PRIVACY POLICY

Introduction

Welcome to the privacy policy of Ion Industries Ltd (company number 10323679) (we, us, ION, Javelin) for Site https://www.askjavelin.com (Site).

We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our Site (regardless of where you visit it from), tell you about your privacy rights and how the law protects you.

Please  use the Glossary to understand the meaning of some of the terms used in this privacy policy.  This privacy policy forms our agreement with you. Capitalised terms not defined in this privacy policy shall have the meaning given to them in our Terms of Service or in the General Data Protection Regulation (EU) 2016/679 (EU GDPR) or the retained version of the EU GDPR as it applies in the UK from 1 January 2021 (UK GDPR).

1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how we collect, process, store and share data that can identify you (End User)  through your use of the Site, including any data you may provide through this Site when you sign up to our newsletter or purchase a product or service or take part in a competition, for instance.

This Site is not intended for children and we do not knowingly collect data relating to children.

We reserve the right to publish different or bespoke versions of this global privacy policy, to suit particular products, sites or apps.  It is therefore important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

This privacy policy primarily applies to our Javelin services, and to your use of our platform and software applications hosted or made available by us, wherever and however you access them (Service). To a lesser extent, this privacy policy applies to any visitor to our Sites (where the level of interaction with your data and the amount of data processing will be much less).

Data Controller

We are the controller and responsible for your personal data.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about it, including any requests to exercise your legal rights, please contact our DPO using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:

Full name of legal entity:  Ion Industries Ltd

Email address:  support@ionhq.co.uk

Postal address:  2 Esh Plaza, Newcastle upon Tyne, NE139BA

Telephone number: 0191 466 1231

We are registered with the Information Commissioner (No. ZA467430).  You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance. The ICO can be contacted at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF or by telephone on 0303 123 1113 or 01625 545 745.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on the date set out at the end of this document. We reserve the right to add to or change the terms of this privacy policy in the same way that we need from time to time to vary our Terms of Service to keep up to date with evolving data protection laws or to take account of changes to our Service. You are therefore advised to keep abreast of this privacy policy through whatever medium, site or device you access it.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This Site may include links to third-party Sites, plug-ins and applications.Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party Sites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy policy of every Site you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been completely removed (anonymous data).

We may collect, use, store, share and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, and job title.‍
• Contact Data includes email address and telephone numbers‍
• Technical Data includes internet protocol (IP) address, your 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 you use to access this Site‍
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses‍
• Usage Data includes information about how you use our Site, products and services‍
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific site feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories[1] of Personal Data about you (this includes 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.

If you fail to provide personal data

Where we need to collect personal data 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 goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

• ‍Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • apply for our products or services
  • create an account on our Site
  • subscribe to our service or publications
  • request marketing to be sent to you
  • enter a competition, promotion or survey
  • give us feedback or contact us‍
• Automated technologies or interactions. As you interact with our Site, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other Sites employing our cookies. Please see our Cookie Policy for further details.
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
  • Technical Data from the following parties:
    • (i) analytics providers such as Google based outside the UK
    • (ii) advertising networks based inside or outside the UK
    • (iii) search information providers based inside or outside the UK
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services
• ‍Identity and Contact Data from data brokers or aggregators based inside and outside the UK‍
• Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK; and

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data 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 obligation.

Please go to the Glossary to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data, although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground on which we are relying in order to process your personal data where more than one ground has been set out in the table below.

‍Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications if you have requested information or purchased goods or services from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out of marketing

You can ask us or third parties to stop sending you marketing messages at any time by logging into the Privacy Centre on the Site and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at anytime at support@ionhq.co.uk.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes (for example, relating to order confirmations for a product/service warranty registration, appointment reminders, updates to our Terms of Service or checking that your contact details are correct.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when Sites set or access cookies. If you disable or refuse cookies, please note that some parts of this Site may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get 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 data 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 data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above, for example, service providers who help us to deliver the Service to you, such as technology companies who may provide elements of the Service functionality.

• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• Any third parties listed in (or implicit from) the table under the heading Purposes for which we will use your personal data above.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

We do not transfer your personal data outside the UK.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

Once we have received your information, we will use procedures and security features to try to prevent unauthorised and unlawful access and processing, as well as accidental loss, destruction or damage. We use encryption technology to protect data that you submit to us online in order to reduce the risk of your data being intercepted by unauthorised persons during transmission.

We deploy a range of technical and organisational measures including physical, electronic, and procedural safeguards to protect information we process and maintain.

Please be aware that the transmission of information via the internet or mobile networks is not completely secure; we cannot guarantee the security of your data transmitted to or from us and any transmission is at your own risk. We may include links to third-party sites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party sites and are not responsible for their content or their privacy statements and strongly encourage you to read their privacy policies in detail.

We have put in place procedures to deal with any suspected personal data breach.  In the event there is an occasion in the future where there is an unauthorised use or breach with respect to data, we shall comply with GDPR expectations and timelines (including a 72 hour investigation and reporting window) in order to mitigate the risk to any individuals affected and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law, we have to keep basic information about our customers (including Contact,Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances, you can ask us to delete your data: see Your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Where we store your data

We process and store the data described in this privacy policy inside the UK. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy, GDPR and UK GDPR at all times. 

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. See below under the heading Your legal rights for more detailed information about this.

If you wish to exercise any of the rights set out above, please Contact Us.

No fee usually required

You will not have to pay a fee to access your personal data (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 could 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 month. Occasionally it could 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.

10. Glossary

LAWFUL BASIS

Legitimate Interests means the interests of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience.We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data 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.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

Other companies in our group, acting as joint controllers or processors and provide IT and system administration services and undertake leadership reporting.

External Third Parties

• Service providers acting as processors who provide IT and system administration services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom]who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

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 data 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 data 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 data where there is no good reason for us continuing to process it. 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 interests (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 data 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 data in the following scenarios:

• If you want us to establish the data's accuracy
• Where our use of the data is unlawful but you do not want us to erase it
• 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
• 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 data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information for which you initially provided consent for us to use or where we used the information to perform a contract with you.

Direct Marketing.

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving the marketing.

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

Objecting to processing of your personal data for direct marketing purposes You also have the absolute right to object at any time to the processing of your personal data for direct marketing purposes (see Opting Out Of Marketing in section 4 for details of how to object to receiving direct marketing communications).

Withdrawal of your consent

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

This privacy policy was last updated:  1 March 2024