2. DATA PROTECTION – WHAT YOU SHOULD KNOW WHEN USING OUR WEBSITES
Customer Relationship Centre contact details: If you’d like to get in touch on a website related query, Just Broadcast Customer, you can do this by visiting this web page:
2. WHAT INFORMATION WE COLLECT FROM OUR WEBSITE AND WHAT INFORMATION WE RECEIVE FROM OTHER SOURCES.
Our websites serve primarily as information portals to help you better understand our products and services. We also, however, offer a number of website functions that collect information you provide to us when you ask to be kept informed, to be added to lists, events or experiences, or when you buy goods or request free trials.
The main ways we collect information from our websites:
When you visit, or use and interact with our websites, for example to take steps to request or use online-available services, where you find out more about an event or experience or where you request any other information;
When you enter into personalised web areas and use our websites as a way to engage with us, as a place where you can ask for personalised reminders, receive information about our products, and/or request other information to be notified to you;
When you provide information to or interact with any of Just Broadcast pages;
When you contact us (via contact details made available on our websites), or send us correspondence.
Information may also be received from other sources. For example:
Vehicle related data from independent third party sources:.
Third party support services: For the performance of our website services and to allow us to maintain appropriate records and to support ongoing queries, we may receive data about you or your website activities from our group companies or third party providers (e.g. to confirm website payments, to track website order deliveries, to support website maintenance). More information on our categories of suppliers is provided at Section 4 (Who we share personal data with) below.
Device data: Our websites automatically take certain device information in order to optimise your website experience (for example, allowing our website to automatically adapt screen size as appropriate for the device you are using to browse the website). This data also supports our website analytics. More information on automated data collection and cookies can be found in our Cookies policy, available via this link.
Marketing data: Your contact details, marketing preferences or other information may be shared with us by retailers or other third parties partners, where there is appropriate notice and in compliance with applicable data protection laws. You have the right to ask us not to use your personal data for marketing purposes. Please see your data protection rights at Section 7 (Your data protection rights) below for further information on these.
Public sources of data: : We may use public sources of data, for example, to support website functionality (e.g. to support authenticate or fraud checks), and/or to maintain the accuracy of the data we hold.
More about the personal data Just Broadcast may receive direct…
We receive information you provide to us in your use of our websites, for example, when you add information to online forms or to data fields on our websites. We may also receive information from you by other online means, for example, if you comment on our social media pages. This will be the information that is visible to you, and may include your name, occupation, contact information (e.g. email, postal address and phone/mobile number), credit card/payment details, and general information you decide to share such as your experience with Just Broadcast products and services.
3. HOW WE USE YOUR PERSONAL INFORMATION.
We use personal information to manage and meet service and information requests, to understand service, and website use, and to make our products and services (including our web services) as effective as possible.
Maintaining and supporting website use
Where you use an online service governed by our provided online Terms and Conditions (for example, purchases from the online stores, or entering into prize draws and competitions), we and our permitted third parties will process data in a number of ways that support our website services. For example, this may include the following activities: identity confirmation, any fraud and authentication checks, service delivery, administration of prize draws, competitions, membership offers, surveys and other promotional activities, any applicable payment processes and collections activities, customer support and any ongoing service communications. We may also seek to improve our services, using user experiences to strengthen our internal processes. For example, we let you know when you call us (our customer care numbers are available from our websites) that our calls may be recorded to support training, audit and quality purposes.
Legitimate Interests in running effective website services
Where personal data is required for entering into a contract, we will identify to you where information is mandatory. The consequences of not providing this information may include being unable to proceed with the requested service.
Managing your requests
We will process data in managing your requests made on or via our websites (e.g. where you request a free trail, sign up to ‘keep me informed’ or add your details into any other website data form or data field). We will also process data in providing and maintaining personalised website experiences.
Enhancing website experience
Where we pre-fill website data fields to enhance and streamline your online experience. Legitimate Interests in enhancing, simplifying and streamlining website experiences.
Other marketing activities will happen assessed on the Legitimate Interests ground. e.g. where we tailor marketing communications or send targeted marketing messages via post or social media and other third party platforms; and in providing existing customers with information about similar products and services. In order to improve the services we offer via our website, we may ask you to participate in research from time to time. It is entirely up to you whether you choose to do so.
We will use profiling and carry out research and analytics activities to inform our marketing strategies, to create a better understanding of our customers and visitors; to support our website advertising, and to better improve the website information, functionality and the services we provide.
Note: Where we collect your personal data with consent, you may withdraw your consent for us to use your information in any of these ways at any time. Please see Withdrawing your consent in Section 7 below for further details. (This right doesn’t effect the lawfulness of processing that was based on that consent before its withdrawal.)
Records maintenance and general administration
To maintain our records, administer and maintain our websites, support your queries and any other internal operations and administrative purposes (for example, this will include troubleshooting, testing, supporting our audit requirements and in responding to any enquiries you may make, including any data protection rights you raise).
Network and information security
To maintain our network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access. And to maintain appropriate server locations (for example, we may work with third parties to support appropriate use of cloud services).
Corporate acquisitions and disposals
Any data processed as is necessary in the context of corporate acquisitions or disposals.
Management of legal and regulatory requirements
To manage legal and regulatory requests and requirements, meet or defend legal rights or for the prevention/detection of crime, (including where required to assist HMRC, law enforcement agencies such as the Police or any other public authority or criminal investigation body, or for the safeguarding of national security).
In the event we communicate to you an urgent safety or product recall notices.
4. WHO WE SHARE PERSONAL DATA WITH.
We may share your personal data with:
Those third parties who need to handle it so we can provide to you the products, services you have signed up to or requested, for example, to provide marketing and advertising support services and for optimised website services.
With our network of retailers (together our “retail network”), so as to be able to fulfil requests for goods, services, etc, and for assessment and training, to be able to enhance the quality of the services you obtain when interacting with our Retail Network.
Third parties in the event we sell or buy any business or assets.
If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or requests, or in order to enforce these terms or to investigate actual or suspected breaches.
5. INFORMATION ABOUT INTERNATIONAL DATA TRANSFERS.
The Just Broadcast website use servers which are hosted in the USA. However we may share website personal data with suppliers or group companies located outside of the USA where this is necessary for the purposes described above. Where this happens, we apply safeguards to add to the data protections that apply to those data transfers. This includes an assessment of the adequacy of the third country in question, use of European Commission approved model contract terms where appropriate, and assessment of Privacy Shield certification for US located entities where applicable.
Where Just Broadcast chooses to share personal data with a third party located outside the USA, the following factors are assessed to support adequate transfer of this data:
Use of measures like European Commission approved measures to support adequate transfers of personal data. To manage data protection compliance with these transfers, we will use European Commission approved data transfer mechanisms such as use of model contractual clauses approved by the Commission. We will also assess where applicable where a supplier is able to demonstrate to us they have Binding Corporate Rules. (Binding Corporate Rules is a GDPR – recognised Data Protection mechanism to ensure adequate personal data transfers). We may work with suppliers who are able to demonstrate to us they are Privacy Shield certified.
6. HOW LONG WE HOLD PERSONAL DATA FOR.
We’ll keep your personal data for as long as we need it to provide the products and services you’ve signed up to. We may also keep it to comply with our legal obligations, respond to queries and resolve any disputes, to meet our legitimate interests and to enforce our rights.
The criteria we use to determine storage periods include the following: Information we have told you about storage periods on our website or in website terms and conditions. We will also use criteria such as applicable contractual provisions that are in force, legal statutory limitation periods, applicable regulatory requirements and industry standards.
7. YOUR DATA PROTECTION RIGHTS.
You have rights in connection with your personal data, including: to withdraw consent where you have given it, to be informed and have access to your personal data, to correct or complete inaccurate data, and in certain circumstances to restrict, request erasure, object to processing, or request portability of your personal data to another organisation.
We try to ensure that we deliver the best levels of customer service. If you do need or want to get in touch with us for any reason regarding your data protection rights, please get in touch using either of the email addresses below, and add into the subject header that it relates to your data protection rights. These Customer care email addresses are the appropriate contact details for our Data Protection Officer where queries are data protection related:
If you are not satisfied, you also have the right to complain to the Information Commissioner’s Office.
To learn more about these data protection rights, see below.
More about my data subject rights…
If you have given us consent to process your personal data, including for electronic marketing communications, you have the right to withdraw that consent at any time. Just use the unsubscribe options presented, for example, these are present in the email marketing communications sent by us.
You can ask for access to the personal data we hold about you, object to the processing, request that we correct any mistakes, restrict or stop processing or delete it. If you do ask us to delete or stop processing it, we will not always be required to do so. If this is the case, we will explain why.
In certain circumstances you can ask us to provide you with your personal data in a usable electronic format and transmit it to a third party (right to data portability). This right only applies in certain circumstances. Where it does not apply, we will explain why.
8. KEEPING YOUR INFORMATION SECURE
We require all of our services providers to have appropriate measures in place to maintain the security of your information.
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 over the internet; any transmission is at your own risk. Your information will be kept in a secure environment protected by a combination of physical and technical measures such as encryption technologies or authentication systems to prevent any loss, misuse, alteration, disclosure, destruction, theft or unauthorised access.