Privacy Policy - As of July 2022 (updated 15/3/2023)

Table of contents

1. I. Identity and contact details of the data controller
   II. Contact details of the data protection officer
   III. General information on data processing
   IV. Rights of the data subject
   V. Provision of website and creation of log files
   VI. Use of cookies
   VII. Contact via Email
   VIII. Corporate web profiles on social networks
   IX. Use of corporate profiles in professionally oriented networks
   X. Hosting

I. Identity and contact details of the data controller

The data controller responsible in accordance with the purposes of the UK General Data Protection Regulation (UK GDPR) and other data protection regulations is:

Just Digital Limited
Kingfisher Way
Huntingdon PE29 6FN
United Kingdom
01480 825000
justask@justdigitaluk.com
justdigitaluk.com

II. Contact details of the data protection officer

The designated data protection officer is:
DataCo International UK Limited
Suite 1, 7th Floor, 50 Broadway
London, SW1H 0BL
United Kingdom
+44 20 3695 6452
www.dataguard.co.uk

III. General information on data processing

1. Scope of processing personal data

In general, we only process the personal data of our users to the extent necessary to provide a functioning website with our content and services. The regular processing of personal data only takes place with the consent of the user. Exceptions include cases where prior consent cannot be technically obtained and where the processing of the data is permitted by law.

2. Legal basis for data processing

Where consent is appropriate for processing personal data, Art. 6 (1) (a) UK GDPR serves as the legal basis to obtain the consent of the data subject for the processing of their data.

As for the processing of personal data required for the performance of a contract of which the data subject is party, Art. 6 (1) (b) UK GDPR serves as the legal basis. This also applies to processing operations required to carry out pre-contractual activities.

When it is necessary to process personal data in order to fulfil a legal obligation to which our company is subject, Art. 6 (1) (c) UK GDPR serves as the legal basis.

If vital interests of the data subject or another natural person require the processing of personal data, Art. 6 (1) (d) UK GDPR serves as the legal basis.

If the processing of data is necessary to safeguard the legitimate interests of our company or that of a third party, and the fundamental rights and freedoms of the data subject do not outweigh the interest of the former, Art. 6 (1) (f) UK GDPR will serve as the legal basis for the processing of data.

3. Data erasure and storage duration

The personal data of the data subject will be erased or restricted as soon as the purpose of its storage has been accomplished. Additional storage may occur if this is provided for by international regulations, laws, or other relevant regulations to which the data controller is subject. Restriction or erasure of the data also takes place when the storage period stipulated by the aforementioned standards expires, unless there is a need to prolong the storage of the data for the purpose of concluding or fulfilling the respective contract.

IV. Rights of the data subject

When your personal data is processed, you are a data subject within the meaning of the UK GDPR and have the following rights:

1. Right to information

You may request that the data controller confirm whether your personal data is processed by them.

If such processing occurs, you can request the following information from the data controller:

• The purpose for which the personal data is processed.
• The categories of personal data being processed.
• The recipients or categories of recipients to whom the personal data have been or will be disclosed.
• The planned duration of the storage of your personal data or, if specific information is not available, criteria for determining the duration of storage.
• The existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning you or to object to such processing.
• The existence of the right to lodge a complaint with a supervisory authority.
• Where personal data are not collected from you any available information as to their source.
• The existence of automated decision-making including profiling under Article 22 (1) and Article 22 (4) UK GDPR and, in certain cases, meaningful information about the data processing system involved, and the scope and intended result of such processing on the data subject.

You have the right to request information on whether your personal data will be transmitted to a third country or an international organization. In this context, you can then request for the appropriate guarantees in accordance with Art. 46 UK GDPR in connection with the transfer.

2. Right to rectification

You have a right to rectification and/or modification of the data if your processed personal data is incorrect or incomplete. The data controller must correct the data without delay.

3. Right to the restriction of processing

You may request the restriction of the processing of your personal data under the following conditions:

• If you challenge the accuracy of your personal data for a period that enables the data controller to verify the accuracy of your personal data.
• The processing is unlawful, and you oppose the erasure of the personal data and instead request the restriction of their use instead.
• The data controller or its representative no longer need the personal data for the purpose of processing, but you need it to assert, exercise or defend legal claims; or
• If you have objected to the processing pursuant to Art. 21 (1) UK GDPR and it is not yet certain whether the legitimate interests of the data controller override your interests.

If the processing of personal data concerning you has been restricted, this data may - with the exception of data storage - only be used with your consent or for the purpose of asserting, exercising or defending legal claims or protecting the rights of another natural or legal person or for reasons of important public interest of the UK.

If the processing has been restricted according to the aforementioned conditions, you will be informed by the data controller before the restriction is lifted.

4. Right to erasure

a. Obligation to erase
If you request that the data controller delete your personal data without undue delay, they are required to do so immediately if one of the following applies:

• Personal data concerning you is no longer necessary for the purposes for which they were collected or processed.
• You withdraw your consent on which the processing is based pursuant to Art. 6 (1) (a) and Art. 9 (2) (a) UK GDPR and where there is no other legal basis for processing the data.
• According to Art. 21 (1) UK GDPR you object to the processing of the data and there are no longer overriding legitimate grounds for processing, or you object pursuant to Art. 21 (2) UK GDPR.
• Your personal data has been processed unlawfully.
• The personal data must be deleted to comply with a legal obligation in the UK to which the data controller is subject.
• Your personal data was collected in relation to information society services offered pursuant to Art. 8 (1) UK GDPR.

b. Information to third parties
If the data controller has made your personal data public and must delete the data pursuant to Art. 17 (1) UK GDPR, they shall take appropriate measures, including technical means, to inform data processors who process the personal data, that a request has been made to delete all links to such personal data or copies or replications of the personal data, taking into account available technology and implementation costs to execute the process.

c. Exceptions
The right to deletion does not exist if the processing is necessary

• to exercise the right to freedom of speech and information.
• to fulfil a legal obligation required by the law of the UK to which the data controller is subject, or to perform a task of public interest or in the exercise of public authority delegated to the representative.
• reasons of public interest in the field of public health pursuant to Art. 9 (2) (h) and Art. 9 (2) (i) and Art. 9 (3) UK GDPR.
• for archival purposes of public interest, scientific or historical research purposes or for statistical purposes pursuant to Art. 89 (1) UK GDPR, to the extent that the law referred to in subparagraph (a) is likely to render impossible or seriously affect the achievement of the objectives of that processing, or
• to enforce, exercise or defend legal claims.

5. Right to data portability

You have the right to receive your personal data given to the data controller in a structured and machine-readable format. In addition, you have the right to transfer this data to another person without hindrance by the data controller who was initially given the data, if:

• the processing is based on consent in accordance with Art. 6 (1) (a) UK GDPR or Art. 9 (2) (a) UK GDPR or performance of a contract in accordance with Art. 6 (1) (b) UK GDPR and
• the processing is done by automated means.

In exercising this right, you also have the right to transmit your personal data directly from one person to another, insofar as this is technically feasible. Freedoms and rights of other persons shall not be affected.

The right to data portability does not apply to the processing of personal data necessary for the performance of a task in the public interest or in the exercise of official authority delegated to the data controller.

6. Right to object

For reasons that arise from your particular situation, you have, at any time, the right to object to the processing of your personal data pursuant to Art. 6 (1) (e) or 6 (1) (f) UK GDPR; this also applies to profiling based on these provisions.

The data controller will no longer process the personal data concerning you unless he can demonstrate compelling legitimate grounds for processing that outweigh your interests, rights and freedoms, or the processing is for the purpose of enforcing, exercising or defending legal claims.

If the personal data relating to you are processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data in regard to such advertising; this also applies to profiling associated with direct marketing.

If you object to processing for direct marketing purposes, your personal data will no longer be processed for these purposes.

7. Right to withdraw the data protection consent declaration

You have the right to withdraw your consent at any time. The withdrawal of consent does not affect the legality of the processing carried out on the basis of the consent until the withdrawal.

8. Automated decisions on a case-by-case basis, including profiling

You have the right to not be subject to a decision based solely on automated processing - including profiling - that will have a legal effect or substantially affect you in a similar manner.

This does not apply if the decision:

• is required for the conclusion or execution of a contract between you and the data controller,
• is permitted by the UK legislation to which the data controller is subject, and where such legislation contains appropriate measures to safeguard your rights and freedoms and legitimate interests, or
• is based on your explicit consent.

However, these decisions must not be based on special categories of personal data under Art. 9 (1) UK GDPR, unless Art. 9 (2) (a) or Art. 9 (2) (b) UK GDPR applies and reasonable measures have been taken to protect your rights and freedoms as well as your legitimate interests.

Right to complain to a supervisory authority

If you are located in the United Kingdom, you shall have the right to complain to the ICO if you are unhappy with how we have used you data and/or believe that the processing of the personal data concerning you violates the applicable law. The ICO's address: Information Commissioner's Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF Helpline number: 0303 123 1113 ICO website: https://www.ico.org.uk

The supervisory authority to which the complaint has been submitted shall inform the complainant of the status and results of the complaint, including the possibility of a judicial remedy pursuant to Art. 78 UK GDPR.

V. Provision of website and creation of log files

1. Description and scope of data processing

Each time our website is accessed, our system automatically collects data and relevant information from the computer system of the calling device.

The following data is collected:

• Browser type and version used
• The user's operating system
• The user's internet service provider
• The IP address of the user
• Date and time of access
• Web pages from which the user's system accessed our website
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• Web pages accessed by the user's system through our website

This data is stored in the log files of our system. This data is not stored together with other personal data of the user.

2. Purpose of data processing

The temporary storage of the IP address by the system is necessary for the delivery of the website to the computer of the user. For this purpose, the user's IP address must be kept for the duration of the session.

The storage in logfiles is done to ensure the functionality of the website. The data is also used to optimize the website and to ensure the security of our IT systems. An analysis of the data for marketing purposes does not take place.

For the aforementioned purposes, our legitimate interest lies in the processing of data in compliance with Art. 6 (1) (f) UK GDPR.

3. Legal basis for data processing

The legal basis for the temporary storage of data and logfiles is Art. 6 (1) (f) UK GDPR.

Duration of storage

The data will be deleted as soon as it is no longer necessary for the purpose of its collection. The session is complete when the collection of data for the provision of the website is accomplished.

If the data is stored in log files, this is the case after seven days at the latest. Storage beyond this is possible. In this case, the IP addresses of the users are deleted or alienated so that an assignment of the calling client is not possible.

Objection and removal

The collection of data for the provision of the website as well as the storage of data in log files are essential for the operation of the website. Therefore, the user may not object to the aforementioned processes.

VI. Use of cookies

1. Description and scope of data processing

Please refer to our Cookie Policy.

2. Purpose of data processing

Please refer to our Cookie Policy.

3. Legal basis for data processing

The legal basis for the processing of personal data using non-technical cookies is Art. 6 (1) (a) UK GDPR.

The legal basis for the processing of personal data using technical cookies is Art. 6 (1) (f) UK GDPR.

4. Duration of storage and possibility of objection and removal

Cookies are stored on the user's device and transmitted to our site by the user. Therefore, you as a user also have full control over the use of cookies. You can deactivate or restrict the transmission of cookies by changing the settings in your Internet browser. Cookies that have already been saved can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, it is possible that not all functions of the website can be used to their full extent.

If you use the Safari browser version 12.1 or higher, cookies will be automatically deleted after seven days. This also applies to opt-out cookies, which are used to prevent the use of tracking mechanisms.

VII. Contact via email

1. Scope of data processing

You can contact us via the email address provided on our website. In this case the personal data of the user transmitted with the email will be stored.

The data will be used exclusively for the processing of the conversation.

2. Purpose of data processing

If you contact us via email, this also constitutes the necessary legitimate interest in the processing of the data.

3. Legal basis for data processing

The legal basis for the processing of data transmitted while sending an email is Art. 6 (1) (f) UK GDPR. If the purpose of the email contact is to conclude a contract, the additional legal basis for the processing is Art. 6 (1) (b) UK GDPR.

4. Duration of storage

The data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected. For personal data sent by email, this is the case when the respective conversation with the user has ended. The conversation ends when it can be concluded from the circumstances that the matter in question has been conclusively resolved.

5. Objection and removal

The user has the possibility to withdraw consent to the processing of their personal data at any time. If the user contacts us by email to justask@justdigitaluk.com, they can object to the storage of their personal data at any time.

In this case, all personal data stored while establishing contact will be deleted.

VIII. Corporate web profiles on social networks

Instagram: Instagram, Part of Facebook Ireland Ltd., 4 Grand Canal Square Grand Canal Harbour, Dublin 2 Ireland

On our company profile we provide information and offer Instagram users the possibility of communication. If you carry out an action on our Instagram company profile (e.g. comments, contributions, likes etc.), you may make personal data (e.g. clear name or photo of your user profile) public. However, as we generally or to a large extent have no influence on the processing of your personal data by Instagram, we cannot make any binding statements regarding the purpose and scope of the processing of your data. Our corporate profile in social networks is used for communication and information exchange with (potential) customers.

Publications on the company profile can contain the following content:

• Information about products
• Information about services
• Customer contact
• Job listings

Every user is free to publish personal data.

The legal basis for data processing is Art. 6 (1) (a) UK GDPR.

The data generated on the company profile are not stored in our own systems.

You can object at any time to the processing of your personal data that we collect within the framework of your use of our Instagram corporate web profile and assert your rights as a data subject mentioned under IV. of this privacy policy. Please send us an informal email to justask@justdigitaluk.com

For further information on the processing of your personal data by Instagram and the corresponding objection options, please click here:

Instagram: https://help.instagram.com/help/instagram/519522125107875/?locale=en_GB

Pinterest: Pinterest Europe Ltd., Palmerston House, 2nd Floor, Fenian Street, Dublin 2, Ireland

On our company profile we provide information and offer Pinterest users the possibility of communication. If you carry out an action on our Pinterest company profile (e.g. comments, contributions, likes etc.), you may make personal data (e.g. clear name or photo of your user profile) public. However, as we generally or to a large extent have no influence on the processing of your personal data by Pinterest, we cannot make any binding statements regarding the purpose and scope of the processing of your data. Our corporate profile in social networks is used for communication and information exchange with (potential) customers.

Publications on the company profile can contain the following content:

• Information about products
• Information about services
• Customer contact
• Job listings

Every user is free to publish personal data.

The legal basis for data processing is Art. 6 (1) (a) UK GDPR.

The data generated on the company profile are not stored in our own systems.

You can object at any time to the processing of your personal data that we collect within the framework of your use of our Pinterest corporate web profile and assert your rights as a data subject mentioned under IV. of this privacy policy. Please send us an informal email to justask@justdigitaluk.com

For further information on the processing of your personal data by Pinterest and the corresponding objection options, please click here:

Pinterest: https://policy.pinterest.com/en-gb/privacy-policy

Twitter: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, Ireland

On our company profile we provide information and offer Twitter users the possibility of communication. If you carry out an action on our Twitter company profile (e.g. comments, contributions, likes etc.), you may make personal data (e.g. clear name or photo of your user profile) public. However, as we generally or to a large extent have no influence on the processing of your personal data by Twitter, we cannot make any binding statements regarding the purpose and scope of the processing of your data. Our corporate profile in social networks is used for communication and information exchange with (potential) customers.

Publications on the company profile can contain the following content:

• Information about products
• Information about services
• Customer contact
• Job listings

Every user is free to publish personal data.

The legal basis for data processing is Art. 6 (1) (a) UK GDPR.

The data generated on the company profile are not stored in our own systems.

You can object at any time to the processing of your personal data that we collect within the framework of your use of our Twitter corporate web profile and assert your rights as a data subject mentioned under IV. of this privacy policy. Please send us an informal email to justask@justdigitaluk.com

For further information on the processing of your personal data by Twitter and the corresponding objection options, please click here:

Twitter: https://twitter.com/en/privacy

YouTube: YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, United States

On our company profile we provide information and offer YouTube users the possibility of communication. If you carry out an action on our YouTube company profile (e.g. comments, contributions, likes etc.), you may make personal data (e.g. clear name or photo of your user profile) public. However, as we generally or to a large extent have no influence on the processing of your personal data by YouTube, we cannot make any binding statements regarding the purpose and scope of the processing of your data. Our corporate profile in social networks is used for communication and information exchange with (potential) customers.

Publications on the company profile can contain the following content:

• Information about products
• Information about services
• Customer contact
• Job listings

Every user is free to publish personal data.

The legal basis for data processing is Art. 6 (1) (a) UK GDPR.

The data generated on the company profile are not stored in our own systems.

You can object at any time to the processing of your personal data that we collect within the framework of your use of our YouTube corporate web profile and assert your rights as a data subject mentioned under IV. of this privacy policy. Please send us an informal email to justask@justdigitaluk.com

For further information on the processing of your personal data by YouTube and the
corresponding objection options, please click here:

YouTube: https://policies.google.com/privacy?gl=DE&hl=en

IX. Use of corporate profiles in professionally oriented networks

1. Scope of data processing

We use corporate profiles on professionally oriented networks. We maintain a corporate presence on the following professionally oriented networks:

LinkedIn: LinkedIn, Unlimited Company Wilton Place, Dublin 2, Ireland

On our site we provide information and offer users the possibility of communication. The corporate profile is used for job applications, information, public relations, and active sourcing.

We do not have any information on the processing of your personal data by the companies jointly responsible for the corporate profile. Further information can be found in the privacy policy of:

LinkedIn: https://www.linkedin.com/legal/privacy-policy

If you carry out an action on our company profile (e.g. comments, contributions, likes etc.), you may make personal data (e.g. clear name or photo of your user profile) public.

2. Legal basis for data processing

The legal basis for the processing of your data in connection with the use of our corporate web profile is Art. 6 (1) (f) UK GDPR.

3. Purpose of the data processing

Our corporate web profile serves to inform users about our services. Every user is free to publish personal data.

4. Duration of storage

We store your activities and personal data published via our corporate web profile until you withdraw your consent. In addition, we comply with the statutory retention periods.

5. Objection and removal

You can object at any time to the processing of your personal data which we collect within the scope of your use of our corporate web profile and assert your rights as a data subject mentioned under IV. of this privacy policy. Please send us an informal email to justask@justdigitaluk.com

You can find further information on objection and removal options here:

LinkedIn: https://www.linkedin.com/legal/privacy-policy

X. Hosting

The website is hosted on servers of service providers commissioned by us. Our service providers are

Shopify International Limited

1 Bartholomew Lane,

London,

England,

EC2N 2AX

The servers automatically collect and store information in so-called server log files, which your browser automatically transmits when you visit the website. The stored information is:

• Browser type and version
• Used operating system
• Referrer URL
• Hostname of the accessing computer
• Time and date of the server request
• IP address of the user's device

This data will not be merged with other data sources. The data is collected on the basis of Art. 6 (1) (f) UK GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimization of his website - and server log files are therefore recorded.

The server of the website is geographically located in the United Kingdom.

This privacy policy has been created with the assistance of DataGuard.