PRIVACY AND COOKIES POLICY
As the operators of the Jifflr mobile App (“App”) and the website Jifflr.com (“Website”), Jifflr Limited (“We“, “Us”) is committed to protecting and respecting your privacy. This Privacy and Cookies Policy (“Policy”) (together with and any other documents referred to therein) sets out the basis on which the personal data collected from you, or that you provide to Us will be processed by Us. Please read the following carefully to understand our views and practices regarding your personal data and how We will treat it.
For the purpose of the General Data Protection Regulation (“GDPR”) and the Data Protection Act 2018, (collectively the “Data Protection Laws”) the Data Controller is Jifflr Limited (Company Number 11058826) Unit 6, Blackthorn Way, Five Mile Business Park, Washingborough, Lincoln, England, LN4 1BF.
YOUR PERSONAL INFORMATION
Information we collect from you
We collect and process some or all of the following types of information from you in the course of you using Our App, Our website and any other services we may provide you:
- Information that you provide in Our App or on Our Website. This includes information provided by you when subscribing to our service; requesting further information or services; creating, reviewing or responding to market research campaigns. We may also ask you for information when you report a problem via Our Website.
- Specifically, where you are a Consumer, personal details such as name, email address, date of birth, gender, location or any other information input by you when using Our App, Website, completing our survey forms, or using any other of Our services.
- If you contact Us, We may keep a record of that correspondence.
- We will also ask you to complete surveys/ answer market research questions that We and other organisations use for research purposes. When responding to market research questions it is likely that your answers will convey Your opinions, comments, likes and dislikes and other user specific details.
- Details of Your visits to Our Website and use of our App including, but not limited to, traffic data, device information, location data, weblogs and other communication data, and the resources that you access.
Where you are a consumer looking to participate and contribute to market research (a “Consumer”), the provision of your personal details e.g. email address, gender, date of birth and location is required from You to enable Us to register your Jifflr Account, contextualise your responses, calculate payments and transfer funds to You.
If we need any more personal information from you, we will inform you prior to collecting such information.
USES MADE OF YOUR INFORMATION
Lawful basis for processing
We rely on “performance of a contract” on which we collect, use and share (in accordance with this policy only) your personal data in order to provide our services or to receive your services pursuant to an agreement with you
We rely on “legitimate interest”:
- Where We collect, use and share (in accordance with this policy only) your personal data in order to provide our services pursuant to an agreement with an organisation that has engaged you.
- Where We collect and use any personal data you provide (including any information you provide in your opinions, comments, likes and dislikes) where you have participated to our monthly ‘quiz’ in order to tailor and deliver relevant market research products to you.
- Where We contact you to provide you with information and offers we feel may interest you.
- To allow you to participate in interactive features of our service, when you choose to do so.
- To ensure that content on the Website and App are presented in the most effective manner for you and for the device(s) you use to access the Website and App;
- To provide you with information and offers that you request from Us or which We feel may interest you.
In addition to the above uses We may use your information to notify you about goods or services which may be of interest to you. Where We do this, We may contact you, by other means e.g. via e-mail or SMS). If you do not want Us to use your data in this way please delete your Jifflr account using the delete button in the App’s Profile page.
Automated decision making/profiling
Jifflr undertakes profiling on Consumers.
The Jifflr App is a market research tool intended to obtain useful and truthful feedback from users to help businesses, organisations and communities better serve their customers or stakeholder groups. The usefulness of the user feedback will increase if the respondents have an interest or some other association with the material requiring feedback. To help with directing market research to the appropriate audience, the ‘consumer’ user data entered into the App (at registration, during a monthly ‘quiz’, prompted by Jifflr to update or improve its user’s profile, or when providing responses to market research questions) will be used in manual and/or automated processes to develop a detailed user profile and ensure that any market research presented to a user is likely to be of interest, although this cannot be guaranteed.
If Your registration data or in-App market research responses are not truthful and honest it is likely that You will be presented with market research products that are of little interest to you. Not only will this impact Your in-App user experience, but it may affect the quality of your responses returned to third parties who pay Us to pay You to undertake the market research for them. Poor quality responses will mean that any responses have little intrinsic value and would undermine the Jifflr business model. To mitigate this risk automated processes examine user data, including answers to market research questions, to identify inconsistencies that may indicate inaccurate user data or responses that are either not truthful or they are in regular conflict.
This automated analysis may result in recommendations that user accounts are suspended or closed and in the most serious cases this process may automatically suspend or close user accounts. You have a right to object to this automated process, however by doing so we will no longer be able to provide you with our services.
DISCLOSURE OF YOUR INFORMATION
We may routinely disclose your personal data to third parties as follows:
- Third-party service providers, agents, subcontractors and other associated organisations for the purposes of supporting the Jifflr platform, completing tasks and providing services to you on our behalf (e.g. to host our servers and make payments to you);
- Any member of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 (where applicable).
If you are a Consumer, we do not disclose your personal data (such as your name, email address(es) and specific location based information). Any responses that you give when answering market research campaign questions are anonymised, meaning that when your responses are returned to the market research company or any other third party, your name, email address(es) or specific location based information are not included.
We may also disclose your personal data to third parties:
- if We are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms and Conditions, or
- to protect Our rights, property, or safety or that of our affiliated entities and our users and any third party We interact with to provide the App and Website; or
- in the event that We sell or buy any business or assets, in which case We may disclose your personal data to the prospective seller or buyer of such business or assets; or
- if We or substantially all of our assets are acquired by a third party, in which case personal data held by Us about our customers will be one of the transferred assets; or
- in relation to selected third parties only, only to the extent that you have consented to such selected third parties notifying you about certain goods or services, which may be if interest to you.
Other than as set out above, and save insofar as is necessary in order for Us to carry out our obligations arising from any contracts entered into between you and Us, We will not share your data with third parties unless We have procured your express consent to do so.
STORING YOUR PERSONAL DATA
We take appropriate measures to ensure that any personal data are kept secure, including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. Where We process payment transactions, these will be encrypted using SSL technology. Where We have given you (or where you have chosen) a password which enables you to access certain parts of the App, you are responsible for keeping this password confidential.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where We are legally required to do so.
Unfortunately, the transmission of information via the internet is not completely secure. Although We will do our best to protect your personal data, We cannot guarantee the security of your data transmitted to the Website; any transmission is at your own risk. Once We have received your information, We will use strict procedures and security features to try to prevent unauthorised access.
Keeping your personal data up to date
If your personal details change you may update them by accessing the Profile page in the App.
If you have any questions about how We use data collected which relates to you, please contact Us by using the Contact Us form on the Jifflr.com website.
How long we keep your personal data
We will hold the data set out above for a reasonably time having regard to the nature of the personal data and the purpose for which it was collected. In particular:
- If you have a Jifflr Account, we will hold your name and email address, company name (if applicable), and your contact details at the company (if applicable) associated to your Jifflr Account until you delete your Jifflr Account in the Profile page of the App.
- If you are a Consumer, any other personal data associated to your Jifflr Account (such as your age, location and any preferences) will be retained indefinitely. On deletion of your Jifflr Account, such personal data will be aggregated and anonymised.
- Where we hold your personal data in connection with the negotiation or performance of a contract with one of our customers or suppliers (including Consumers), we will hold your data, and in particular any communications between you and us in relation to the negotiation or performance of the contract by either party for so long as that contract is in force and for a period of at least 7 years from the date of our last correspondence with you in relation to the same.
Where we store your personal data
All information We hold about you is stored on our secure servers within the EEA.
The data that We collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for Us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your orders, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing.
Such countries outside the EEA may not have the same data protection laws as the United Kingdom and EEA. Whilst the European Commission has not given a formal decision that these countries provide an adequate level of data protection similar to those which apply in the United Kingdom and EEA, any transfer of your personal data will be subject to an agreement that with such third parties that we will have reviewed, approved and/or negotiated with these services to ensure that any transfer of your personal data will have an adequate level of protection.
If you would like further information please contact our Data Protection Officer using the Contact Us form on the Jifflr Website.
We will not otherwise transfer your personal data outside of the United Kingdom or the EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
- access to your personal data and to certain other supplementary information that this Policy is already designed to address
- require Us to correct any mistakes in your information which We hold that is not accessible for You to update directly
- require the erasure of personal data concerning you in certain situations
- receive the personal data concerning you which you have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
- object at any time to processing of personal data concerning you for direct marketing
- object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
- object in certain other situations to our continued processing of your personal data
- otherwise restrict our processing of your personal data in certain circumstances
- claim compensation for damages caused by our breach of any data protection laws.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
- Contact Our Data Protection Officer using the Contact Us form on the Jifflr.com website
- let Us have enough information to identify you e.g. your login email address
- let Us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
- let Us know the information to which your request relates
HOW TO COMPLAIN
We hope that We can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.
We may collect information about your mobile phone, computer or other device from which you use our mobile App or access Our Website including where available your IP address, operating system and browser type, for systems administration, data security, App functionality and to report aggregate anonymised information to third parties affiliates. This is statistical data about our users’ App use and browsing actions and patterns, and does not identify any individual. We may, however, use such information in conjunction with the data We have about you in order to record your usage of our services.
A cookie is a small file of letters and numbers that We store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
The cookies We use include:
- “Analytical” They help Us to improve the way our Website works by allowing Us to recognise and count the number of visitors and to see how visitors move around the Website when they are using it. They help to ensure that users are finding what they are looking for easily.
- “Strictly necessary” cookies. They enable you to log into secure areas of our Website, use a shopping cart or make use of e-billing services etc. These cookies are required for the operation of our Website.
- “Functionality” cookies. These enable Us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region). They are used to recognise you when you return to our Website.
- “Targeting” cookies. These cookies are used to make our Website, any offers e-mailed to you and the campaigns displayed on it more relevant to you. We may also share this information with third parties for this purpose. These cookies record your visit to our Website, the pages you have visited and the links you have followed to our affiliates websites.
All questions, comments and requests regarding this Privacy and Cookies Policy should be addressed to Our Data Protection Officer using the Contact Us form on the Jifflr.com website.