www.jportnoy.com iscommitted to providing a superior learning experience for everyone we workwith. We know that our users are committed to their success and we are equallycommitted to ensuring that each interaction that someone has with our contentis optimized for maximum educational potential. To enable us to do this,www.jportnoy.com needs to gather and use certain information about individuals.Individuals who wegather information about includes customers, affiliates, business contacts,employees, and other people the organization has a relationship with or mayneed to contact.This policy describeshow this personal data is collected, handled, and stored to meet the company’sdata protection standards — and to comply with the law.
This data protectionpolicy ensures www.jportnoy.com:
The GDPR(General Data Protection Regulation) protection law describes how organizationswho conduct business with individuals or entities located in EU (European Union)nations — including www.jportnoy.com — must collect, handle, and store personalinformation.
These rules applyregardless of whether data is stored electronically, on paper, or in any othermanner.
Tocomply with the law, personal information must be collected and used fairly,stored safely, and not disclosed unlawfully.
The EU GDPR isunderpinned by eight core principles. These state that personal data must:
Every day our businesswill receive, use, and store personal information about our customers, affiliates,partners, and colleagues. It is important that this information is handledlawfully and appropriately, in line with the requirements of the DataProtection Act 2018 and the General Data Protection Regulation (collectivelyreferred to as the ‘Data Protection Requirements’).
We take our dataprotection duties seriously because we respect the trust that is being placedin us to use personal information appropriately and responsibly.
This policy and anyother documents referred to in it, sets out the basis on which we will processany personal data that we collect or process. This policy does not form part ofany employee’s contract of employment and may be amended at any time.
The company as a wholeis responsible for ensuring compliance with the Data Protection Requirementsand with this policy. Any questions about the operation of this policy or anyconcerns that the policy has not been followed should be referred in the firstinstance to the Data Protection Officer.
Personal data isdefined as data, (whether stored electronically or paper based) relating to aliving individual who can be identified directly or indirectly from that data,(or from that data and other information in our possession).
Processing is anyactivity that involves use of personal data. It includes obtaining, recording,or holding the data, organizing, amending, retrieving, using, disclosing,erasing, or destroying it. Processing also includes transferring personal datato third parties under privacy control conditions.
Sensitive personal dataincludes contact info, address, session activity on the platform, IP locationetc. Sensitive personal data can only be processed under strict conditions, andused for express purpose that it was collected for.
Anyoneprocessing personal data, must ensure that data is:
A. Processed fairly,lawfully and in a transparent manner.
The DataProtection Requirements are not intended to prevent the processing of personaldata, but to ensure that it is done fairly and without adversely affecting therights of the individual.
In accordance with theGeneral Data Protection Regulation (GDPR), we will only process personal datawhere it is required for a lawful purpose. The lawful purposes include (amongstothers): whether the individual has given their consent, the processing is necessaryfor performing a contract with the individual, for compliance with a legalobligation, or for the legitimate interest of the business. When sensitivepersonal data is being processed, additional conditions must be met.
We receive and storeinformation about you such as:
Information you provide us: We collectinformation you provide to us which includes: your name, email address, addressor postal code, payment method, and telephone number. We collect thisinformation in a number of ways, including manual entry while you are using ourservice, interact with our customer service, participate in surveys ormarketing promotions, provide reviews or ratings, taste preferences, setpreferences in Your Profile/Account, or otherwise provide information to usthrough our service or elsewhere.
Information wecollect automatically: We collect information regarding you and youruse of our service, your interactions with us and our advertising, as well asinformation regarding your computer or other device used to access our service.
We use the informationwe collect to provide, analyze, administer, enhance, and personalize ourservices and marketing efforts, to process your registration, your orders, yourpayments, and your communication on these and other topics.
Our primary aim isalways to enhance the user experience. We do so in several ways using the datathat we collect, but a few examples are: determining your general platformusage, required action item completions, login details, etc. which then helpsus know what difficulties the you’re facing within the platform, with which canthen use to take action to minimize the effort on your end. We collect otherinformation, such as most visited links on our website, which then help usconclude what content was most watched, enabling us to create additionalcontent geared toward our users’ needs and personal preferences.
In the course of ourbusiness, we may collect and process personal data, which may include data thatwe receive directly from a data subject and data we receive from other sourcesincluding location data, business partners, and subcontractors who worktechnical, payment and delivery services, credit reference agencies, and othercapacities.
We will only processpersonal data for the specific purposes or for any other purposes specificallypermitted by the Data Protection Requirements. We will notify those purposes tothe data subject when we first collect the data or as soon as possiblethereafter.
If we collect personaldata directly from an individual, we will inform them about:
If we receive personaldata about an individual from other sources, we will provide them with thisinformation as soon as possible (in addition to telling them about the categoriesof personal data concerned) but at the latest within One (1) month.
We will also informdata subjects whose personal data we process, that we are the data controllerwith regard to that data and our contact detail regarding data protection actis email protected, and who the Data Protection Compliance Manager/DataProtection Office is.
We will only collectpersonal data to the extent that it is required for the specific purposenotified to the data subject.
We will ensure thatpersonal data we hold is accurate and kept up to date. We will check theaccuracy of any personal data at the point of collection and at regularintervals afterwards. We will take all reasonable steps to destroy or amendinaccurate or out-of-date data.
We will not keeppersonal data longer than necessary for the purpose or purposes for which itwas collected. We will take all reasonable steps to destroy or erase from oursystems, all data which is no longer required.
We will process allpersonal data in line with data subjects’ rights, in particular their right to:
We will takeappropriate security measures against unlawful or unauthorized processing ofpersonal data and against the accidental or unlawful destruction, damage, loss,alteration, or unauthorized disclosure of or access to personal datatransmitted, stored, or otherwise processed.
We will put in placeprocedures and technologies to maintain the security of all personal data fromthe point of the determination of the means for processing and point of datacollection to the point of destruction. Personal data will only be transferredto a data processor if he or she agrees to comply with those procedures andpolicies, or if he or she puts in place adequate measures himself/herself.
We will maintain datasecurity by protecting the confidentiality, integrity, and availability of thepersonal data, defined as follows:
Subject to therequirements above, personal data we hold may also be processed by staffoperating outside the EEA who work for us or for one of our suppliers. Thosestaff may be engaged in, among other things, the fulfilment of contracts withthe data subject, the processing of payment details and the provision ofsupport services.
We may share personaldata we hold with any member of our group, which means our subsidiaries, ourultimate holding company and its subsidiaries.
To these ends, thecompany has a privacy statement setting out how data relating to individuals isused by the company.
Individuals must make aformal request for information we hold about them. Employees who receive arequest should forward it to the data department immediately.
When receivingtelephone inquiries, we will only disclose personal data we hold on our systemsif the following conditions are met:
Our support team willrefer a request to the data processing department or the Data ProtectionCompliance Manager for assistance in difficult situations.
We may modify thisPrivacy Statement at any time, but we will provide prominent advance notice ofany material changes to this Statement, such as posting a notice through theServices, on our websites, or sending you an email, to provide you theopportunity to review the changes and choose whether to continue using theServices.