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Privacy Policy

We are Just Between Us, and when you access or use this website (www.justbetweenus.co.uk), or our mobile application, our blog, our branded pages on social media services, or any of the other sites, services, features, content or applications we offer in the United Kingdom (collectively, the "Services"), or register an account with us, purchase our products or contact us from anywhere, this Privacy Policy will tell you how Just Between Us Ltd, and its subsidiaries, collect, use and share the personally identifiable information ("Personal Data") we collect about you.

We urge you to read this Privacy Policy in full, but wanted to mention a few things upfront: • When you use the Services, even if you don't have an account with us or purchase our products, we may receive some Personal Data from you through your web browser, including your IP address, the type of device you're using and other similar information, and use it to understand where and how our Services are being used, among other purposes described in this Privacy Policy. If you do set up an account with us or purchase our products, we'll collect other Personal Data from you, and use it to verify your identity, fulfill your orders, market to you and for other purposes.

• In this Privacy Policy, we describe the various purposes for which we use your Personal Data, as well as the legal bases supporting those purposes. As you'll read below, the legal basis on which we rely for a given use of your Personal Data may be contractual necessity (i.e., where we need to use your Personal Data to complete a contract with you), consent freely given to us (which you can withdraw at any time) and/or certain legitimate business of ours or of others, but only where we have determined that those interests are not overridden by your own interests, rights and freedoms.

• You have certain rights regarding the Personal Data we collect from you.

• As noted in our Terms of Service, we do not knowingly collect or solicit Personal Data from anyone under the age of 18. If you are under the age of 18, please do not access or use the Services, or attempt to send us any Personal Data. If we learn that we have collected Personal Data from an individual under the age of 18, we will delete that information as quickly as possible.

• Our subsidiary based in the United Kingdom, is the primary data controller of your information.

• This Privacy Policy does not apply to the practices of third parties that we do not own or control, including, but not limited to, any third party websites, services, products or applications (each a "Third Party Service") that you elect to access and may interact with during your use of the Services, or to individuals that we do not manage or employ. We take steps to ensure that we only work with Third Party Services that share our respect for your privacy, but we cannot take responsibility for the content, products, services or privacy policies of those Third Party Services. We encourage you to carefully review the privacy policies of any Third Party Services you access.


PERSONAL DATA YOU PROVIDE US


REGISTRATION INFORMATION

We collect your email address and the password you enter when you register for an account with us, and we use them to verify your identity, based on our legitimate business interests in keeping your account secure and preventing fraudulent transactions.

We also use your email address:

• to send you confirmations, notifications and other information regarding your account, your purchases, as may be necessary to complete our contractual obligations to you. Without your email address, we wouldn't be able to provide you this information in a timely and effective manner;

• to send you information and materials about us, our products and our services that we think may be of interest to you, based on our legitimate business interest in marketing to individuals who have indicated an interest in our products and services. You can choose not to receive such information when you register an account with us, and you can decide to stop receiving this information at any time by emailing us at customercare@justbetweenus.co.uk

You may be able to register for or access the Services using Third Party Services, such as Facebook. If you've registered for an account with us through Facebook or another Third Party Service, we will collect and receive your login credentials for such Third Party Service in connection with providing you with the Services if you expressly provide us with such information. We will only use such login information for the purposes described above. In any case, we urge you to review your privacy settings on any Third Party Service and their associated privacy policies to understand more about disclosures of information from your applicable Third Party Services.

INFORMATION YOU SHARE WITH US IN COMMUNICATIONS OR INTERACTIONS

When you communicate with us or our customer service representatives, including when you call us, email us or interact with us through the Services, we automatically record that communication, and use that record and the information you provide us in those communications, to address your questions and complaints about us, our products and our services, and to train our customer service representatives, based on our legitimate business interest in providing quality customer service. We also use the information you provide us to address your requests regarding your account and purchase orders, as may be necessary to complete a contract with you. Without this information, we may not be able to address these requests.

When you respond to a survey we provide you, or leave a written comment or review on the Services about us, our products or the Services, we record that survey response, comment or review, and use the information you provide us in them, in order to assess and/or address your responses, comments or reviews regarding us, our products or our services, based on our legitimate business interest in providing quality products and customer service.

OTHER PERSONAL DATA WE RECEIVE ABOUT YOU

In addition to the information you directly provide us, we automatically receive and record certain information about you when you access or use the Services, or otherwise communicate or interact with us (including through other websites or mobile applications). Additionally, like many e-retailers, we collect certain information about you from third parties, including advertising and analytics companies.

LOCATION INFORMATION

When you access or use the Services, we collect information from your web browser, including your IP address and your device's settings and unique identifiers, and use that information to determine your general location, based on our legitimate business interests in reliably and accurately providing you with Services and information that apply to you, and in learning more about where the Services are being accessed or used.

List of cookies we collect

The table below lists the cookies we collect and what information they store.

COOKIE name COOKIE Description
CART The association with your shopping cart.
CATEGORY_INFO Stores the category info on the page, that allows to display pages more quickly.
COMPARE The items that you have in the Compare Products list.
CURRENCY Your preferred currency
CUSTOMER An encrypted version of your customer id with the store.
CUSTOMER_AUTH An indicator if you are currently logged into the store.
CUSTOMER_INFO An encrypted version of the customer group you belong to.
CUSTOMER_SEGMENT_IDS Stores the Customer Segment ID
EXTERNAL_NO_CACHE A flag, which indicates whether caching is disabled or not.
FRONTEND You sesssion ID on the server.
GUEST-VIEW Allows guests to edit their orders.
LAST_CATEGORY The last category you visited.
LAST_PRODUCT The most recent product you have viewed.
NEWMESSAGE Indicates whether a new message has been received.
NO_CACHE Indicates whether it is allowed to use cache.
PERSISTENT_SHOPPING_CART A link to information about your cart and viewing history if you have asked the site.
POLL The ID of any polls you have recently voted in.
POLLN Information on what polls you have voted on.
RECENTLYCOMPARED The items that you have recently compared.
STF Information on products you have emailed to friends.
STORE The store view or language you have selected.
USER_ALLOWED_SAVE_COOKIE Indicates whether a customer allowed to use cookies.
VIEWED_PRODUCT_IDS The products that you have recently viewed.
WISHLIST An encrypted list of products added to your Wishlist.
WISHLIST_CNT The number of items in your Wishlist.

ADDITIONAL INFORMATION ABOUT INTEREST-BASED ADVERTISEMENTS

We serve advertisements, and also allow third party ad networks, including third party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Services. These advertisements are sometimes targeted to users who fit certain general profile categories or display certain preferences or behaviours (such advertisements, "Interest-Based Ads"). Information for Interest-Based Ads (including Personal Data) may be provided to us by you, as outlined above, as well as derived from the usage patterns of particular users on the Services and/or Third Party Services over time. Such information may be gathered by us or our third party service providers through Cookies, which may include a file known as a "web beacon" from an ad network to you through the Services. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their website, allow them to serve Interest-Based Ads to you when you visit other websites, and also allow them to provide us and our advertisers with anonymized, aggregated auditing, research and reporting about advertisements.

Remember, you can always choose to stop us from collecting your Cookie Information by turning off the Cookie feature on your browser or by ceasing to use the Services. Also, you can opt out of Interest-Based Ads sourced by Google using Google's Ads Settings. For more information on how to make choices about Interest-Based Ads from participating third parties, and to learn how to opt out of receiving them from participating organizations, please visit the European Interactive Digital Advertising Alliance's user information website at http://www.youronlinechoices.eu/.

LINKS AND CONFIRMATIONS

When you open an email or an SMS, MMS or other text message, or a push notification (each, a "Message") sent by us, or click on any links in that Message, we receive a confirmation that you did so (and when), as well as Cookie Information. We also receive confirmation and Cookie Information when you click on any links elsewhere throughout the Services, including on our website and our branded pages on social media. We use the information described in this paragraph to assess the effectiveness of our Messages and associated marketing campaigns, to learn more about the audience for our Messages, and to better understand your preferences, all based on our legitimate business interest in marketing to individuals who may be interested in our services and products. You can stop receiving Messages from us at any time by emailing us at customercare@justbetweenus.co.uk.

Additionally, you should know that when you click on an advertisement for, or link to, a Third Party Service that appears anywhere on the Services, the Third Party Service or its advertiser may receive a confirmation and certain Cookie Information from you for the same purposes listed in the preceding paragraph, based on their own legitimate business interest in marketing to individuals who may be interested in their products and services. Remember, this Privacy Policy does not apply to your access or use of any Third Party Services, and we're not responsible for the content, products, services or privacy policies of those Third Party Services. We encourage you to carefully review the privacy policies of any Third Party Services you access.

INFORMATION FROM ADVERTISING AND ANALYTICS PARTNERS

We work with advertising and analytics companies that provide us with certain information about you, your interactions with us and the Services, and your usage of both the Services and Third Party Services, including your age or birthday, demographic or interest data, Cookie Information, hashed email addresses, unique identifiers assigned to you by our Advertising Partners, as well as pages or content you've viewed, links you've clicked or other actions you've taken on both the Services and on Third Party Services. We use this information in order to enhance our understanding of your interests and preferences, so that we can serve you with Interest-Based Ads and measure their effectiveness, based on our legitimate business interest in marketing to individuals who we think may be interested in our services and products. We sometimes attempt to direct Interest-Based Ads to individuals who fit a certain general category, and as a result of the information our advertising and analytics partners provide us, Interest-Based Ads or other advertisements or recommendations may appear on Third Party Services that you visit.

To collect the information described above, as well as to serve targeted advertisements to you, our advertising and analytics partners sometimes integrate their own Cookies, including web beacons, into the Services and/or into Third Party Services that you visit, as mentioned above. Remember, you can elect not to have these Cookies collect your information on the Services. Also, your browser or device may offer you a "Do Not Track" or "DNT" option, which allows you to signal to operators of Third Party Services (including, without limitation, behavioural advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites; however, we cannot and do not make any promises about how such Third Party Services will react when you set this signal on your browser.

INFORMATION FROM OTHER SERVICE PROVIDERS

In addition to our advertising and analytics partners, we contract with various third party entities in order to operate our business and provide you with the Services and our products. These third parties provide us with various services described throughout this policy, including shipping and logistics, name and address verification, email distribution, market research, fraud prevention, promotions management and payment processing, and may share with us information about you that they have independently developed or acquired (in accordance with their own privacy policies and practices) for those purposes, as may be necessary for us to complete a contract with you or in furtherance of our legitimate business interests.

TRANSACTION DATA

We sometimes request and receive information about your transaction history from our Payment Processor in order to process your purchase order, or to enroll you in discount, rebate and other programs in which you have elected to participate and use it to verify your identity by combining it with information you provide us, based on our legitimate business interest in protecting against fraudulent transactions.

WHO WE SHARE YOUR PERSONAL DATA WITH

We share your Personal Data within our corporate family. We also share your Personal Data with third party vendors, service providers and agents, for the purposes and on the legal bases discussed herein, including:

• with shipping and logistics companies, our Payment Processor and others that we rely on to provide you with the Services or process and fulfill your purchase orders, in each case, as may be necessary to complete a contract with you under our Terms of Service or your purchase; and

• with advertising companies, analytics companies, marketing service providers, fraud detection and prevention service providers, name and address verification service providers, email providers, email verification and suppression service providers, hosting and database service providers, data security service providers, customer relationship management service providers and staff augmentation and contract personnel, in each case, based on various legitimate interests described in this Privacy Policy.

We seek to provide these third party vendors, service providers and agents with only the Personal Data they need to perform their services, and we work with them to help ensure that your privacy is respected and protected. Unless set forth in this Privacy Policy or otherwise communicated to you, these third parties do not have any rights to use your Personal Data beyond what is necessary to provide those services requested by us.

PUBLIC INFORMATION

If you post information or content publicly on or through the Services (including when you submit comments or reviews of our products or Services), or post content publicly elsewhere, including on your social media accounts, that relates to us or the Services, we may receive and share that public information with third parties, based on our legitimate business interest in marketing our products and services.

CHANGE OF OWNERSHIP OR CONTROL

If we are acquired by or merge with another company, go out of business or enter bankruptcy, or sell some or all of our assets, your Personal Data may be sold or transferred in connection with the transaction in question. If such events do take place, this Privacy Policy will continue to apply to your Personal Data.

LAWS AND SAFETY

We also reserve the right to access, read, preserve and disclose your Personal Data as we reasonably believe is necessary to:

• satisfy any applicable law, regulation, legal process or governmental request;

• enforce this Privacy Policy and our Terms of Service, including investigation of potential violations hereof or thereof; or

• protect our rights, property or safety, and those of our users, customers and the public.

However, nothing in this Privacy Policy is intended to limit your rights and remedies regarding your Personal Data, including your right to register a complaint with your local data protection authority.

HOW WE PROTECT YOUR PERSONAL DATA

We seek to protect your Personal Data using appropriate technical and organizational measures, taking into account the nature of the applicable Personal Data and processing activity. For example, all Payment Information regularly collected through the Services is encrypted and maintained using industry standard methods designed to ensure its security against loss or theft, including during transmission to our Payment Processor. However, we cannot and do not guarantee or warrant that such techniques will prevent unauthorized access to Personal Data or other information about you that we collect and store. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of such information at any time.

You can help us prevent unauthorized access to your account with us and your Personal Data by selecting and protecting your password appropriately and limiting access to your device and browser by signing off after you have finished accessing your account.

WHAT YOUR RIGHTS ARE TO YOUR PERSONAL DATA, AND HOW YOU CAN EXERCISE THEM

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request with respect to these rights, you can email customercare@justbetweenus.co.uk. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous, inaccurate or extremely impractical, if it jeopardizes the rights of others or if it is not required by law, but in those circumstances we will still respond to notify you of such a decision. In some cases, we may need you to provide us with additional information, which may include Personal Data, as necessary to verify your identity and the nature of your request.

RIGHT OF ACCESS

• Where permissible, you can request more information about the Personal Data we hold about you and you can request a copy of your Personal Data. If you have an active account with us, you can also access your Personal Data by visiting your account settings on our website.

RIGHT OF RECTIFICATION

• If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such Personal Data. You can also correct some of this Personal Data directly by visiting your account settings on our website.

RIGHT OF ERASURE

• Where permissible, you can request that we erase some or all of your Personal Data from our systems. You can also delete your account with us at any time by emailing us at customercare@justbetweenus.co.uk

RIGHT TO WITHDRAW CONSENT

• If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent to this processing at any time, which you can do by emailing us at customercare@justbetweenus.co.. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.

RIGHT TO OBJECT TO PROCESSING AND TO RESTRICT PROCESSING

• Where permissible, you can let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as marketing to you (to name one example), and you can also ask us to restrict further processing of your Personal Data.

RIGHT OF PORTABILITY

• Where permissible, you can ask for a copy of your Personal Data in a machine-readable format, and you can also request that we transmit the data to another controller where technically feasible.

RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY

• You have the right to lodge a complaint about our practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. Please visit http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm for more information.

OUR PERSONAL DATA RETENTION POLICY

We retain your Personal Data for as long as you have a working account with us, or as otherwise necessary to provide you with the Services. In some cases we retain Personal Data for longer, if doing so is necessary to pursue our legitimate business interests (but only if those interests are not overridden by your own interests, rights and freedoms), comply with our legal obligations, resolve disputes or collect fees owed, conduct audits, or if doing so is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we dispose of your Personal Data securely, but may retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.

As stated above, you can request us to erase some or all of your Personal Data from our systems, and you can delete your account with us at any time, by emailing us at

customercare@justbetweenus.co.uk.

ANY QUESTIONS OR CONCERNS?

If you have any questions or concerns regarding how we collect, use, protect or share your Personal Data, including, for example, about our legitimate business interests or the legitimate business interests of others that we describe above, please send a detailed message to customercare@justbetweenus.co.uk. We will make every effort to resolve your concerns.

EFFECTIVE DATE:

25 May 2018