John Mills Ltd (ICO registration Z5266132) (“JML”) takes your privacy very seriously. This Privacy Notice is intended to set out your rights and answer any queries you may have about your personal data. If you need more information, please contact:
John Mills Ltd
610 Chiswick High Road
London, W4 5RU
UK Customers – 0800 781 7831
Republic of Ireland Customers – 041 978 0003
Our data protection policy and procedures have been developed in line with the requirements of the 1995 European Union Data Protection Directive (Directive 95/46/EC) and the General Data Protection Regulation (in force from 25 May 2018) and applicable national law.
1 WHAT INFORMATION DO WE COLLECT?
We collect and process personal data about you when you interact with us and our services.
The personal data we process includes:
- Your name
- Your username and password
- Your home or work address, email address and/or telephone number
- Information related to the browser or device you use to access our website;
- Internet browser and operating system;
- and/or any other information you provide
2 WHAT IS THE SOURCE OF THIS INFORMATION?
The source of this information is either information you have given us directly or is gathered during your browsing history.
3 HOW DO WE USE THIS INFORMATION AND WHAT IS THE LEGAL BASIS FOR THIS USE?
We process the personal data listed in paragraph 1 above for the following purposes:
- as required to establish and fulfill a contract with you, for example, if you make a purchase from us or enter into an agreement to provide or receive services. This may include verifying your identity, taking payments, communicating with you, providing customer services and arranging the delivery or other provision of products or services. We require this information in order to enter into a contract with you and are unable to do so without it;
- to comply with applicable law and regulation;
- in accordance with our legitimate interests in protecting JMLs legitimate business interests and legal rights, including but not limited to, use in connection with legal claims, compliance, regulatory and investigative purposes (including disclosure of such information in connection with legal process or litigation);
- with your express consent to respond to any comments or complaints we may receive from you, and/or in accordance with our legitimate interests including to investigate any complaints received from you or from others, about our website or our products or services;
- we may use information you provide to personalise (i) our communications to you; (ii) our website; and (iii) products or services for you, in accordance with our legitimate interests;
- to monitor use of our websites and online services. We may use your information to help us check, improve and protect our products, content, services and websites, both online and offline, in accordance with our legitimate interests;
- if you provide a credit or debit card, we may also use third parties (such as POS payment providers) to check the validity of the sort code, account number and card number you submit in order to prevent fraud, in accordance with our legitimate interests and those of third parties;
- we may monitor any customer account to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law and our legitimate interests;
- in circumstances where you contact us by telephone, calls may be recorded for quality, training and security purposes, in accordance with our legitimate interests; and
- we may use your information to invite you to take part in market research or surveys.
- Where we rely on consent to use your information, you have the right to withdraw that consent at any time.
4 WITH WHOM AND WHERE WILL WE SHARE YOUR PERSONAL DATA?
Personal data may be shared with government authorities and / or law enforcement officials if required for the purposes above, if mandated by law or if needed for the legal protection of our legitimate interests in compliance with applicable laws.
Personal data may also be shared with third party service providers (processors) who will process it on behalf of JML for the purposes above. We will only use processors who have demonstrated sufficient guarantees of compliance.
Such third parties include, but are not limited to:
- our professional advisors such as our auditors and external legal and financial advisors;
- marketing and communications agencies where they have agreed to process your personal data in line with this Privacy Notice;
- market research companies;
- our suppliers, business partners and sub-contractors; and/or
- search engine, web analytics and social media platforms.
In the event that our business or any part of it is sold or integrated with another business, your details will be disclosed to our advisers and those of any prospective purchaser and will be passed to the new owners of the business.
We promise we’ll never share your details with anyone else.
5 HOW LONG WILL YOU KEEP MY PERSONAL DATA?
We will not keep your personal information for any purpose for longer than is necessary and will only retain the personal information that is necessary in relation to the purpose. We are also required to retain certain information as required by law or for as long as is reasonably necessary to meet regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions.
Personal information is kept indefinitely.
6 WHERE IS MY DATA STORED?
The personal data that we collect from you may be transferred to, and stored 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, in which case the third country’s data protection laws will have been approved as adequate by the European Commission or other applicable safeguards are in place. Further information may be obtained from our Privacy Team.
7 WHAT ARE MY RIGHTS IN RELATION TO MY PERSONAL DATA?
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
The right to be informed
We will inform you of what personal information we collect and how this is used. This privacy notice is how we inform you of this information.
We will inform you of any changes to the way we process your data.
The right of access
You have the right, with some exceptions and qualifications, to ask us to provide a copy of any personal data we hold about you.
The right of rectification
If the information we hold about you is inaccurate or incomplete, you can notify us and ask us to correct or supplement it.
The right to erasure
In certain circumstances you can ask for the data we hold about you to be erased from our records.
The right to restrict processing
If you have a complaint about how we have handled your personal data, you may be able to ask us to restrict how we use your personal data while your complaint is resolved. In some circumstances you can ask us to erase your personal data:
a) by withdrawing your consent for us to use it;
b) if it is no longer necessary for us to use your personal data;
c) if you object to the use of your personal data and we don’t have a good reason to continue to use it; or
d) if we haven’t handled your personal data in accordance with our obligations.
The right to data portability
You have the right to have the data we hold about you transferred to another organisation.
The right to object
You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data, clicking the unsubscribe button on any communication we have sent to you or by contacting us.
Rights in relation to automated decision making and profiling
Where you have provided your data to us and it is processed by automated means, you may be able to request that we provide it to you in a structured, machine readable format.
8 WHERE CAN I FIND MORE INFORMATION ABOUT JML’S HANDLING OF MY DATA?
Should you have any queries regarding this privacy notice, about JML’s processing of your personal data or wish to exercise your rights you can contact JML’s Data Protection Representative using this email address:
If you are not happy with our response, you can contact the Information Commissioner’s Office:
Cheshire, SK9 5AF
UK Calls – 0303 123 1113
Outside UK – +44 1625 545 700