Last updated on 16 January 2024
This policy covers the processing of personal data by Jungle Creations Limited, whose registered address is 6 Batty Street, London, England, E1 1RH and its associated Group companies and brands (“Jungle”, “we” or “us”). 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. This policy relates to users of our websites and social media accounts.
Jungle is committed to protecting the privacy of your personal information whilst striving to provide the very best user experience. We want our websites and social media accounts to be safe and enjoyable for everyone. Under the UK General Data Protection Regulation 2021 (GDPR), the Data Protection Act 2018 and related laws, we have a legal duty to protect the personal information we collect from you.
GDPR says that ‘personal data’ is any information relating to a living individual who can be identified, either directly or indirectly, from that information. This could include your name, email address, postal address or telephone number, or information collected online and used to identify you.
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 6 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.
Content you share with us: When you choose to share comments, photos, videos and other content with us we may receive personal information about you, for example when you interact with us on social media.
Information we collect automatically when you use our sites/services: We may collect technical and/or behavioural information about your use of our websites or other content online, and the device(s) you use to access the services. For example, this information may include details about how you browse our website and the devices and technology you use to browse our website. This may also include unique online identifiers such as device ID, device type, IP address and approximate location at the time of browsing. This may also include video viewing data and may link to your activity on other sites and allows us to recognise you or your device. We may use this to build a more detailed profile of you and your interests. We may also provide you with location-based services (for example, advertising and other personalised content), where we collect geo-location data.
Information for analysis, reporting and research: We may also collect statistical and analytical data about your visits and activity on our sites, such as the pages you view, how long for, and which links are followed. This helps us to improve the way we deliver content and the products and services offered to you. We also use this anonymised data to report on our performance and to sell advertising. In addition, we may need to contact you about your experience of a product or service we provide you.
Research Surveys: We may use the information you provide to invite you to participate in surveys and focus groups about our products, clients and services. Participation is always voluntary and the answers you provide are anonymous and aggregated to support our learnings and inform changes we can make to improve our products and services.
Information from other sources: We may receive information and data about you from other sources such social media platforms. For example, when you visit one of our Facebook pages. Other information, such as inferred data and demographics data, may also be collected and used to match, combine and enrich profile information we hold on you. For example, linking your contact or subscriber information with your activity across our sites.
Business specific data: Some of our websites may also collect business data, for example when signing up for a webinar or when downloading a newsletter. This may include professional or employment information, such as company name, job title, job function, level in organisation, company type, company revenue and number of company employees, business phone number, business address, business email, corporate website, employment history, professional designations and educational information. Also location information, such as country, and state (or county), and ZIP code (or postcode). We typically collect this information directly when you complete registration forms or when you provide other information through our Website or via email. When we collect this information directly, we let you know if providing the information is optional or if it is required to provide our Services.
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. WHAT LAWFUL BASIS DO WE RELY ON FOR PROCESSING?
In order to process your personal data, we must have a lawful reason for doing so. GDPR sets out six lawful bases under which organisations can collect, use and store personal data. We rely on four of the lawful bases:
Necessary for the performance of a contract
If you are our customer, we will process your personal data on the basis that it is necessary for us to provide our products and services to you.
In some instances we rely on your specific consent to process your personal information. This is where you have actively agreed and ‘opted-in’, for example to receive marketing communications from us, and you have the right to withdraw your consent at any time.
Compliance with laws
We may have to process and share your personal data in order to comply with our legal obligations, or to protect our rights or the rights of others. For example, we are required to collect certain information from you for tax or financial reporting reasons.
In some situations we rely on our legitimate business interests in order to collect and use your personal data. In these situations, we have conducted a balancing test to carefully consider the impact of the processing on your interests, rights and freedoms. We will only undertake the processing if we are satisfied there is no negative impact on you. We rely on Legitimate Interests for the following activities:
providing, maintaining, improving and developing our products and services;
sending direct marketing communications about our products and services to customers, include content we send on behalf of advertisers;
sending marketing communications related to the products and services of carefully selected companies in a business-to-business context;
managing suppression and unsubscribe requests;
researching publicly available business contact details;
managing certain aspects of our events;
analysing the use of our products and services;
using aggregated, non – personally identifiable statistical and analysis data to identify usage trends, such as your visits and activity on our sites, and to determine the effectiveness of campaigns;
allowing you to comment on our sites, provide feedback or take a survey;
dealing with queries and complaints;
notifying you of product recalls or providing other information concerning products you have purchased;
personalising your experience on our sites;
Improving merchandise selections and your overall shopping experience;
using your data in hashed non-identifiable form to help find you or similar audiences through Facebook’s audience function and Google customer match; and
identifying fraudulent behaviour and ensuring our websites and systems are secure;
building and enriching profiles of users based upon, for example, product selection and online behaviour.
If you object to our reliance on Legitimate Interests for any purpose please contact us (see below).
4. WHAT DATA IS COLLECTED ON OUR WEBSITES?
Information storage and access
The storage of information, or access to information that is already stored, on your device such as advertising identifiers, device identifiers, cookies, and similar technologies.
Content selection, delivery, reporting
The collection of information, and combination with previously collected information, to select and deliver content for you, and to measure the delivery and effectiveness of such content. This includes using previously collected information about your interests to select content, processing data about what content was shown, how often or how long it was shown, when and where it was shown, and whether you took any action related to the content, including for example clicking on content. This does not include personalisation, which is the collection and processing of information about your use of this service to subsequently personalise content and/or advertising for you in other contexts, such as websites or apps, over time.
When you visit our site we may collect information about your use of the content, and combine this with previously collected information, in order to measure, understand, and report on your usage of the service. This may include collecting certain personal data about you for an online audience measurement project that analyses internet users’ behaviour and profile across different websites, applications and devices in the UK, working with IPSOS, a specialist research agency.
This does not include personalisation, or the collection of information about your use of this service to subsequently personalise content and/or advertising for you in other contexts, i.e. on other services, such as websites or apps, over time.
The collection and processing of information about your use of this service to subsequently personalise advertising and/or content for you in other contexts, such as on other websites or apps, over time. Typically, the content of the site or app is used to make inferences about your interests, to help us to personalise your experience and show you more relevant content and advertising.
Ad selection, delivery, reporting
The collection of information, and combination with previously collected information, to select and deliver advertisements for you, and to measure the delivery and effectiveness of such advertisements. This includes using previously collected information about your interests to select ads, processing data about what advertisements were shown, how often they were shown, when and where they were shown, and whether you took any action related to the advertisement, including for example clicking an ad or making a purchase.
This does not include personalisation, which is the collection and processing of information about your use of this service to subsequently personalise advertising and/or content for you in other contexts, such as websites or apps, over time.
5. HOW DOES IT WORK WITH SOCIAL MEDIA ACCOUNTS?
We operate accounts on different social media platforms. If you visit one of our social media accounts we can usually only see information stored in your public profile on the social media platform, when you are logged in to your profile, while visiting our social media account; although we may process data that you provide to us when you contact us (for example: if you create a post, or send us a private message via Facebook).
If you visit one of our social media accounts, the operator of the social media platform also processes your data, regardless of whether you yourself have a profile on the platform. The social media platform also provides us with anonymous usage statistics, which we use to improve user experience. We do not have access to the usage data that the operator of the social network collects to create these statistics. For information on the social media operators and their privacy policies, please see links below:
Certain sites offer services that require you to set up an account prior to receiving such services. To create a secure account you can use your email address and a password or, if the site offers a Facebook single-sign-on service, you will be able to register for and log-in to your account using your Facebook account. If you choose to use the Facebook single-sign-on service, you are granting permission to Facebook to share certain profile information with us. This may include your name, profile picture, and list of friends and any other information notified to you by Facebook prior to you completing the single-sign-on authorisation process. You control what social information you allow us to have access to using the privacy settings on the applicable media platform and any permissions you give as part of the single-sign-on authorisation process.
6. HOW WE MAY USE YOUR INFORMATION
By using our websites, apps and other products and services, 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.
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:
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 7 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.
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.
Lawful basis for processing this data: Legitimate Interests of improving our services for recipients.
Other purposes: 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.
7. HOW WE MAY SHARE YOUR INFORMATION WITH THIRD PARTIES
Vendors: We may share 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.
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.
8. DETAILS OF TRANSFERS TO THIRD COUNTRIES AND SAFEGUARDS
Your personal data may be processed in a country other than your country of residence. For example, if you are a UK citizen you may find your data is processed by a supplier or service based outside the UK or EEA, such as in the United States.
If such a transfer requires us to apply additional safeguards to your personal information under, for example, UK or European data protection laws, we will do so. These steps may include implementing the UK’s International Data Transfer Agreement clauses or European Commission’s Standard Contractual Clauses, with additional UK-specific clauses for transfers of personal information to our service providers and business partners.
To the extent applicable, we may rely on derogations as set forth in Article 49 of the GDPR for the transfer and onward transfer of personal information collected from individuals in the UK or EEA to the United States, and other countries that the EU views as not providing adequate data protection. Specifically, we may transfer such information to another party in accordance with our lawful basis for processing.
By using our website, products or services or by interacting with us in the ways described in this Privacy Notice, you consent to the transfer, storage and processing of your personal information outside your country of residence, including out of the EEA, in the circumstances set out in this Privacy Notice. If you do not want your information to be transferred in this way you should not use our website, applications or services.
9. 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.
10. HOW YOU CAN EXERCISE YOUR DATA SUBJECT RIGHTS- UK AND EU USERS
You have the right to request:
Access to the personal data we hold about you.
The correction of your personal data when incorrect, out of date or incomplete.
The deletion of your personal data.
That we stop using your personal data for direct marketing if you object to it.
That we stop any consent-based processing of your personal data after you withdraw that consent.
The right to request a transfer of your data to another service provider.
Your right to withdraw consent
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
Where we rely on our legitimate interest. In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
Direct marketing- You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request. Remember, you can always stop direct marketing messages by clicking on an unsubscribe link in any of our emails.
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 14.
Deletion: To ask us to delete your personal data, please contact us at the contact details provided below at Section 14. 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. You will not usually have to pay a fee to access your personal data (or to exercise any of the rights), however, we may charge a reasonable fee if your request is unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. If we choose not to action your request we will explain to you the reasons for our refusal.
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.
11. 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 case 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/tax purposes.
12. 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.
13. 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.
14. 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.
Jungle Creations Limited is registered as a controller with the Information Commissioner’s Office with registration number ZA428049.
15. OTHER DATA SUBJECTS
GDPR in relation to Jungle’s clients is covered within a specific section of our client agreement for products and services.
GDPR in relation to Jungle’s employees and freelancers is covered within the employment contract or contract for services.
GDPR in relation to Jungle’s suppliers is covered within the contractual terms of agreement between Jungle and the supplier.