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JINNIE FEMME – PRIVACY NOTICE

Jinnie Femme (“The Company”, “we” or “us”) are committed to protecting your privacy, including online, and in the transparent use of any information you give us. This Privacy Notice (the “Policy”) (together with our Website Usage Terms & Conditions at https://www.jinnie-femme.eu/website-usage-terms-and-conditions/ ; our Cookie Policy at https://www.jinnie-femme.eu/cookie-policy/  and any other documents referred to on these) sets out what information we may hold about you if you provide it, and how that data will be used. No information will be shared more widely than is set out below unless it is required by law.

Please read this policy carefully to understand our practices regarding your personal data and how we will treat it.

Who we are

Jinnie Femme will be what is known as the “data controller” of the personal data you provide to us.  You may contact us by email at [email protected] or via our website at https://www.jinnie-femme.eu/contact-us/

Information we collect from you

Unless otherwise agreed with you, we will only collect basic personal data about you which does not include any special information about you (often known as “sensitive personal data”).

This information does, however, includes the likes of your name, date of birth, gender, email address and debit or credit card details (if paying by card).

Our website is not intended for children and we do not knowingly collect or process personal information relating to individuals under 16 years of age.

By submitting your personal information to us, you are confirming that the information you are giving is correct and relates to you.

How we use your information

We need to know basic personal data in order to register you on our website; to provide and manage your account and your access to our website and to manage payments for our services.  If you do not provide this information, then we will be unable to provide the services you have requested from us.

We will also use your basic personal data to keep in contact with you and to answer any questions or queries you may have submitted.

We may share your information with third party service providers in connection with providing our services to you where we have your permission or such disclosure is required by law.  However, when we use third party service providers, we disclose only the personal data that is necessary to deliver the service and we require them to keep your information secure and not to use it for their own direct marketing purposes.

We will not collect any personal data from you that we do not need in order to provide and oversee the services we have agreed to provide you with.

We will not share any of your personal information with any third parties for any purposes, unless there is a legal obligation for us to provide them with this.

How and where we store or transfer your information

All information you provide to us is stored on our secure servers in Malta.  Please be aware, however, that your information will also be transferred to and stored on cloud-based systems whose servers are located in countries outside the European Economic Area (EEA).

We have taken all reasonable steps to ensure that your information is treated securely.  We have ensured that third party service providers who handle or may store data outside the EEA, for example through data servers or relays, have appropriate safeguards in place to ensure equivalent levels of data protection or that they adhere to the EU-US Privacy Shield.

What we would also like to do with your information

From time to time, we may wish to send you suggestions and recommendations about goods and services that may interest you by email or for market research purposes.  However, we will not contact you for marketing purposes unless you have given your prior consent.

Please note that if you consent to being sent our marketing information via email, your data will be shared with and you will be contacted by the third party organisation SendGrid (https://sendgrid.com/) who is Privacy Shield certified and who will make this contact on our behalf.

You can change your marketing preferences or unsubscribe at any time by contacting us by email to [email protected]

How long we keep your information

We only keep your personal information for as long as you are a subscriber of Jinnie Femme, unless we believe in good faith that the law or other regulation requires us to preserve it (for example, because of our obligations to tax authorities or in connection with any anticipated litigation).  Please be aware that we will keep your basic personal data (name, email, payment details) for as long as the tax authorities require us to retain it, after which time it will be destroyed if it is no longer required for the legitimate business need for which it was obtained or for other legal or regulatory purposes.

If you consent to marketing, the information we use for this purpose will be kept with us until you notify us that you no longer wish to receive this information.

Any other information you provide to us is deleted from our secure servers and any other third party service providers’ servers where it might be stored once we have completed our contractual obligations towards you.

Links to / from other websites

Our website contains links to other websites run by other organisations. This privacy policy applies only to our website‚ so we encourage you to read the privacy statements on the other websites you visit. We cannot be responsible for the privacy policies and practices of other sites even if you access them using links from our website.

In addition, if you linked to our website from a third party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party site and recommend that you check the policy of that third party site.

Security precautions in place to protect the loss, misuse or alteration of your information

We are committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, disclosure, alteration, unauthorised access or destruction. We do this by having in place a range of appropriate technical and organisational measures including but not limited to, secure hosting of our website, virus and malware protections, using an SSL certificate, compliance with PCI vulnerability standards, securing access to our site via a Website Application Firewall (WAF) and procedures in place to deal with any suspected data breach.

Any sensitive information (such as credit or debit card details) is encrypted and protected, so that it cannot be read as the information travels over the internet.  Additionally, our choice of payment provider allows us to never hold your card details on our website.

Non-sensitive personal details (your email address etc.) are transmitted normally over the Internet, and this can never be guaranteed to be 100% secure. Although we will do our best to protect your personal data, we cannot guarantee the security of any information you transmit to us; any transmission is at your own risk.

Once we have received your information, we will use strict procedures and security features to ensure its security on our systems and try to prevent any unauthorised access, alteration, disclosure or destruction.

Visitors to our website

When you visit https://www.jinnie-femme.eu/ we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the site; where visitors have come to the website from and the pages they visited. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.

Cookies

Cookies are small text files that are placed on your computer or other device when you access the internet. Our site uses cookies to distinguish you from other users of our site and allow your preferences to be recorded when visiting the website.  This helps us to provide you with a better user experience when you browse our website and also allows us to improve our site.

Cookies may also be used to track your return visits and to remember your preferences when interacting with the website again.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you may modify your browser setting to decline cookies if you prefer.  Without cookies enabled, we can’t guarantee that the website and your experience whilst visiting are as we intended them to be.

For more information on cookies, please refer to our Cookie Policy at https://www.jinnie-femme.eu/cookie-policy/

What are your rights?

Under certain circumstances, you have rights under the General Data Protection Regulation (GDPR) and applicable data protection laws in relation to your personal information. You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it, for example where you consider that we do not need it any longer for the purposes for which we originally collected it as explained to you in this Policy; where you have withdrawn your consent to our using it and we had relied on that consent according to this Policy; where you consider that we cannot show a ‘legitimate interest’ in continuing to process it and we have relied on that legitimate interest to process it as explained to you in this Policy. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below); where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the information’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

To contact us about any of your rights, please email: [email protected]

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one (1) month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

If you are not satisfied with our response or you believe we are processing your personal data not in accordance with the law, you can complain to the Office of the Information and Data Protection Commissioner (IDPC) https://idpc.org.mt/en/Pages/Home.aspx

Changes to our privacy notice

We may make changes to this Policy any time. Any changes we may make will be posted on this page.

Any questions or comments about this Policy can be sent to [email protected]

This Privacy Notice was last updated on 11 March 2019.

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