17 Aug 2020
We respect your privacy and are committed to protecting your personal data. This privacy notice will inform you as to how Switchplane Ltd collects, processes and looks after your personal data when you access Julia or download the Julia mobile app and use our services. It will also tell you about your privacy rights and how the law protects you.
Switchplane Ltd of 24 Broad Road, Eastbourne, East Sussex, BN20 9QU, UK, is the controller and responsible for your personal data (collectively referred to as "we", "us" or "our" in this privacy notice). If you have any questions about this privacy notice, including any requests to exercise your legal rights, please email us at firstname.lastname@example.org.
Personal data, or personal information, means any information about an individual from which that person can be identified either directly or indirectly.
We may collect, use, store and transfer different kinds of personal data to include:
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 provide our services to you. In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
Julia is not intended for use by children and we do not knowingly collect or use personal information relating to children.
We use different methods to collect data from you, including the following:
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:
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.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending 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 on the details above.
When we process any special categories of information i.e. information revealing racial or ethnic origin, religious or philosophical beliefs; genetic data or health data, we must have a further lawful basis for the processing. This may include:
If we process any information relating to your criminal convictions or offences, we will only do so in compliance with data protection legislation. Typically we rely on one of the following lawful bases:
We have set out below a description of all the ways we plan to use your personal data:
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. 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.
We may use your data to form a view on the products and services. You will receive marketing communications from us if you have requested information from us and you have not opted out of receiving that marketing.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of you staying with us or using our services or other transactions.
As part of the services we provide to you, we may have to share your personal data with third parties such as:
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.
We may use external third parties who are based outside the UK and the European Economic Area (EEA) and their processing of your personal data will involve a transfer of data outside the UK and EEA.
Whenever we transfer your personal data 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 unless an exemption applies under Article 49 GDPR:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK and EEA.
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.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. This is usually 6 years.
Our Data Retention Policy is available to view upon request.
Julia may include links to third-party websites, 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 necessarily control these third-party websites and are not responsible for their privacy statements. When you leave Julia, we encourage you to read the privacy notice of every website you visit.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You are entitled to:
We try to respond to all legitimate requests within one month. Occasionally it may 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.
If you wish to exercise any of the rights set out above, please contact us. Our contact details are at the top of this page.
If you have any queries or concerns about the way we process your personal data then please contact us. We hope that we can resolve any concerns for you, but if you wish to take your complaint further you can contact the Information Commissioners Office (ICO) and further information can be found on their website www.ico.org.uk.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive. Cookies may store your IP address and user-agent (operating system and browser) and geographical location.
We use the following cookies:
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
You can also choose to opt-out of Google Analytics using this Google tool: https://tools.google.com/dlpage/gaoptout/
Except for essential cookies, all cookies will expire after 12 months (if not earlier).