Privacy Policy US

1. Important information and who we are

This privacy policy gives you information about how Joonbyrd Limited collects and uses your personal data through your use of this website (Website), including any data you may provide when you create an account with us, sign up to our newsletter or purchase a product.

This privacy policy is for: 

• Potential and current customers that are individual consumers.
• The staff of customers and potential customers that are organizations. 
• Potential and current suppliers (including wholesalers) and their staff. 
• Users of our Website. 
• Job applicants. 

This Website is not intended for children (individuals under the age of 18) and we do not knowingly collect data relating to children.

2. Controller

Joonbyrd Limited is the Controller and responsible for your personal data (collectively referred to as we, us or our in this privacy policy).

We have appointed a data protection manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data protection manager using the information set out in the contact details in section 10.

3. The types of personal data we collect about you

Personal data means any information about an individual from which that person can be identified. 

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, marital status, title, date of birth and gender. 
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes payment card details. 
• Transaction Data includes details about payments to and from you and other details of products you have purchased from us.
• Subscription Data includes your preferences around your purchase of a product subscription from us (Subscription Program).
• Profile Data includes your username (or similar identifier), password, purchases or orders made by you, your interests, and preferences (including marketing preferences). 
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this Website. 
• Usage Data includes information about how you interact with and use the Website. 
• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
• CV Data includes information about you that would appear in a CV or other media. 

Aggregated Data

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyze general trends in how users are interacting with our Website to help improve the Website and our service offering. 

Special Category Personal Data 

You may have heard Special Category Personal Data be called ‘sensitive’ data. Special Category Personal Data is subject to enhanced protections under the UK GDPR. It includes: 

• Personal data revealing racial or ethnic origin;
• Personal data revealing political opinions;
• Personal data revealing religious or philosophical beliefs;
• Personal data revealing trade union membership;
• Genetic data;
• Biometric data (where used for identification purposes);
• Data concerning health;
• Data concerning a person’s sex life; and
• Data concerning a person’s sexual orientation.

We do not intentionally collect any Special Category Personal Data as part of our organization’s day-to-day activities or as a requirement of supplying our products to you. 

However, you could potentially provide Special Category Personal Data to us if you email us to tell us you have a skin condition and you ask for advice around which of our products to purchase taking into account your skin condition. In these circumstances we would be processing personal data concerning your health. The same is true in respect of any other Special Category Personal Data you provide to us. 

4. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• Make a purchase on our Website;
• Create a profile on our Website (and manage your profile);
• Subscribe to our Subscription Programme and manage it;  
• Request marketing to be sent to you; or
• Give us feedback or contact us. 

• Automated technologies or interactions. As you interact with our Website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details. 

The following are examples of information we may collect: 

• Technical Data. 
• Website Usage Data. 
• Length of visits to certain pages. 
• Subjects you viewed or searched for. 
• Page response times. 

• Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below: 
• Technical Data is collected from the following parties:

• Analytics providers such as Google, using UK data centers; and
• Our web-developer, Superrb, responsible for managing our cookies. 

• Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services such as Stripe and Shopify. 

5. How we use your personal data

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Performance of a contract with you: where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate interests: we may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Consent: we rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example when you provide us with Special Category Personal Data (which we will never request from you). 

6. Purposes for which we will use your personal data 

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/Use	Type of Data	Legal Basis
To process and deliver your order, including manage payments, fees, charges, and refunds (if you are an individual that is our customer).	(a) Identity  (b) Contact  (c) Financial  (d) Transaction  (e) Profile	Performance of a contract with you.
To process and deliver your order, including managing payments, fees, charges, and refunds (if you are an employee of an organization that is our customer).	(a) Identity  (b) Contact  (c) Financial  (d) Transaction  (e) Profile	Necessary for our legitimate interests (to sell our products to your organization).
To permit you to create a profile on our Website	(a) Identity  (b) Contact  (c) Financial  (d) Transaction  (e) Profile	Necessary for our legitimate interests (to make the purchase of our products more seamless).
To publish and manage any contribution you may make to our Website.	(a) Identity  (b) Contact  (c) Financial  (d) Transaction  (e) Profile	Necessary for our legitimate interests (to share your opinions on our products or other relevant material to other customers and other customers).
To manage your Subscription.	(a) Identity  (b) Contact  (c) Financial  (d) Transaction  (e) Subscription (f) Profile	Performance of a contract with you.
To receive your or your organization’s goods or services to us.	(a) Identity  (b) Contact  (c) CV	Necessary for our legitimate interests (to receive the supply of goods or services to our business).
To consider you or your organization’s offer to supply goods or services to us.	(a) Identity  (b) Contact  (c) CV	Necessary for our legitimate interests (to consider the supply of goods or services to our business.)
To consider your application for a job with us.	(a) Identity  (b) Contact  (c) CV	Necessary for our legitimate interests (to consider candidates to join us).
To manage our relationship with you by notifying you about changes to our terms or privacy policy or to address your requests, complaints or queries (where you are an individual customer).	(a) Identity  (b) Contact  (c) Financial (d) Transaction  (e) Profile	Performance of a contract with you.
To manage our relationship with you by notifying you about changes to our terms or privacy policy or to address your requests, complaints or queries (where you are an employee of an organization that is our customer).	(a) Identity  (b) Contact  (c) Financial (d) Transaction  (e) Profile	Necessary for our legitimate interests (to sell our products to your organization).
To respond to your enquiries about our products (where you are not our customer or your organization is not a customer of ours).	(a) Identity  (b) Contact	Necessary for our legitimate interests (to respond to your queries to attract new customers and improve our products and services).
To respond to your enquiries about our products, where you provide us with Special Category Personal Data (whether or not you are a customer or your organization is a customer).	(a) Special Category Personal Data	Explicit consent.
To administer and protect our business and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).	(a) Identity (b) Contact (c) Technical (d) Profile	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization).
To deliver relevant website content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you.	(a) Identity  (b) Contact   (c) Usage  (d) Marketing and Communications  (e) Technical  (f) Profile	Necessary for our legitimate interests (to study how customers use our products, to develop them, to grow our business and to inform our marketing strategy.
To use data analytics to improve our Website, products, customer relationships and experiences and to measure the effectiveness of our communications and marketing.	(a) Technical  (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and to keep our Website updated and relevant, to develop our business and to inform our marketing strategy).
To send you relevant marketing communications and make personalized suggestions, back in stock email notifications and recommendations to you about goods that may be of interest to you.	(a) Identity  (b) Contact  (c) Technical  (d) Usage  (e) Marketing and Communications (f) Profile	Legitimate interests (to promote our products and services).

7. Direct marketing

You will receive marketing communications from us if you have requested information from us or purchased goods from us and you have not opted out of receiving the marketing.

We may also analyze your Identity, Contact, Technical, Usage and Profile Data to form a view which product and offers may be of interest to you so that we can then send you relevant marketing communications. 

8. Third-party marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes. 

9. Opting out of marketing

You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us. 

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes (for example relating to order confirmations for a product warranty registration, updates to our Terms and Conditions, checking that your contact details are correct).

10. Cookies

For more information about the cookies we use and how to change your cookie preferences, please see our Cookie Policy page.

11. Disclosures of your personal data

We may share your personal data where necessary with the parties set out below for the purposes set out in the table above.

• Internal Third Parties such as lawyers, accountants, other professional advisers that assist us with the running of our business. 
• External Third Parties with which we contract with to provide various services to us:
• CRM and order management providers like Zendesk, Klaviyo, and SoPost; and
• Providers that assist us with the functionality of the Website like cloud computing services, message boards and image hosting services and with analytics and search engine providers that assist us in the improvement and optimisation of our Website as described above.
• Our warehousing and logistics service provider(s) such as Walker Logistics.
• Delivery providers, like DPD, Evri, and so on. 
• Our payment partners: Visa, Mastercard, American Express, Google Pay and Apple Pay.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. 

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 (commercial or otherwise) and only permit them to process your personal data for specified purposes and in accordance with our instructions.

In simple terms: we do not sell your personal data. 

12. International transfers

We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law.

Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place: 

• We will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data.
• Where we use certain service providers, we may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK. 

Please note that some of our External Third Parties are based in the US, so the personal data they process on our behalf may be exported to the US, always in accordance with data protection law. 

By submitting your personal information, you agree to this transfer, storing or processing. If you would like more information about the mechanisms via which your personal data is transferred, please contact us. 

13. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized 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. 

14. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain. 

your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax and other legal purposes.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. 

15. Your legal rights

You have a number of rights under data protection laws in relation to your personal data. 

You have the right to:

• Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes. 
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products to you. We will advise you if this is the case at the time you withdraw your consent.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:

• If you want us to establish the data's accuracy;
• Where our use of the data is unlawful but you do not want us to erase it;
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us. 

16. No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

17. What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

18. Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could 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. 

19. Contact details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact our data protection manager in the following ways:

• Email address: customercare@joonbyrd.com  
• Postal address: 128 City Road, London, England, EC1V 2NX. 

20. Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

21. Changes to the privacy policy and your duty to inform us of changes  

We keep our privacy policy under regular review. This version was last updated April 2024. Historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

22. Third-party links 

This Website 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 control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy policy of every website you visit.