BACKGROUND:

Just Average Jen understands that your privacy is important to you and that you care about how your personal data is used. I respect and value the privacy of everyone who visits this website, www.justaveragejen.com (“My Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with my obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is deemed to occur upon your first use of my site. If you do not accept and agree with this Privacy Policy, you must stop using My Site immediately.

1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

“Account”means an account required to access and/or use certain areas and features of My Site;
“Cookie”means a small text file placed on your computer or device by My Site when you visit certain parts of My Site and/or when you use certain features of My Site. Details of the Cookies used by My Site are set out in Part 14, below; and
“Cookie Law”means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

2. Information About [Us] OR [Me]

My Site is owned and operated by Jennifer Mellor, a Sole Trader registered in England.

Registered Address: 15 Hilcote Drive, NG21 9AT, UK.

VAT Number Not Applicable

Data Protection Officer: Jennifer Mellor.

Email address: jen@justaveragejen.com.

Telephone number: 07377971240.

Postal Address: 15 Hilcote Drive, NG21 9AT, UK.

3. What Does This Policy Cover?

This Privacy Policy applies only to your use of My Site. My Site may contain links to other websites. Please note that I have no control over how your data is collected, stored, or used by other websites and I advise you to check the privacy policies of any such websites before providing any data to them.

4. What is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

5. What Are My Rights?

Under the GDPR, you have the following rights, which I will always work to uphold

a) The right to be informed about my collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact me to find out more or to ask any questions using the details in Part 15.

b) The right to access the personal data I hold about you. Part 13 will tell you how to do this.

c) The right to have your personal data rectified if any of your personal data held by me is inaccurate or incomplete. Please contact me using the details in Part 15 to find out more.

d) The right to be forgotten, i.e. the right to ask me to delete or otherwise dispose of any of your personal data that I hold. Please contact me using the details in Part 15 to find out more.

e) The right to restrict (i.e. prevent) the processing of your personal data.

f) The right to object to me using your personal data for a particular purpose or purposes.

g) The right to data portability. This means that, if you have provided personal data to me directly, I am using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask me for a copy of that personal data to re-use with another service or business in many cases.

h) Rights relating to automated decision-making and profiling. I do not use your personal data in this way.

For more information about my use of your personal data or exercising your rights as outlined above, please contact me using the details provided in Part 15.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about my use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

6. What Data Do We Collect?

Depending upon your use of My Site, I may collect some or all of the following personal  data (please also see Part 14 on my use of Cookies and similar technologies and my Cookie Policy):

  • Name;
  • Address;
  • Email address;
  • Telephone number;
  • Payment information;
  • Information about your preferences and interests;
  • IP address;
  • Web browser type and version;
  • Operating system;
  • A list of URLs starting with a referring site, your activity on my Site, and the site you exit to;

7. How Do You Use My Personal Data?

Under the GDPR, I must always have a lawful basis for using personal data. This may be because the data is necessary for my performance of a contract with you, because you have consented to my use of your personal data, or because it is in my legitimate business interests to use it. Your personal data may be used for the following purposes

  • Supplying my products to you. Your personal details are required in order for me to enter into a contract with you.
  • Communicating with you. This may include responding to emails or replying to comments you leave on my site.
  • Supplying you with information by email that you have opted-in to (you may unsubscribe or opt-out at any time by emailing me at jen@justaveragejen.com).
  • Analysing your use of my Site and gathering feedback to enable me to continually improve My Site and your user experience.

With your permission and/or where permitted by law, I may also use your personal data for marketing purposes, which may include contacting you by email or text message with information, news, and offers on my products and services or updates of my latest articles. You will not be sent any unlawful marketing or spam. I will always work to fully protect your rights and comply with my obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt out.

Third Parties (including but not limited to HIBS100) whose content appears on My Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that I do not control the activities of such third parties, nor the data that they collect and use themselves, and I advise you to check the privacy policies of any such third parties.

8. How Long Will You Keep My Personal Data?

I will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

  • The Life of this website

9. How and Where Do You Store or Transfer My Personal Data?

I will only store or transfer your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the GDPR or to equivalent standards by law.

10. Do You Share My Personal Data?

I may sometimes contract with the following third parties to supply certain products and services. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that I hold.

  • Gleam competition app – When entering giveaways
  • Rafflecopter – When entering giveaways
  • Brands that supply prizes for giveaways will only receive winners’ details unless otherwise stated in the entry of the giveaway.

When any of your personal data is required by a third party, as described above, I will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, my obligations, and the third party’s obligations under the law, as described above in Part 9.

If any personal data is transferred outside of the EEA, I will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 9.

In some limited circumstances, I may be legally required to share certain personal data, which might include yours, if I am involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

11. How Can I Control My Personal Data?

11.1       In addition to your rights under the GDPR, set out in Part 5, when you submit personal data via My Site, you may be given options to restrict my use of your personal data. In particular, I aim to give you strong controls on my use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from me which you may do by unsubscribing using the links provided in my emails, at the point of providing your details and by managing your Account).

11.2       You may also wish to sign up for one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you from receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receive.

12. Can I Withhold Information?

You may access My Site without providing any personal data at all.

You may restrict my use of Cookies. For more information, see Part 14 and my Cookie Policy.

13. How Can I Access My Personal Data?

If you want to know what personal data I have about you, you can ask me for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover my administrative costs in responding.

I will respond to your subject access request within 28 days and, in any case, not more than one month of receiving it. Normally, I aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date I receive your request. You will be kept fully informed of my progress.

14. How Do You Use Cookies?

My Site uses analytics services provided by Google and Jetpack, which uses Cookies.

Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling me to better understand how people use My Site.

For more details, please refer to My Cookie Policy.

15. How Do I Contact You?

To contact me about anything to do with your personal data and data protection, including making a subject access request, please use the following details:

Email address: jen@justaveragejen.com.

Telephone number: 07377971240.

Postal Address: 15 Hilcote Drive, NG21 9AT.

16. Changes to this Privacy Policy

I may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if I change my business in a way that affects personal data protection.

Any changes will be immediately posted on My Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of My Site following the alterations. I recommend that you check this page regularly to keep up-to-date.

What we collect

We may collect the following information:

contact information including email address
demographic information such as zip code, preferences and interests
other information relevant to customer surveys and/or offers
What we do with the information we gather

We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:

We may use the information to improve our products and services.
We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided.
From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone, fax or mail. We may use the information to customise the website according to your interests.
Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

How we use cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

Advertising

Some of our advertisers occasionally serve you cookies as well. We do not have control over cookies placed by advertisers. We may use advertising service vendors to help present advertisements on the website, one of which is Mediavine. These vendors may use cookies, web beacons, or similar technologies to serve you advertisements tailored to interests you have shown by browsing on this and other sites you have visited, to determine whether you have seen a particular advertisement before and to avoid sending you duplicate advertisements. In doing so, these vendors may collect non-personal data such as your browser type, your operating system, Web pages visited, time of visits, content viewed, ads viewed, and other clickstream data. The use of cookies, web beacons, or similar technologies by these advertising service vendors is subject to their own privacy policies, not ours, and Service Provider disclaims all liability in connection therewith.

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Controlling your personal information

You may choose to restrict the collection or use of your personal information in the following ways:

whenever you are asked to fill in a form on the website, look for the box that you can click to indicate that you do not want the information to be used by anybody for direct marketing purposes if you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us.

We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.

Display Ads

The Website uses Mediavine to manage all third-party advertising on the Website. Mediavine serves content and advertisements when you visit the Website, which may use cookies. Mediavine may collect IP addresses and locations to serve personalized ads.  If you would like more information about this practice and to know your choices to opt in or opt out of this data collection, please visit http://www.networkadvertising.org/managing/opt_out.asp.

Mediavine Programmatic Advertising (Ver 1.1)

The Website works with Mediavine to manage third-party interest-based advertising appearing on the Website. Mediavine serves content and advertisements when you visit the Website, which may use first and third-party cookies. A cookie is a small text file which is sent to your computer or mobile device (referred to in this policy as a “device”) by the web server so that a website can remember some information about your browsing activity on the Website.

First party cookies are created by the website that you are visiting. A third-party cookie is frequently used in behavioral advertising and analytics and is created by a domain other than the website you are visiting. Third-party cookies, tags, pixels, beacons and other similar technologies (collectively, “Tags”) may be placed on the Website to monitor interaction with advertising content and to target and optimize advertising. Each internet browser has functionality so that you can block both first and third-party cookies and clear your browser’s cache. The “help” feature of the menu bar on most browsers will tell you how to stop accepting new cookies, how to receive notification of new cookies, how to disable existing cookies and how to clear your browser’s cache. For more information about cookies and how to disable them, you can consult the information at All About Cookies.

Without cookies you may not be able to take full advantage of the Website content and features. Please note that rejecting cookies does not mean that you will no longer see ads when you visit our Site. In the event you opt-out, you will still see non-personalized advertisements on the Website.

The Website collects the following data using a cookie when serving personalized ads:

  • IP Address
  • Operating System type
  • Operating System version
  • Device Type
  • Language of the website
  • Web browser type
  • Email (in hashed form)

Mediavine Partners (companies listed below with whom Mediavine shares data) may also use this data to link to other end user information the partner has independently collected to deliver targeted advertisements. Mediavine Partners may also separately collect data about end users from other sources, such as advertising IDs or pixels, and link that data to data collected from Mediavine publishers in order to provide interest-based advertising across your online experience, including devices, browsers and apps. This data includes usage data, cookie information, device information, information about interactions between users and advertisements and websites, geolocation data, traffic data, and information about a visitor’s referral source to a particular website. Mediavine Partners may also create unique IDs to create audience segments, which are used to provide targeted advertising.

If you would like more information about this practice and to know your choices to opt-in or opt-out of this data collection, please visit National Advertising Initiative opt out page. You may also visit Digital Advertising Alliance website and Network Advertising Initiative website to learn more information about interest-based advertising. You may download the AppChoices app at Digital Advertising Alliance’s AppChoices app to opt out in connection with mobile apps, or use the platform controls on your mobile device to opt out.

For specific information about Mediavine Partners, the data each collects and their data collection and privacy policies, please visit Mediavine Partners.

If you believe that any information we are holding on you is incorrect or incomplete, please contact us.

Mediavine Programmatic Advertising (Ver 1.1)

The Website works with Mediavine to manage third-party interest-based advertising appearing on the Website. Mediavine serves content and advertisements when you visit the Website, which may use first and third-party cookies. A cookie is a small text file which is sent to your computer or mobile device (referred to in this policy as a “device”) by the web server so that a website can remember some information about your browsing activity on the Website.

First party cookies are created by the website that you are visiting. A third-party cookie is frequently used in behavioral advertising and analytics and is created by a domain other than the website you are visiting. Third-party cookies, tags, pixels, beacons and other similar technologies (collectively, “Tags”) may be placed on the Website to monitor interaction with advertising content and to target and optimize advertising. Each internet browser has functionality so that you can block both first and third-party cookies and clear your browser’s cache. The “help” feature of the menu bar on most browsers will tell you how to stop accepting new cookies, how to receive notification of new cookies, how to disable existing cookies and how to clear your browser’s cache. For more information about cookies and how to disable them, you can consult the information at All About Cookies.

Without cookies you may not be able to take full advantage of the Website content and features. Please note that rejecting cookies does not mean that you will no longer see ads when you visit our Site. In the event you opt-out, you will still see non-personalized advertisements on the Website.

The Website collects the following data using a cookie when serving personalized ads:

  • IP Address
  • Operating System type
  • Operating System version
  • Device Type
  • Language of the website
  • Web browser type
  • Email (in hashed form)

Mediavine Partners (companies listed below with whom Mediavine shares data) may also use this data to link to other end user information the partner has independently collected to deliver targeted advertisements. Mediavine Partners may also separately collect data about end users from other sources, such as advertising IDs or pixels, and link that data to data collected from Mediavine publishers in order to provide interest-based advertising across your online experience, including devices, browsers and apps. This data includes usage data, cookie information, device information, information about interactions between users and advertisements and websites, geolocation data, traffic data, and information about a visitor’s referral source to a particular website. Mediavine Partners may also create unique IDs to create audience segments, which are used to provide targeted advertising.

If you would like more information about this practice and to know your choices to opt-in or opt-out of this data collection, please visit National Advertising Initiative opt out page. You may also visit Digital Advertising Alliance website and Network Advertising Initiative website to learn more information about interest-based advertising. You may download the AppChoices app at Digital Advertising Alliance’s AppChoices app to opt out in connection with mobile apps, or use the platform controls on your mobile device to opt out.

For specific information about Mediavine Partners, the data each collects and their data collection and privacy policies, please visit Mediavine Partners.