites or web analytic companies.
We will only keep information about you for as long as we need to, and we make sure that any companies that process your information on our behalf do the same.
2. MARKETING AND COMMERCIAL USE
When you gave us your information, you will have been offered the opportunity to sign up to our marketing communications.
You can subscribe to or unsubscribe from our marketing communications at any time.
We will only share information under the following circumstances:
- With our company group.
- With government, law enforcement agencies and regulatory bodies when we consider the disclosure to be fair, reasonable and legal.
- With credit reference agencies when we need to and service providers.
We take the security of your information very seriously, and have controls and processes to minimise the risk of a data breach occurring, though you must take responsibility when visiting other websites, even if following a link to them from our website.
In the event that a breach does occur, we will take appropriate steps to notify you if you are, or could be, affected and will make all efforts to minimise the impact. We use some companies to process information which are based overseas and outside Europe. We ensure that they have strict checks and controls in place to keep your information safe.
If there is a material change that could have a detrimental effect on you, and we have your contact details, we will contact you to check whether you are happy with it.
6. YOUR RIGHTS
You can ask us for a copy of your information or to correct the information we hold on you at any time.
7. THE DATA PROTECTION ACT
We comply with the principles set out in the Data Protection Act 1998.
8. CONTACT US
If you have a question, complaint or query with regards to how we use your information, please contact us and we will do our best to resolve it as soon as possible.
9. YOUR INFORMATION
9.1. The companies that work on our behalf
9.1.1. These are the companies that help us deliver our services to you. They include our marketing agencies, data hosting provider(s), and email service provider(s).
9.1.2. We only choose those companies who prioritise the protection of personal information and that pass the strict organisational and technical security standards that we set.
9.1.3. The companies that work on our behalf include:
(a) Our marketing agencies that provide analysis and understanding of our customers.
(b) Our data hosting providers that host and store information on our customers.
(c) Our email service provider broadcasts emails to our customers.
9.2. Personal Information
9.2.1. This is information that can identify you and includes the information you provide us with when you purchase from our website.
9.2.2. For example, your:
- name and address
- email address
- telephone number
- payment card information.
9.2.3. We process this information for the purposes of:
- dealing with your inquiries and requests
- providing and personalising our services
- compiling your profile
- administering membership records
- processing your payment
- crime prevention and prosecution of offenders
- maintaining information as a reference tool or general resource
- to notify you about changes to our service
- carrying out market research campaigns.
9.3. Information that we may buy
9.3.1. If we purchase information on you from another company, such as marketing lists, we promise to take all the necessary checks to make sure your information was collected legally.
9.3.2. We may also purchase profile information from other companies to better understand our customers and our market. This helps us to provide you with better suited products and services.
9.4 Information on your use of our website We collect information about your use of our website. This includes the pages of our website that have been viewed by you and for how long, and your website journey. This is done by cookies or other tracking technologies and will include your IP address, and if you have logged in, your log-in details too.
9.5. Cookies or other tracking technologies
9.5.2. You may disable cookie support on your browser but be aware that by doing so, you will lose certain features that require a cookie to work properly. We may use the information collected by the cookie to provide us with various statistics without identifying any individual.
9.5.3. Please contact us at email@example.com if you require information about disabling any cookies on our website.
9.5.4 We use the following cookies:
(a) Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
(b) Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
(c) Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region)
(d) Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
9.5.5. You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
(insert table of cookies)
9.6. How you arrived at our website
9.6.1. We collect information about how you arrived at our website in the first place. This can include what links or adverts of ours you've viewed or clicked on to reach us, or any search terms you’ve used. If we understand how you look for us, we hope to make it easier to be found.
9.6.2. If you see an advert of ours elsewhere, we or our ad agencies that work on our behalf, place a cookie on your browser. This is so that when you arrive at our website we can recognise that you’ve seen an advert of ours elsewhere.
9.7. Other companies
9.7.1. Some other companies also collect certain information from our website. This includes companies involved in:
a. Social networking applications
We have social networking widgets found in many of our pages. This widget gives you the tools to bookmark our websites, blog, share, tweet and email our content to a friend. Your interaction with those options will result in further cookies, from the providers you use being placed on your system. You can opt-out of the data collection and aggregation created from your interactions by contacting the relevant social network website owners.
b. Website analytics
9.8. Keeping information only as long as we need to
We will only keep information about you for as long as we need to. We make sure that any companies that process your data on our behalf do the same. We have an internal retention policy, where there are varying retention periods for different categories of information depending on our legal obligations and whether there is a commercial need.
10. MARKETING AND COMMERCIAL USE
10.1. Marketing communications
10.1.1. We will send you emails on a fortnightly, and occasionally weekly basis depending on the preferences you stated when you bought from us and/or joined our marketing lists.
10.2. Marketing from other companies
10.2.1. If we pass your information on to any other company for marketing purposes it will only be with your explicit consent, and only to companies we trust to keep your information secure and those who have passed our internal checks.
10.3. Subscribe or unsubscribe
10.3.1. You can subscribe to or unsubscribe from our marketing communications at any time, and we will action your request as quickly as possible.
10.3.2. You can do so by emailing us at firstname.lastname@example.org.
11.1. Sharing with our company group
11.1.1. We will share your information with other members of Njorun Active Limited family and their employees.
11.1.2. We may share your information with any successors in title to our business.
11.2. Sharing with government, law enforcement agencies and regulatory bodies
11.2.1. We will disclose information on you to these bodies when we consider the request to be fair, reasonable and legal.
11.3. Sharing with companies for marketing purposes
11.3.1. If we pass your information on to any other company for marketing purposes it will only be with your explicit consent and only to companies, we trust to keep your information secure and that pass our internal checks.
11.4. Sharing with service providers
11.4.1. We will share your information, only if necessary, with third party consultants, contractors or other service providers who may access your personal information when providing services (including but not limited to IT support services) to us.
11.4.2. We will share your information with auditors or contractors or other advisors auditing, assisting with or advising on any of our business purposes
12.1. Controls and processes
12.1.1. We take the security of our customers’ data very seriously. We use technical and organisational measures to keep your data as secure as possible.
12.1.2. Technical measures include multiple layers of firewalls, specialist devices to detect and prevent intrusion attempts and encryption systems to ensure data is scrambled while being transmitted from system to system. We perform regular system patching, and employ an independent security company to perform penetration tests (authorised attempts to try to hack our systems to show any risks) annually and whenever we bring new systems online.
12.1.3. Organisational measures include relevant policies and procedures, periodic security reviews and clearly defined responsibilities for security. We employ equally rigorous physical security polices to prevent physical access to our data centres.
12.1.4. All of our employees and data processors that have access to, and are associated with, the processing of your personal information are obliged to respect the confidentiality of your personal information.
All your card details are passed from your browser to Stripe using the highest levels of PCI and SSL encryption (https://stripe.com/help/security), or if you choose to Paypal, again using PCI and SSL encryption systems (https://www.paypal.com/uk/webapps/mpp/paypal-safety-and-security). Your user admin area is protected by your user name and password, which you should never divulge to anyone else.
12.2. Appropriate steps
12.2.1. We will do our very best to avoid a breach but sometimes events happen despite this. Our promise to you is that if they do happen, we will ensure that the impact on you is as minimal as it can be.
12.2.2. If we discover that your personal information has been breached and it could adversely affect you - and we have the means to let you know - we will do so as quickly as possible. If we can, we will tell you how the breach occurred, its nature, the steps we have taken to rectify its adverse effects and the steps you can take. We will provide you with details of who you can contact here if you have any queries and details of the regulator – the Information Commissioner's Office – should you want to speak to them.
12.3. Other websites
We are not responsible for the privacy policies and practices of other websites even if you accessed the third party website using links from our website. We recommend that you check the policy of each website you visit and contact the owner or operator of such website if you have any concerns or questions.
12.4. Strict checks and controls
12.4.2. We ensure all information sent overseas is dealt with only by companies who we trust and have passed our internal checks and controls.
14. YOUR RIGHTS
14.1. For a copy of your information
If you would like a copy of some or all of the personal information of yours we hold, please contact us email@example.com. We will charge you £10 for this information to cover the administration costs involved and we will do our best to respond to you as quickly as possible and in any event, within 40 days of receipt of your request.
14.2. To correct your information
We want to make sure that your personal information is accurate and up to date. Please always let us know if you think it is not.
15. THE DATA PROTECTION ACT
Njorun Active Limited is registered as a Data Controller under the terms of the Data Protection Act 1998 and we ensure we comply with all the protection the Act affords to you. Our registration number is (to be provided).
16.1.1. If you have a question, complaint or query around how we use your information, please contact us at firstname.lastname@example.org.
16.1.2. We will try respond to you within 7 days.
16.1.3. If you have a complaint regarding the use of your information by us, you can also complain to the regulator, the Information Commissioner's Office.