Privacy Notice
Privacy
At JO1N, we understand that your privacy is important. We respect and value the privacy of everyone who visits www.JO1N.com or our app (the “Site”). We only collect and use your Data as described in this Privacy Notice (the “Notice”) and as permitted by Data Protection Legislation.
The purpose of this notice is to explain how and why we collect information from you, who has access to it and what your rights are. Please read this Notice carefully and ensure that you understand it.
Please note that our Site are not intended for use by individuals under 18 years old.
Who are we?
We are JO1N, and our Site is owned and operated by JO1N Limited (trading as JO1N), a company registered in the UK, registration number: 12993623 at 35 Waveley Road, Coventry, England, CV1 3AG (“JO1N”, or “we”, “us” or “our”).
For the purposes of the Data Protection Legislation under the UK Data Protection Act (UK GDPR), as well as under the EU/EEA GDPR we are the data controller, which means that we are responsible for determining the purposes for which and means of how your Data is Processed.
If you have any concerns about how we Process or protect your Data or would like to contact us about any aspect of this Notice, please get in touch with our privacy team, who oversees our handling of Data, and who can be contacted at; privacy@jo1n.com
This Notice should be read together with our Cookies Notice, and our Site terms and conditions.
What information do we process?
When you use JO1N, there’s two ways we receive your personal data: There’s personal data you provide when you interact with us and there’s personal data, we collect about you from a variety of sources (e.g., credit and fraud prevention agencies, stores, or public databases).
We process personal information about you we need to be able to confirm your eligibility for credit, confirm your identity, offer you support, or carry out a credit assessment before granting credit. This may include your name, date of birth, address, contact details, employment, financial and identification information. We may require further information dependant on requirements.
Why is it being processed?
We process this information in order to be able to deliver credit payment services that suit your needs, and in order to deliver services to our partners/clients. We also collect this information to comply with Fraud. Anti-Money Laundering Regulations, and the Financial Conduct Authority (FCA) requirements.
How is your information collected and who is collecting it?
We will collect Data about you from the following sources:
- Directly from you via registration forms, email or written; (for example, when you create an account, make a payment, tell us about your preferences or respond to our campaigns, communicate with us, or use our Site);
- From our clients and partners (with whom we may have a direct relationship with, for example as a third-party store/site or a lender) who we have shared your information with in order for us to provide services to you.
- JO1N will collect information relating to your interactions on the Site and from cookies and tracking devices on your devices where you have permitted their use;
- All other information that is collected by us is information that you provide to us yourself, or that we have received from one of our clients (as set out above).
We will collect the following types of information:
| Type of Data | Description |
|---|---|
| Your personal and contact details | Information including your name, date of birth, home address, email address, telephone number, ID details, employment details. |
| Account information | Information about your account with us, including unique account number, unique customer identification, payment method information, marketing preferences, complaints details and any notes added to your account. |
| Visual images | Such as videos and photographs of you provided in your interactions with us in social events we host and your profile image on social media if you choose to enable this through your social media account. |
| Financial information | Such as information that allows us to understand your creditworthiness or your payment method, including bank account or payment card details. |
| Transactions and account history | Such as which transactions you have made. We will also receive information about you from any third-party brokers or lenders. |
| Lifestyle and demographic | Such as information available publicly on your social media profile where you connect with or contact us through your social media account. |
| Your communications via our Site | Such as chat conversations via the Site your recorded telephone conversations with our customer support staff and emails. |
| How you use the Site | Such as which pages you visit, which content you view and what links and buttons you click. This information may be collected through cookies or similar technologies. For more information, please see our Cookie Notice. |
| General Location information | The device or computer you use to access the Site will provide us with your IP address. The IP address tells us which city, state or country you are accessing the Site or Apps from but does not give us detailed information about your location. |
| Device and other technical information | Such as the unique device identifier and other information about the device’s hardware and software. |
| Advertising and direct marketing preferences and responses | Such as your interaction with offers and competitions, including any requests to stop receiving marketing communications. This information may be collected through cookies or similar technologies. For more information, please see our Cookie Notice. |
| Sensitive Information | We may also Process Data about you that is sensitive in order to meet our legal and regulatory obligations and to protect our business. This includes Data as required by the Financial Conduct Authority, the Anti-Money Laundering Regulations and the Proceeds of Crime Act and otherwise to fulfil our legal and regulatory obligations as a money services business. This also includes biometric data (such as through photograph and CCTV) and information about suspected fraud, theft or offences. If you come to an event that we host, this also includes information you provide (such as dietary preferences or disability information). |
How do we use your information and on what basis do we process it?
We use your Data in the following ways, and for the following reasons:
| What we use your Data for | The basis on which we can use your Data |
|---|---|
| To register you as a new user on the Site. | We need to Process this information to meet our contractual obligations. |
| To allow you to use our services (including managing your payments). | We need to Process this information to meet our contractual obligations and to comply with our legal and regulatory obligations. |
| To communicate with you about updates to the Site, our services, and any changes to our terms and conditions or Privacy Notice. | We need to Process this Data to meet our contractual obligations; to comply with our legal and regulatory obligations; and it is in our legitimate business interests to keep accurate records. |
| To receive feedback from you on our products and services. | We need to Process this Data to meet our contractual obligations and it is in our legitimate business interests to understand how we can improve our products and services. You do not have to provide us with this information. |
| To run our promotional events such as competitions and offers which may be of interest to you. We may send you marketing material about our offers and events via email, text or phone. You may opt out of direct marketing at any time (see below). | We need to Process this Data as it is in our legitimate business interests to provide you with a personalised experience when you use our services. Where necessary, we Process this Data based on your consent. |
| To provide customer support services. | It is in our legitimate business interests to respond to any communications we receive from you. If you do not wish to provide us with this information, we may not be able to respond fully to your queries. |
| To train our staff (for example our customer service team). | It is in our legitimate business interests to provide you with a helpful service. |
| To maintain and administer our Site. | It is in our legitimate business interests to maintain our IT services, network security, to maintain our system; and we need to Process this information to comply with our legal and regulatory obligations |
| To improve our Site, products and services, and experiences, such as by understanding analytics. | It is in our legitimate business interests to better understand your preferences, update our Site and Apps, and develop our business strategy. |
| To comply with our legal and regulatory obligations as payment services operator. This may involve verifying your identity. | We need to Process this information to comply with our legal and regulatory obligations and it is in our legitimate business interests to prevent fraud and illegal activities on our Site. |
| To protect our business from money laundering, terrorist financing and other illegal activities. We may identify you electronically using technology such as cookies. | We need to Process this information to comply with our legal and regulatory obligations under a payment processor, anti-money laundering, anti-fraud and anti-terrorism laws. We also Process this information in the public interest and it is in our legitimate business interests to protect our business from any illegal or abusive use of our Site. |
| To provide you with advertising which is relevant to you, and to understand your advertising preferences. | It is in our legitimate business interests to understand how you use our Site and how we should develop our marketing strategy. |
| In relation with a legal action, or when acquiring or selling a business. | It is in our legitimate business interest to be able to protect ourselves through legal action and to develop the business through acquiring or selling parts of our business. |
Who will we share your information with?
We may share your personal information with the following categories of people/organisations:
- With our banks and other service providers who assist in providing support for our internal operations;
- With fraud prevention agencies such as CIFAS as outlined above;
- With service providers who assist in providing our services such as relevant agents, affiliates, introducers, investment providers;
- To relevant authorities, when legally required to do so, at the request of governmental authorities conducting an investigation;
- To other JO1N group companies and offices, including our office in the EU; and/or
- To a successor entity in connection with a corporate merger, consolidation, sale of assets or other corporate change which affects the operation of the website.
These disclosures will in some cases involve transferring your personal information overseas. If you are dealing with us within the European Economic Area (EEA) or the United Kingdom (UK), you should be aware that this may include transfers to countries outside the EEA / UK. Where required, when we transfer personal data to our affiliates, partners or our service providers, we will ensure that our arrangements with them are governed by appropriate safeguards or agreements on terms approved for this purpose by the European Commission and / or the relevant authority in the UK (as the case may be).
We use information about you only for our own purposes. We do not pass your information on to any third parties for marketing purposes unless we have specifically obtained your permission to do so.
What rights do I have and can I access the information held on me?
Under the GDPR and Data Protection laws, you have rights as an individual which you can exercise in relation to the information we hold about you.
- A right of access to the personal data that we hold about you, and to some related information, under applicable data protection law and regulation. We will provide you with one copy of your personal data free of charge, but we may charge you a fee to cover our administrative expenses if you request further copies of the same information.
- A right to require any inaccurate personal data that we hold about you to be corrected or deleted.
- A right to object to our use of your personal data for direct marketing purposes at any time.
- A right to object to our processing of some or all of your personal data (and require it to be deleted).
- A right to data portability, which means the right to receive your personal data in a structured, commonly used and machine-readable format.
You can also request access to your personal data or exercise your other individual rights by emailing us at privacy@jo1n.com
If you are accessing our services from the EEA, our representative in the EEA is LeagueLions and they can be contacted at info@leaguelions.co.uk
How long do you keep my information for?
We keep your information for a period of 5 years from the last time our client received services from us and it will be permanently deleted from our database after this. This is to comply with the Financial Conduct Authority’s record keeping requirements and the current UK Money Laundering Regulations, as well as our obligations under data protection laws and regulations.
Where we have received your personal information from our client, we will keep your information for a period of 5 years from the last time our client received services from us and it will be permanently deleted from our database after this.
Where do we store your information?
We primarily store and Process our Account data within the UK or the European Economic Area (“EEA”). However, if we transfer your Data outside of the EEA or UK, we ensure a similar degree of protection is afforded to it to safeguard your Data in accordance with Data Protection Legislation, which can include by: (i) ensuring that your Data is only processed in countries which provide adequate data protection laws (in accordance with the Data Protection Legislation); (ii) requiring recipients to sign up to strong contractual commitments that ensure the protection of your Personal Data (such as the EU Model Clauses); and/or (iii) taking any other measures that comply with Data Protection Legislation.
How is the information we hold protected?
With respect to security: We have advanced security measures in place in our physical facilities and industry leading security solutions across all of our technical systems to protect your information against security breaches, loss, misuse or alteration.
However, whilst the nature of the internet means that the transmission of information on the internet cannot be guaranteed as completely secure. We have implemented security measures to prevent your Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed, but any transmission is at your own risk.
We further endeavour to protect your information by:
- Only requesting information that is relevant for our purposes
- Try to keep information on you up to date and accurate
- Delete any information which is no longer relevant
- Protect your data against unauthorised use
Privacy policies of other websites
Our Site may contain links to other websites. This Notice only applies to our Site. If you click on a link to another website, you should read their privacy and cookie policies to understand how they Process your information.
Changes to this privacy notice
We may, from time to time, change or update this Privacy Notice in line with legal requirements or if our business changes. All changes to this Privacy Notice will be published on this page of the Site. Each change will become effective on publication. We recommend that you revisit and read this Privacy Notice regularly to ensure that you are up-to-date with the current terms.
This notice was last reviewed and updated in June 2021.
Any Questions?
If you have any questions or comments about this Notice, want to know more about how we use your Data, or want more information on your rights, please contact our Privacy Team by contacting: privacy@jo1n.com.
Complaints
If you have a complaint about how we Process your Data, please contact us at privacy@jo1n.com and will try to resolve this. However, if you feel that we haven’t addressed your concern in a satisfactory manner, EEA users can complain to their local data protection supervisory authority, but all other users can complain to the UK Information Commissioner’s Office (“ICO”) at www.ico.org.uk/global/contact-us.
You can read more about these rights here – https://ico.org.uk/your-data-matters/
Glossary
| Term | What this means |
|---|---|
| Data | Information relating to an identifiable person, who can be directly or indirectly identified in particular by reference to an identifier, or which is otherwise defined as ‘Personal Data’ under Data Protection Legislation. |
| Data Protection Legislation | Data Protection Act 2018, EU General Data Protection Regulation 2018 (GDPR), the Privacy and Electronic Communications (EC Directive) Regulations 2003, and any other applicable laws relating to the protection of Data. |
| Process, Processing or Processed | Accessing, collecting, obtaining, recording, holding, disclosing, using, altering, deleting, erasing or destroying Data, or carrying out any operation(s) on the Data or as otherwise defined under applicable Data Protection Legislation. |
This notice is effective from 14 June 2021.