- About Us
- Information We Collect
- How We Collect Information
- Use and Disclosure of Personal Information
- Data Collected for and by our Users
- Public Information and Third Party Websites
- Third Parties
- Content of Email Campaigns
- Your Distribution Lists
- Safeguarding Your Information
- Retention of Information
- Your Rights
- Access Request
- Right to Rectification
- Right to be Forgotten
- Restriction of Processing
- Data Portability
- Right to Object
- Right to Withdraw Consent
1. About Us
Jumplead ("We") are committed to protecting and respecting your privacy. For the purposes of the
relevant data protection legislation, the “data controller” is Mooloop Limited, incorporated and
registered in England and Wales with company number 05207897 whose registered office is at Park
House, 37 Clarence Street, Leicester, LE1 3RW (trading as Jumplead).
This Policy explains the basis on which we collect Personal Information (defined in Section 2 below) from you and the way in which it will be processed by us when you visit one of our Websites, being jumplead.com, app.jumplead.com, manager.jumplead.com, developer.jumplead.com, as well as any other webpages, mobile applications or interactive features owned or operated by us in which we refer you to this Policy (each a “Website” and together the “Websites”), or when you use the marketing service offered through our Website which allows you to create and manage marketing campaigns (the “Service”).
It is important that you read this Policy together with any other fair processing notice that we issue on specific occasions when we are collecting or processing Personal Information about you. This Policy supplements any other such notices and is not intended to override them.
If you have any questions or comments; if you need to update, remove, or correct any Personal Information we hold, or you have a concern about the way in which we have handled any privacy matter, please use our contact form to send us a message. You may also contact us at email@example.com.
These definitions should help you to understand this Policy:-
- When we say “you,” we are referring either to a Member, the persons using the Service on behalf of the Member, or to any other person who visits our Websites.
- When we say “Member,” we are referring to a person or entity that is registered with us to use the Service.
- A “Distribution List” is a list of your Subscribers and all associated information related to those Subscribers (including, for example, email addresses).
- A “Subscriber” is a person whom you contact, or a person whom you might choose to contact at some point in the future, through the use of our Service. In other words, a Subscriber is anyone on your Distribution List or about whom you have given information to us.
- “Personal Information” means any information that identifies or can be used to identify an individual (e.g. about you or a Subscriber).
We reserve the right to update or otherwise amend this Policy from time to time. All updates and amendments are effective immediately once we have given you notice of the updated or amended Policy (which we may give by any means including, but not limited to, posting a revised version of this Policy on any of our Websites). We encourage you to review this Policy regularly so that you stay informed about any changes that may affect you. This Policy was last updated on [06/04/2018] at [11.58am].
Information We Collect
We may collect, use, store and transfer different kinds of Personal Information, which we have grouped together as follows:
- “Identity Data”, which comprises first name, maiden name, last name, gender, occupation and location.
- “Contact Data”, which comprises address, email address and telephone numbers.
- “Financial Data”, which comprises bank account and payment card details.
- “Transaction Data” which comprises details about payments to and from you and other details of services you have purchased from us in the past.
- “Technical Data” which comprises internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices used to access our Websites.
- “Profile Data” which comprises username and password, purchases or orders made, interests, preferences, feedback and survey responses.
- “Usage Data”, which comprises information about a person who uses our Websites, products, service and other services.
- “Marketing and Communications Data”, which includes preferences in receiving marketing from us and our third parties and communication preferences.
We also collect, use and share “Aggregated Data” such as statistical or demographic data. Aggregated Data may be derived from your Personal Information but does not constitute personal data in law as it does not directly or indirectly reveal your identity. For example, we may aggregate (i.e. combine with information relating to others) your Usage Data to calculate the percentage of users accessing a specific feature of our Website. However, if we combine or connect Aggregated Data with your Personal Information so that it can directly or indirectly identify you, we will treat the combined data as Personal Information which will only be used in accordance with this Policy.
We do not collect any “Special Categories” of Personal Information about you (i.e. details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data), nor do we collect any information about criminal convictions and offences.
Where we need to collect Personal Information by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the Service). In that event, we may have to cancel our agreement with you to provide a product or service, but we will notify you if this is the case at the time.
How We Collect Information
We collect may collect information from you in the following ways:
- Information that you voluntarily provide to us: When you sign up for and use the Service, consult with our customer service team, send us an email, post on our blog, integrate the Service with another website or service (for example, when you choose to connect your website account with the Service), or communicate with us in any way, you are voluntarily giving us information that we collect. That information may include either your or your Subscribers’ name, physical address, email address, IP address, phone number and credit card information, as well as additional details including gender, occupation, location, purchase history, and other demographic information.
- List and email information: When you add a Distribution List or create an email with the Service, we have and may access the data on your Distribution List and the information contained within your email. If a Subscriber chooses to use the ‘forward to a friend’ (“FTF”) link in an email campaign that you run, it will allow the Subscriber to share your email content with individuals not on your Distribution List. When a Subscriber forwards an email to a friend, we do not store your Subscriber’s email address or their friend’s email address, and no one is added to any Distribution List as a result of the FTF. The Member who created the email campaign only sees an aggregate number of times their email campaign was forwarded by a Subscriber and does not have access to the email addresses used to share or receive that forwarded content.
- Information from your use of the Service: We may receive information about how and when you use the Service, store this information in log files or other types of files associated with your account, and link it to other information we collect about you. This information may include, for example, your IP address, time, date, browser used, and actions you have taken within the application. This type of information helps us to improve our Service for both you and for all of our users.
- Web beacons: We use web beacons on our Websites and in our emails. When we send emails to Members, we may track online behaviour such as who opened the emails and who clicked the links. This allows us to measure the performance of our email campaigns and to improve our features for specific segments of Members. To do this, we include single pixel gifs, also called web beacons, in emails we send. Web beacons allow us to collect information about when you open the email, your IP address, your browser or email client type, and other similar details. We also include web beacons in the emails we deliver for you or send to you. We use the data from those web beacons to provide you with the Service, monitor the effectiveness of our marketing, and to create reports about how your email campaign performed and what actions your Subscribers took. Reports are also available to us when we send emails to you, so we may collect and review that information where it is in our legitimate interests or where we have the user’s consent to do so.
- Information from other sources: From time to time we may obtain information about you or your Subscribers from third party sources, including public databases such as Whois, social media platforms such as Twitter, Facebook and LinkedIn, third party data providers such as FullContact Inc (based outside the EU), and our joint advertising partners such as Google and Facebook. We take steps to ensure that such third parties are legally permitted or required to disclose such information to us. Examples of the information we may receive from other sources include: demographic information, device information (such as IP addresses), location, and online behavioural data (such as information about your use of social media websites, page view information and search results and links). We use this information, alone or in combination with other information (including Personal Information) we collect, to enhance our ability to provide relevant marketing and content to you and to develop and provide you with more relevant products features, and services.
- Information from the use of our mobile applications: When you use our mobile applications, we may collect certain information in addition to information described elsewhere in this Policy. For example, we may collect information about the type of device and operating system you use. We may ask you if you want to receive push notifications about activity in your account. If you have opted in to these notifications and no longer want to receive them, you may turn them off through your operating system. We do not ask for, access or track any location-based information from your mobile device at any time while downloading or using our mobile applications or the Service. We may use mobile analytics software in order better to understand how people use our application. We may collect information about how often you use the application and other performance data.
Use and Disclosure of Personal Information
We will only use your Personal Information when the law allows us to. Most commonly, we will use your Personal Information in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
We have set out below a description of all the ways we plan to use any Personal Information, and which of the legal bases we intend to rely on in order to do so. We have also identified what our legitimate interests are where appropriate. We may use and disclose Personal Information only for the following purposes:
- To promote use of our services to you and others. For example, if you give us your Personal Information when you visit our Website and do not sign up for an account in order to use our Service, we may send you an email inviting you to sign up. If you sign up to use our Service and we think you might benefit from using another similar product or service we offer, we may send you an email about that, provided that we have given you the opportunity to opt-out of receiving any such emails at the time you originally gave us your information. This is necessary in order to develop our services and grow our business. You can stop receiving our promotional emails by following the “unsubscribe” instructions included in every email we send.
- To send you informational and promotional content in accordance with your marketing preferences. We will only send you marketing emails where this is in our legitimate interests and we have told you about this, or where you have provided us with your express consent for us to be able to do so. You can stop receiving our promotional emails by following the “unsubscribe” instructions included in every email. Such marketing may include offers, surveys, contests, or other promotions on our Websites or through social media. Participation in our promotions is completely voluntary.
- To bill and collect money owed to us by our Members. This includes sending you emails, invoices, receipts, notices of delinquency, and alerting you if we need a different credit card number. We use third parties for secure credit card transaction processing, and we send billing information to those third parties to process your orders and credit card payments. This is both necessary in order to perform our contract with you, and necessary in order to recover any debts due to us.
- To communicate with our Members about their account and provide customer support (including to send you System Alert messages). For example, we may inform you of temporary or permanent changes to our services, such as planned outages, new features, version updates, releases, abuse warnings, and changes to this Policy. This is necessary in order to perform a contract we have with you, necessary to comply with a legal obligation, and in order to keep our records updated and to study how customers use our products or services.
- To enforce our Terms of Business. This may include developing tools and algorithms that help us prevent violations. This is necessary in order to perform our contract with you and to protect our and our other customer’s business.
- To administer and protect our business and this Website. This includes troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data. This is necessary for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise, and necessary to comply with our legal obligation to protect the rights and safety of our Members and third parties (as well as our own).
- To comply with relevant legal obligations. This includes complying with Court orders and responding to lawful requests made by public authorities or regulators, including in order to meet national security or law enforcement requirements.
- Combined Information. We may combine Personal Information with other information that we collect or obtain about you (such as information we source from our third party partners) to serve you specifically, such as to deliver a product or service according to your preferences or restrictions, or for advertising or targeting purposes in accordance with this Policy. When we combine Personal Information with other information in this way, we treat it as, and apply all of the safeguards in this Policy applicable to, Personal Information.
- To provide, support, and improve the Services we offer. This includes our use of the data that our Members provide us in order to enable our Members to use the Services to communicate with their Subscribers. This also includes, for example, aggregating information from your use of the Services or visit to our Websites and sharing this information with third parties to improve our Service. This might also include sharing your information or the information you provide us about your Subscribers with third parties in order to provide and support our Services or to make certain features of the Service available to you. When we do have to share Personal Information with third parties, we take steps to protect your information by requiring these third parties to enter into a contract with us that requires them to use the Personal Information that we transfer to them in a manner that is consistent with this Policy.
We will only use your Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another lawful reason and that reason is compatible with the original purpose. If you require an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your Personal Information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your Personal Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. We will obtain your express opt-in consent before we share your personal data with any company outside Jumplead for marketing purposes.
We will make sure that we consider and balance any potential impact on you (both positive and negative) and your rights before we process any Personal Information for our legitimate interests. We do not use your Personal Information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Data Collected for and by our Users
When you use our Service, you may import into our system Personal Information which you have collected from your Subscribers or other individuals. We have no direct relationship with your Subscribers or any person other than you, and for that reason, you are responsible for making sure that you have the appropriate permission for us to collect and process information about those individuals in accordance with our Terms of Business.
If you are a Subscriber and no longer want to be contacted by one of our Members, please unsubscribe directly from that Member’s newsletter or contact the Member directly in order to update or delete your data. If you contact us, we may remove or update your information within a reasonable time and after providing notice to the Member of your request.
We will retain Personal Information we process on behalf of our Members for as long as needed to provide our Service or to comply with our legal obligations, resolve disputes, prevent abuse, and enforce our Terms of Business.
Public Information and Third Party Websites
- Blog. We may from time to time publish public blogs on our Websites. Any information that you include in a comment on our blog may be read, collected, and used by anyone. If your Personal Information appears on our blogs and you wish for it to be removed, contact us to let us know. If we are unable to remove your information for any reason, we will tell you why.
- Social media platforms and widgets. Our Websites include social media features, such as the Facebook “Like” button. These features may collect information about your IP address and the pages which you are visiting on our Websites, and they may set a cookie in order to ensure that the feature functions properly. Social media features and widgets are either hosted by a third party or hosted directly on our Websites. We also maintain presences on social media platforms including Facebook, Twitter, LinkedIn and Instagram. Any information, communications, or materials that you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the persons or organisations that provide them.
We require all third parties to respect the security of your Personal Information and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Information for their own purposes and only permit them to process your Personal Information for specified purposes and in accordance with our instructions.
We may disclose Personal Information to the following types of third parties for the purposes described in this Policy:
- Service Providers. Consistent with the uses of Personal Information covered elsewhere within this Policy, we may transfer Personal Information of you or your Subscribers to companies that help us to promote, provide, or support our Service or the services of our Members. For example, if it is necessary to provide you something that you have requested (such as to enable a feature such as Social Profiles), then we may share your or your Subscribers’ Personal Information with a Service Provider for that purpose. Just like the other third parties we work with, these third party Service Providers enter into a contract that requires them to use your Personal Information only for the provision of services to us and in a manner that is consistent with this Policy. Examples of Service Providers include payment processors, hosting services and content delivery services. We may also share your Personal Information with our professional advisers including lawyers, bankers, auditors and insurers based who provide consultancy, banking, legal, insurance and accounting services.
- To transfer your information in the case of a sale, merger, consolidation, liquidation, reorganisation, or acquisition. In that event, any acquirer will be subject to our obligations under this Policy, including your rights as a “data subject”. We will notify you of the change either by sending you an email or posting a notice on our Websites.
Many of our external third parties are based outside the European Economic Area (“EEA”) so their processing of your Personal Information will involve a transfer of data outside the EEA. Whenever we transfer your Personal Information out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Information out of the EEA.
Content of Email Campaigns
When you send an email marketing campaign using the Service, it is transferred from server to server as it crosses the Internet. Along the way, server administrators may be able to read what you send. Email was not built for confidential information. You must not use the Service to send sensitive or confidential information.
Your Distribution Lists
A Distribution List can be created in a number of ways, including by importing contacts such as through csv or directly from your email client. Your Distribution Lists are stored on a secure Jumplead server. We do not, under any circumstances, sell your Distribution Lists. If someone on your Distribution List complains or contacts us, we might then contact that person to deal with their request. Only authorised employees have access to view Distribution Lists. You may export (i.e. download) your Distribution Lists from Jumplead at any time.
We will use and disclose the information in your Distribution Lists only for the reasons discussed in this Policy. We will not use and disclose the information in your Distribution Lists to bill or collect money owed to us, send you system alert messages, communicate with you about your account, or send you informational and promotional content.
Safeguarding Your Information
We take reasonable and appropriate measures to protect Personal Information from loss, misuse and unauthorised access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the Personal Information.
When you make any payment to us, our credit card processing vendor Stripe Payments Europe Ltd uses appropriate security measures to protect your information both during the transaction and after it is complete. If you have any questions about the security of your Personal Information, you may contact us at firstname.lastname@example.org.
Jumplead accounts require a username and password to log in. You must keep your username and password secure, and never disclose it to a third party. Because the information in your Distribution Lists is so sensitive, account passwords are encrypted, which means we cannot see your passwords. Also, we cannot resend forgotten passwords; we will only reset them.
If a security breach causes an unauthorised intrusion into our system that materially affects you or people on your Distribution Lists, then Jumplead will notify you as soon as possible and later report the action we took in response. We will notify you and any applicable regulator of any breach of security where we are legally required to do so.
Retention of Information
How long we store your Personal Information depends upon the type of information we are holding and the purpose for which we need it.
We shall keep your data for the period of time for which you hold an account with us, to enable us to contact you, keep a record of your past purchases and supply you with any new purchases. We shall not keep your Personal Information for any longer than necessary to fulfil our obligations to you or to meet our legitimate business interests or legal requirements, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.
Under certain circumstances, you have the following rights:
- to request that we provide you with a copy of the Personal Information that we hold about you (“Access Request”);
- to request that we rectify any Personal Information that we hold about you (“Right to Rectification”);
- to request that we erase any Personal Information that we hold about you (“Right to be Forgotten”);
- to restrict the level of processing we carry out with your Personal Information (“Restriction of Processing”);
- to obtain from us all Personal Information that we hold about you in a structured, machine readable form, and have this information transmitted to another organisation (“Data Portability”);
- to object to our processing your Personal Information in certain ways (“Right to Object”); and
- to withdraw your consent at any time to our processing of your Personal Information.
Please see the relevant sections below for further details on your rights as a data subject. You can exercise any of the above rights by emailing us at email@example.com. You also have the right to lodge a complaint with the Information Commissioner’s Office if you are unhappy in any way with how we have treated your Personal Information. We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
We shall comply with any request made under this section as soon as possible, and normally within one month from the date of your request. However, if necessary, for example if your request is particularly complex or we receive a number of similar requests, we may extend this period by an additional two months, but we shall notify you if we need to do this.
You will not have to pay a fee to access your Personal Information (or to exercise any of the other rights). However, please note that where we receive requests under this section which are manifestly unfounded or excessive, for example because they are repetitive in nature, we may:
- charge a reasonable fee taking into account the administrative costs of providing the information or taking the action requested; or
- refuse to act on the request.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information 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.
You have the right to request a copy of the Personal Information that we hold about you at any time. Please note that in most circumstances, we shall not make a charge for this. However, we may charge a reasonable fee based on administrative costs for any further copies requested. This enables you to receive a copy of the Personal Information that we hold about you and to check that we are lawfully processing it.
Right to Rectification
You have the right at any time to ask us to rectify any Personal Information that we hold for you which is incorrect or incomplete. This enables you to have corrected any incomplete or inaccurate data we hold about you, though we may need to verify the accuracy of the new Personal Information that you provide to us.
If we have disclosed any incorrect or incomplete Personal Information to any third parties, we shall inform them of any necessary amendments or corrections made to your Personal Information under this section.
Right to be Forgotten
You have the right to ask us to erase the Personal Information that we hold about you in circumstances where:
- it is no longer necessary for us to handle your Personal Information for the purpose for which it was originally collected;
- you have withdrawn your permission for us to hold your Personal Information (where this was the basis on which it was collected or used);
- you object to the processing of the Personal Information and there is no lawful overriding reason for us to continue processing it;
- the Personal Information was unlawfully processed; or
- we have to erase your Personal Information in order to comply with a legal obligation.
Please 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.
Restriction of Processing
You can ask us to restrict how we use your Personal Information in the following circumstances:
- where you believe that the Personal Information we hold about you is inaccurate, you can ask that we refrain from using your Personal Information until we can verify the accuracy of it;
- where we have unlawfully processed your Personal Information, you can ask that we restrict our usage of it rather than erase it completely;
- where we no longer need to hold your Personal Information, but you wish us to retain your it for the purpose of establishing, exercising or defending a legal claim; or
- you have objected to our use of your Personal Information but we need to verify whether we have overriding legitimate grounds to use it.
You have the right to obtain from us all Personal Information which you have provided to us which concerns you in a structured, commonly used and machine-readable form, provided that such data was processed based on your consent, or for the purpose of a contract between us and the processing was carried out by automated means. 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.
This will allow you to move, copy or transfer Personal Information easily from one IT environment to another. Alternatively, we can transmit such data directly to another organisation.
Please note that we shall not be able to comply with a data portability request if this will affect the rights and freedoms of others.
Right to Object
You have the right to object, on grounds relating to your particular situation, to our processing of your Personal Information where we are doing this for the performance of a task carried out in the public interest (which we shall have told you about, if applicable), or where we are carrying out processing for the purposes of legitimate interests pursued by us.
You also have the right at any time to ask us not to process your Personal Information for direct marketing or profiling purposes (to the extent that such profiling is related to such direct marketing). We shall have informed you before the time we obtained your Personal Information whether we intend to process your Personal Information for this purpose, or if we intend to disclose your information to any third party for such purposes.
If we process your Personal Information for automatic decision making or profiling purposes (i.e. to analyse or predict your personal preferences and purchase behaviour, and such profiling is automated) we shall tell you about this beforehand (either in this Policy or otherwise), and will only do this where this is a necessary condition of entering into a contract between you and us, or where you have given us your explicit consent to do this.
Right to Withdraw Consent
Where you have given us your consent to our processing of any of your Personal Information, you have the right to withdraw your consent at any time, for example if you no longer wish us to share your information with third parties for marketing purposes (where you have previously consented to this). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
In addition to any other way we make available to you the ability to withdraw your consent, you may also withdraw your consent at any time by contacting us at firstname.lastname@example.org.