PRIVACY POLICY

Effective date:08 November 2021

 

Introduction

Jane McMillan ("Jane McMillan", "us", "we" or "our") respects the privacy concerns of our customers, workers and all users of our website www.janemcmillan.com ("the website") and all our products and services (collectively "the product").  We are committed to protecting your privacy.   This Privacy Policy (the "Privacy Policy" or "policy") sets forth the basis of how we collect and process your personal data that you provide to us or we collect from you in connection with the product.  We are providing this Privacy Policy so that you can better understand how we collect, use and share information that is gathered using our product.

For the purposes of this Privacy Policy, “personal data” means any information that can be used to identify an individual whether directly or indirectly.

By visiting www.janemcmillan.com you are accepting and consenting to the practices described within.   Read through this policy carefully and if you do not accept, understand or agree with it please discontinue use of this website immediately.  By accessing www.janemcmillan.com and providing us with your personal data you are attesting to being over 13 years old in the UK or over 16 years old outside of the UK.

Jane McMillans' Product is not directed at children under the age of 16 and we never knowingly collect personal information from children.  We recognize the special obligation to protect personally identifiable information obtained from children age 13 and under.

If you are 16 years old or younger, Jane McMillan requests that you DO NOT submit any personally identifiable information to the site, to Jane McMillan or any of our team.  If we discover that a child age 16 or younger has signed up for our Product or provided us with personally identifiable information, we will delete that child’s identifiable information from our records. 

 

Personal Data that we Collect

Your privacy and the security of your personal information is important to us and we take it very seriously.  We have taken suitable and reasonable steps to protect the personal data we hold from misuse, loss or unauthorised access and all the information you provide to us is stored on secure servers with any payment transactions encrypted using SSL technology.  Payment data is stored only by payment processors and is never stored on our servers. 

Where we have given you (or where you have chosen) a password, which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone and recommend that you change it frequently.

Access to your personal data is limited to employees, contractors or third parties who require it for the purpose of carrying out their service.  They will comply with our instructions, must keep your data confidential and for no longer than required.

The types of data will depend on each individual but typically might include  the following:

  • Personal information:  This might include your name, email address, phone number or contact details.
  • Customer information:  If you purchase products and/or services from us we might process information relating to your purchase, supply and also keep any appropriate records of such.  This might include your billing address, delivery address, credit card or other payment details and we shall process these on contractual grounds.
  • Promotional use:   This could include any information you provide regarding promotions, marketing or advertising (from us or third parties).   We shall use this information to provide the product to you, to monitor our marketing and promotional activities, record-keeping and to compile legitimate analytics.  We shall also use it to provide relevant free resources, offers, advertisements, promotions, competitions or advertisements through our website and other online platforms or to analyse results for the legitimate purpose of promoting and growing our business.
  • User information: Including any comments,  posts, images, documents or videos that you share on our website, online platforms or social media channels.    This can also include technical information regarding your use of our website or other online platforms such as your pixel ID, pages visited, page views, your browser information, number of visits and, if appropriate, log-in details.    This information will only be used to analyse and monitor the usage and the content of our website and other online platforms to improve www.janemcmillan.com and provide content relevant to you.   It also assists administration with record keeping obligations.   If you have  purchased or enquired about our products or services and at the time of purchase or enquiry you agreed to receive advertising or marketing information from us (and you have not opted out) in accordance with the Privacy and Electronic Communications Regulations (PECR) we might also send you relevant advertisements or marketing information.  We shall ensure our emails clearly display the location of the sender and easy options to opt-out in accordance with the CAN-SPAM act.
  • If you participate in a video meeting with us, we may record the session and retain the recordings.  We will notify you first that the session is being recorded so that you can choose not to participate.  If you participate in a training or product course, we collect completion data.

  • Emails sent from us include page tags that allow us to collect information about who opened those emails and clicked on links in them.

 

Personal Data that You Give Us

You may give us information about you by (1) filling out forms on www.janemcmillan.com, (2) subscribing to our newsletter, (3) subscribing to our email list, (4) requesting information through a contact form,  (5) send questions or comments by live chat, (6) interract with Jane McMillan or customer support, (7) fill out surveys, (8) create an account, (9) purchase or subscribe to our Product, (10) participate in events or promotions, (11) report a website problem or  (12) by corresponding with us by e-mail, social media channels or otherwise. 

This data will NEVER be leased or sold and you can easily unsubscribe at any time.   If you decide to unsubscribe, your data will be permanently deleted from the system.    

Your data will be kept for no longer than is required in relation to the purpose for which it was collected by us or provided by you and we will take reasonable steps to permanently destroy your personal data when it is no longer required. 

We may also process your personal data through the use of other tracking software and third parties, search and analytics information providers, advertising networks, or other online information providers based outside of the EU.   

Third parties may gather technical information about your computer for our services and to provide statistical information regarding the use of www.janemcmillan.com to enable us to improve the website.

We may also process your personal data through the use of payment and delivery services such as PayPal, Stripe or other payment processing providers based outside of the EU.

 

Information That We Collect

This might include, but is not limited to, your email address, phone number, address, financial and credit card information, personal description and photograph. 

When we process your personal data we will comply with relevant data protection laws such as the Data Protection Act 1998 and the General Data Protection Regulation (EU Regulation 2016/679) (“GDPR”), which means that your data will be used lawfully, fairly, kept securely and only for as long as necessary for the purposes explained in this policy.

We will only collect and process your personal data for legitimate purposes or reasons clearly outlined prior to you providing us with your data.

We will only process your personal data on the basis of a lawful condition.  This will either be because it is in our legitimate interests to do so, you have given your consent for us to process your data or where we are under a contractual or legal obligation.

 

How This Information is Used

We may use the personal information collected through our Product to:

  • Provide and deliver to you the information, Product or other services you requested from us, process transactions and send you related information.
  • To operate, personalise and improve our Product and provide content, communications or features that match users interests.
  • To serve you and others in the most effective way by providing information about goods, services, content and advertising we feel may interest you.
  • To allow you to participate fully in our services.
  • Respond to your queries, comments, requests and provide you with requested customer support.
  • To maintain a secure website, prevent fraud and protect the security of your account.
  • Monitor and evaluate usage, trends and activities in connection with our Product.
  • To carry out our legal obligations arising from contracts entered into between you and us.
  • To assist with internal operations such as troubleshooting, testing, research, data analysis, survey purposes and statistics.
  • To notify you about any changes to our services, technical notices, updates, security alerts, support and administrative messages.

 

Disclosure of your Information

We might share your information with selected third parties as follows:

  • External service providers that support our business including but not limited to:
    • Facebook / Instagram (aka Meta)
    • Google
    • Paypal
    • Stripe
    • Kajabi
    • Zoom

We understand that these third parties have appropriate technical snd security processes in place to protect your data.

  • Where required by professional support teams & contracted workers.
  • Where required by government bodies or legal obligations.
  • When external service providers or business partners are engaged by us to help provide services to our clients and customers.  This is solely for the performance of any contract we enter into with them or you.  (We only disclose personal data that the service provider needs to undertake that specific activity.  Any external service providers are required to agree to keep your personal data secure in accordance with the relevant law).   
  • Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others.
  • Analytics and search engine providers that assist us in the improvement and optimisation of our site.
  • In order to enforce or apply our terms and conditions and other agreements
  • In business transfers. When any asset is transferred we will transfer information including personal information, provided that the receiving party agrees to respect your privacy in a way that is consistent with our Privacy Policy.
  • Whenever necessary to protect the rights, property, or safety of Jane McMillan, our customers, or others. This includes exchanging information for the purposes of fraud protection and credit risk reduction.

 

Where Your Information is Processed

Our website is located in the United Kingdom and we comply with the Internet laws applicable to the United Kingdom which includes the GDPR. 

Your data will be processed within the United Kingdom and for the purpose of the Privacy Policy the data controller is Jane McMillan, 167-169 Great Portland Street, 5th Floor, London W1W 5PF.

Your data might also be transferred to a third-party service provider which requires your data to be transferred outside of the EEA. We understand that they comply with the following standards relating to the security of your personal data: 

  • Google complies with the General Data Protection Regulation,  is certified under the privacy shield for data transfers and comply with the Payment Card Industry Data Security Standards. 
  • Facebook complies with the General Data Protection Regulation and is certified under the Privacy shield for data transfers. 
  • Zoom is certified under the EU-U.S. Privacy Shield Framework and the Swiss-U.S Privacy Shield.  Stripe is certified under the EU-US Privacy Shield as well as EU Standard Contractual Clauses and Binding Corporate Rules. 
  • Paypal relies on Binding Corporate Rules approved by competent Supervisory authorities. 
  • Kajabi information is stored on secure servers and they have a European Data Protection Office (EDPO) as their GDPR representative in the EEA.

Where your data is transferred to parties not listed above then at least one of the following conditions will be met: 

  • It is a legal requirement.
  • The country has an adequate level of protection for personal data;
  • You have given your express consent.
  • It is authorised by the relevant data protection authority.

You have the right to access and receive a copy of your personal data, to ask us to erase your personal data, correct any errors, restrict or object to how your information is processed.  You can find out more about your rights by visiting https://ico.org.uk/your-data-matters/.   Also if you are not happy with how we have processed your personal data you have the right to lodge a complaint with the Information Commissioners Office (ICO), the UK supervisory authority for data protection issues.

If you are submitting information over the internet that you wish to remain private, while attempts are made to secure information transmitted to this site, there are inherent risks in transmitting information across the internet.  Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access however any transmission is at your own risk.  You can, if preferable,  contact us by alternative means using phone or mail. 

To keep the information we hold on you up-to-date please contact us at [email protected]  whenever your personal details change.

Please note that you can withdraw your consent for us to process your personal data at any time by contacting [email protected] .

We reserve the right to change the provisions of this Privacy Policy from time to time and will indicate when changes have been made by revising the date at the top of this Policy.  We will not notify you of any changes however any changes will be uploaded to the website.  We encourage you to review the Policy whenever you access the Product to make sure that you understand our practices. 

Your first visit to www.janemcmillan.com and any related landing pages after any alterations or updates will constitute your acceptance of such changes.

Please check back frequently to see any updates or changes to our privacy policy.

If you have any questions about this Privacy Policy or require more information concerning our private practices please contact us at:

Email: [email protected] 

Post:

Jane McMillan

167-169 Great Portland Street, 5th Floor, London W1W 5PF