JMA EU Supplemental Privacy Terms

Last Updated:2022-06-02


This should be read in conjunction with our Privacy Policy.

This privacy notice explains how your data is collected, used, transferred and disclosed by JMA. For the purpose of EU law, JMA is the Controller of all personal data collected. It applies to data collected when you use our websites, software or mobile phone applications, and when you interact with us through email, or phone.

The personal data we collect

Personal data means any information about an individual from which that person can be identified. It does not include anonymised data, where the identity and identifying information has been removed, and cannot be re-identified.

While our website is designed for a general audience, we will not knowingly collect any data from children under the age of 13 or sell products to children. If you are under the age of 13, you are not permitted to use or submit your data to the website.

The following groups of personal data are collected:

  • Identity Data includes information such as: first name, last name, and title.
  • Contact Data includes information such as: email address, billing or donor address, and telephone number.
  • Financial Data includes information such as: donations you have made, payment card details and bank account.
  • Transaction Data includes information such as: payments to and from you and details of other products and services you have obtained from us, correspondence or communications with you in respect of your orders and your work with us.
  • Technical Data includes information such as: details of the device(s) you use to access our services, your internet protocol (IP) address, login data, your username and password, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform.
  • Usage Data includes information such as: how and when you use our website/app, how you moved around it, what you searched for; website/app performance statistics, traffic, location, weblogs and other communication data; and details of any other JMA products and services used by you.
  • Marketing and Communications Data includes information such as: your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data where this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

How we use your data

The legal basis for processing your personal data

We will only collect and process your personal data where we have a legal basis to do so. As a data controller, the legal basis for our collection and use of your personal data varies depending on the manner and purpose for which we collected it.

We will only collect personal data from you when:

  • we have your consent to do so, or
  • we need your personal data to perform a contract with you. For example, to process a payment from you, fulfil your order or provide customer support connected with an order, or
  • the processing is in our legitimate interests and not overridden by your rights, or
  • we have a legal obligation to collect or disclose personal data from you.

Uses made of your personal data

Your personal data is used by JMA to support a range of different activities. These are listed in the table below together with the types of data used and the legal bases we rely on when processing them, including where appropriate, our legitimate interests. Please be aware that we may process your personal data using more than one lawful basis, depending on the specific activity involved. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.


We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we wish to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. We may process personal data without your consent, in compliance with the above rules, where this is required or permitted by law.

If you have any questions about how JMA use any of your personal data, please contact our Data Protection Officer, Joseph Murray at privacy@JMAConsulting.biz.

How long we keep your data for

We will keep your personal data for no longer than is necessary for the purpose(s) it was provided for and to meet our legal obligations. Further details of the periods for which we retain data are available on request.

Our use of analytics and targeted advertising tools

We use a range of analytics to evaluate use of our website content, deliver relevant content to you in marketing communications (where applicable), and to measure the effectiveness of the content provided. For example, we may use tools such as Google Analytics to target and improve our marketing strategies and website content.

Your data and countries outside of Europe

The personal data we collect from you may be transferred to, and stored at, destinations outside the European Economic Area ("EEA") using legally provided mechanisms to lawfully transfer data across borders. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. We will take all steps necessary to ensure that your data is treated securely and in accordance with this privacy notice.

Whenever we transfer personal data outside the EEA, we will ensure a similar degree of protection is afforded to it by ensuring appropriate safeguards, as required by law, are in place. This may include using specific contractual clauses approved by the European Commission which give personal data the same protection as it has in Europe. More information about these is available here

Please contact us if you want further information on the countries to which we may transfer personal data and the specific mechanism used by us when transferring your personal data outside the EEA.

Your Rights

You have several rights under the data privacy legislation. This includes, under certain circumstances, the right to:

  • request access to your personal data,
  • request correction of your personal data,
  • request erasure of your personal data,
  • request restriction of processing of your personal data,
  • request the transfer of your personal data,
  • object to processing of your personal data,
  • request human intervention for automated decision making.

Brief details of each of these rights are set out below. If you wish to exercise any of these rights, please email us at privacy@JMAConsulting.biz.

Request access to your personal data

You have the right to obtain a copy of the personal data we hold about you and certain information relating to our processing of your personal data.

Request correction of your personal data

You are entitled to have your personal data corrected if it is inaccurate or incomplete. You can update your personal data at any time by logging into your account and updating your details directly, or by emailing us at insert.

Request erasure of your personal data

This enables you to request that JMA delete your personal data, where there is no good reason for us continuing to process it. 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.

Request restriction of processing of your personal data

You have a right to ask JMA to suspend the processing of your personal data in certain scenarios, for example if you want us to establish the accuracy of the data, or you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Where processing is restricted, we are allowed to retain sufficient information about you to ensure that the restriction is respected in future.

Request the transfer of your personal data

You have the right to obtain a digital copy of your personal data or request the transfer of your personal data to another company. Please note though that this right only applies to automated data which you initially provided consent for us to use or where we used the data to perform a contract with you

Object to processing of your personal data

You have the right to object to the processing of your personal data where we believe we have a legitimate interest in processing it (as explained above). You also have the right to object to our processing of your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your data which override your rights and freedoms.

Request human intervention for automated decision making and profiling

You have the right to request human intervention where we are carrying out automated decision making when processing your personal data. This form of processing is permitted where it is necessary as part of our contract with you, providing that appropriate safeguards are in place or your explicit consent has been obtained.

We will try to respond to all legitimate requests within one month. Occasionally, it may 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. We may need to request specific information from you to help us confirm your identity and ensure your right to exercise any of the above rights. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

Right to lodge a complaint

If you have any concerns or complaints regarding the way in which we process your data, please email us directly at privacy@JMAConsulting.biz. You also have the right to make a complaint to the ICO (the data protection regulator in the UK), if you are a resident of the UK and to your national data protection authority if you are a resident of the EU. (For a list of EU National data protection authorities see: https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens/redress/what-should-i-do-if-i-think-my-personal-data-protection-rights-havent-been-respected_en. We would, however, appreciate the chance to deal with your concerns before you approach any regulator, so please do contact us in the first instance.

How to contact us

We welcome feedback and are happy to answer any questions you may have about your data.

Please send any questions, comments or requests for more information to our nominated representative and Data Protection Officer Joseph Murray, who can be contacted at privacy@JMAConsulting.biz.

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