1. INTRODUCTION

Last updated on 16 August 2021.

This privacy notice sets out how we process your personal data. It provides you with certain information that must be provided under data protection legislation. Personal data is information about individuals or information from which individuals can be identified (“personal data”).

Jungle Creations Limited is the controller of your personal data, which means that we are responsible for making decisions regarding the processing of your personal data. “We”, “our”, “us” refer to Jungle Creations Limited, including all our brands. 

2. WHAT KINDS OF INFORMATION DO WE COLLECT

• Information you've provided to us: We collect information about you, such as your name, email address and opinions, when you provide such information to us, including when you create an online account, subscribe to one of our titles, order or register your interest in one of our products, post a comment under an article or sign up for a newsletter. This could be via your computer browser, via an app, by telephone, or by post.
• Information about transactions made: If you purchase anything or make any other financial transactions on any of our websites/apps, we collect information about your purchase and ask for information including your name, e-mail address and delivery address to be forwarded on to the vendors who are responsible for delivering your order.This does not include payment information such as your credit/debit card number
• Information from Partners: Where you have registered or created an account with one of our websites, we may obtain information about you from other companies who have obtained your permission (through their own privacy policies) to share information about you. For more information about this, please see “Personalisation/Identifying Your Interests” in Section 2 below.
• Social Media: If you log-in to our websites through a social media site, such as Facebook, you are granting permission to Facebook to share your user information with us. This will include your name, email address, date of birth, location, plus any other information you have permitted Facebook to share with third parties. If you remove the app from your Facebook account, we will no longer have access to this information. We may also collect your personal data through our social media accounts when you use tools to tag us and mention us in your posts, statuses and comments through your accounts on these platforms, and when you provide us with your personal data on our accounts on these platforms, e.g. when you comment on one of our posts on Facebook.
• Information about other people: By supplying us with information about someone else, you confirm that they have authorised you to provide us with their information (including sensitive personal data) on their behalf.
  Before you use “email a friend” or “share this article” buttons please make sure that anyone you wish to email or share with are happy for this to occur and expect to receive the email or article. You may only share the details of another person with us where you have their express permission.

3. HOW WE MAY USE YOUR INFORMATION

• Delivering Services:By using our websites, apps and other products andservices, we may process your information for the purpose of entering into and/or performing our obligations under a contract we have with you, for example, for the provision of our products and services. This may include (without limitation): 
  • to set-up, administer and manage your account with us
  • to send you service updates about our websites, apps and other products and services 
• Managing our relationship with you, which shall include(without limitation):
  • contacting you where a checkout journey is not completed if you have provided your information;
  • delivering customer services and support;
  • ensuring the integrity of votes and polls;
  • maintaining records of our communications with you if you get in contact with us;
  • obtaining customer reviews and conducting market research.

Lawful basis for these processing activities: Legitimate Interests of ensuring our services and website are as useful as possible and legitimate interests of providing our products and services. 

• Communicating with you: We may process your personal data in responding to communications by you on the basis of your consent. For example, if you contact us with a query or in circumstances where it is appropriate for us to reply, we will proceed on the basis that you consent to us using your personal data to the extent required to respond to you.
• Marketing: In accordance with your preferences and data protection legislation, we may use your information to send you direct marketing communications. This may include communications by post, telephone, email or SMS about our products and services, events and special offers, mobile phone notification.
  We may also send you periodic newsletters about your chosen services, inform you of promotional offers that you might find interesting, and inform you about any changes to our products and services where we have permission to do so.
  Lawful basis for processing this data: Consent/ Our legitimate Interests including our commercial interests in maintaining and expanding our operations.
• Personalization/Identifying your Interests: We may use your information to provide you with a greater personalised experience when you visit/use one of our sites/apps, and for insight and marketing purposes. We provide personalisation by using data you submit to us, cookies, IP addresses, web beacons or similar technologies in relation to the devices you use. By doing so, we can provide you with editorial content and/or advertising that we believe is more relevant to your interests. Please see our cookie policy for more information on this. .
  Lawful basis for this processing activity: Consent
  We may also overlay demographic and lifestyle data from CACI and Acxiom to help us understand what you might be interested in for insight and marketing purposes (also known as “profiling”). CACI and Acxiom data are built using a variety of sources, including publically available data (such as the electoral register and UK Census records) or from surveys and polls where you have given permission for your data to be shared. For more information on these partners and how you can opt-out of having your data shared with us from these sources for profiling purposes, please see the section entitled “Marketing Personalisation” in Section 4 below.
  Lawful basis for this processing activity: Legitimate Interests of providing you with a tailored experience, including our commercial interests in maintaining and expanding our operations. 
• Tailored advertising: We use advertising to fund some of our websites and apps. Some advertising is “contextual” meaning it is shown due to the particular web page you are presently viewing. Other advertising, known as “online behavioural advertising” is shown to you based upon your likely interests, which are inferred from your device’s browsing history. This information is collected through the use of cookies and similar technologies. For more information on controlling your tailored advertising preferences, please see our cookie policy.
  Sometimes we allow advertisers to show advertisements directly on our website and apps, which are tailored to you based upon information they have obtained, such as your browsing history on their own websites.
  Other times we will arrange for our customers to be shown advertisements on our own or other websites or apps. These advertisements are tailored to you with information we have obtained from your browsing on our websites and apps via cookies.
  Where we arrange for our customers to be shown advertisements, we use technological and contractual mechanisms to protect your cookie data and to ensure that your browsing data used for advertising is not used by advertisers or other website owners for other purposes, such as linking online behavioural advertising data with your contact details, unless you have provided the advertiser or other website with your express permission to do this.
  When you are shown an advertisement, our advertising systems do not know who you are or your contact details (such as your name, email address or postal address).
  Demographic information from your registration on our websites and apps (such as your age, gender and city) may also be used to tailor the advertising we arrange to be shown. Your demographic information is not shared with advertisers. We may also target advertising on social media sites to specifically include customers who have registered for our products and services or previously visited our websites.
  Contextual data is being collected by Premutive LLC
  Legal basis for this processing activity: Consent
• Location based services and advertising: Where we provide services that utilise your device’s location, such as local weather or news, your location will be determined either from a lookup of your IP address in a “GeoIP” database which lists information provided by your ISP (usually your closest town or borough) or your precise location directly from the device (such as through GPS or Wifi on mobile devices) where you have granted permission for us to access this location information via your device settings. We use such information to provide you with a more tailored, relevant experiences when using our websites/apps. Where you have granted permission to access your device’s location and consented to us to use your data for advertising purposes, this location information may be used to tailor the advertising you receive, including showing you certain advertisements when you are in the vicinity of a particular location.
  Lawful basis for this processing activity: Consent
• Measurement and analytics: We may use certain information (such as the websites that you visit and advertisements you see or click on) to help advertisers and other promotional partners measure the effectiveness and distributions of their advertisements and promotions.
  Lawful basis for this processing activity: Consent
• Improving our services and products: We may use your information to monitor and improve our products, content and services. This may include (without limitation):
  • developing the design and style of our products and services to make improvements
  • carrying out statistical, technical and logistical analysis to inform our strategic development
  • blocking disruptive use and ensuring the security of our products and services
• If you have registered on our websites or apps, we may analyse the information we hold on you in aggregate with our other customers to improve our advertising systems.
  Lawful basis for this processing activity: Legitimate Interests of ensuring our services and website are as useful as possible
• Message boards, blogs and other public forums: Our websites may provide message boards, blogs and other user generated content facilities. Anything that you share will become public information. You should always be careful when deciding to disclose your personal information. 
  Lawful basis for this processing activity: Legitimate interests of promoting our products and services and running our everyday operations. 
  We may share your personal data with the Audit Bureau of Circulations Ltd so they can verify aggregated statistics about circulation and usage of our products or review our policies, processes and procedures for compliance with relevant standards. You can view their privacy policy by following this link.
  Lawful basis for processing this data: Legitimate Interests of improving our services for recipients.
• We may also process your personal data: (a) to comply with any legal obligation we are under; and (b) for additional purposes in the future, but only if such purposes are compatible with those listed above and if we believe that the same lawful basis applies.

In certain circumstances, failure to provide us with personal data that we have requested may impact the operation of our business or prevent us from performing any legal obligations to you. For example, if you make a data subject access request, we may need to verify who you are before providing personal data to you; if you do not provide the information we reasonably need to verify your identity, we may not be able to comply with the subject access request.

4. HOW WE MAY SHARE YOUR INFORMATION

• Sharing with third parties 
  Vendors: We may your personal data with third parties, for example, service providers we use to help us in the running of our operations and the provision of our products and services, for example, organisations that provide us with technology related services. 
• Social media: Your personal data may be shared with other parties and/or on our social media accounts for the purposes and the legitimate interests of facilitating our operations and promoting our offerings including on Facebook and Instagram.
• Industry Affiliates: We regularly partner with industry affiliates to bring you special deals on products and packages you may find of interest. These include a variety of industry specific providers. These providers collect marketing permissions for us and share data back with us about your purchases in order for us to measure the effectiveness of our marketing campaigns.
  If you decide to book a holiday with an affiliate, use their advisory services or set up an account, or purchase a financial product, these affiliates will be data controllers of the information you have provided them in order to administer your relationship with them and will handle your information in accordance with their own privacy policies.
• Functionality: We may share information about you with suppliers that we engage to help us provide our services and/or functionality of our websites and apps. For example, we share data with Google to prevent certain website functions from being abused. Where this happens your data will be processed in accordance with Google’s Privacy Policy.
• Advertisers: We may provide third party advertisers with reports containing aggregate statistical data about our customers’ use of our websites and apps to determine the kinds of people viewing their ads and how they are performing. This aggregated information may include demographic data such as age range and/or geographic location of groups of our customers.
  This aggregated data does not include contact details (such as names, addresses or email addresses) that can be used to personally identify you or contact you. Marketing personalisation: We may match your data with data held by CACI and Acxiom, to add extra lifestyle and demographic insight information to your account with us which we then use to make our marketing more relevant to you (subject to your communication preferences and our internal policies and procedures). We can only obtain this information where they have your permission to share this information with us in line with their privacy policies. You can opt-out of having your personal information profiled in this way by contacting us or adjusting your account settings. For more information on these partners and the data it provides, and to opt out of their programmes directly, please visit them at CACI and Acxiom.www.vt.co is part of the Jungle Creations Ltd. Digital properties operated by Jungle Creations Ltd may, use and share, within that organization, the information you provide and other information held about you for the purposes set out in this Policy. For more information about the Jungle Creations Ltd please see the Jungle Creations website and the Jungle Creations’s Privacy Policy. Change of Control: We may transfer, sell or assign any of the information described in this Policy to third parties as a result of a sale, merger, consolidation, change of control, transfer of assets or reorganisation of our business.
• Other data sharing: There are other circumstances in which we may need to share your data with third parties. We may, for example, share your data in connection with legal proceedings or if we need to protect or defend our legal rights. We may also disclose your personal data to HMRC and / or law enforcement agencies in order to assist with any investigations and/or to companies that we have close links with, for example, elements of common ownership.

5. DETAILS OF TRANSFERS TO THIRD COUNTRIES AND SAFEGUARDS

When we share your personal data with parties based and/or processing personal data outside of the UK and the EEA we implement appropriate transfer safeguards, for example, model clauses approved by the European Commission, and other additional contractual measures, if necessary. You can view the European Commission’s decisions which include the model clauses at these links: (i) http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32010D0087&from=en; and (ii) https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2004:385:0074:0084:EN:PDF. 

We are monitoring the developments in this area of law and will be putting in place any necessary new, different and/or additional measures for any international transfers.

6. HOW OUR BRANDS WORK TOGETHER

The VT, Four Nine, Four Nine Looks, Viral Motion, Twisted, Twisted London, Craft Factory, Lovimals, Level Fitness and Jungle Creations share infrastructure, systems and technology and all fall under the data control of Jungle Creations Ltd. These brands work together to understand how our users interact with our products and services, and to share insights to improve our products and services.

7. HOW YOU CAN EXERCISE YOUR DATA SUBJECT RIGHTS 

• Access: If you wish to exercise your right to access a free copy of your data, you can contact us at the contact details provided below at Section 12.
• Deletion: To ask us to delete your personal data, please contact us at the contact details provided below at Section 12. However, there may be circumstances where we are legally entitled to retain it.
• Rectification: If you wish to update or rectify your data, you can do this directly by accessing your account settings.
• Revoke consent: If the lawful basis we rely on to process your personal data is consent you have the right to withdraw this consent. Please email us at [email protected] to withdraw consent for the processing of your personal data. If you wish to object to the processing of your data for direct marketing or online behavioural advertising purposes, you can opt-out by updating your settings or, for direct marketing, clicking on the “unsubscribe” link in any marketing email or newsletter you receive from us.
• Objection to automated profiling: If you wish to opt-out of having your personal information profiled for personalisation purposes you can adjusting your account settings or contact us directly.
• Objection to legitimate interests: If you wish to object to our processing of your data where we are pursuing our legitimate interests or those of a third party please contacting us as at the contact details provided below stating the nature of and reasons for such objection.
• Restriction: You may request a restriction on the processing we undertake on your personal data. This will only apply if we have no lawful basis to process your personal data, your personal data is inaccurate or to comply with an objection request.
• Portability: You have the right to receive some of your personal data in machine readable format. This right extends to you being able to request that such data is sent to a third-party controller.
• Complain: You also have the right to lodge a complaint about us with a supervisory authority. In the UK, this is the Information Commissioner’s Office.
  If you are contacting us to exercise any of your data subject rights, you will have to provide valid proof of identification. We are required to respond to your request within 1 month.

8. DATA RETENTION AND ACCOUNT DELETION

We store your data for no longer than necessary in relation to the purpose under which such data was collected. This is determined on a cases by case basis and depends on things such as the nature of the data provided, why it was collected, the legal basis we rely upon to process the data, and our relevant legal or operation retention requirements. For example, if you request to delete your account we still have to retain some data for fraud prevention purposes and financial auditing

9. CHILDREN AND YOUNG PEOPLE

Our websites, apps and other products and services are not aimed at children. We do not target, intend to collect, or knowingly collect or otherwise process information from anyone under the age of 13.

If you are under the age of 13, we request that you do not provide us with your information and do not use our websites and apps.

If you are a parent or guardian of a child under 13, please contact us if you are aware that your child has used our websites or apps or otherwise provided their information to us without your consent. We will delete or otherwise cease processing your child’s personal information within a reasonable time.

If you are aged 13, 14 or 15, we request that you seek your parent or guardian’s permission before providing us with your information or using our websites or apps. In accordance with industry best practice guidelines, we may retain your information for a reasonable amount of time to make sure that we do not contact you in the future.

10. CHANGES TO THIS POLICY

We reserve the right to make changes to this Policy. Where changes are made, we will post the revised Policy here with an updated effective date. Please check regularly for any changes to this Policy.

11. HOW TO CONTACT US

If you have any queries or comments about this Policy or to exercise any of your data subject rights, please contact us by email at: [email protected]. 

Alternatively you can write to us at:

Data Protection & Privacy 

Jungle Creations Ltd

6 Batty St.

London, E11RH

U.K.

Jungle Creations Limited is registered as a controller with the Information Commissioner’s Office with registration number ZA428049.