Privacy policy

Last updated on: 30 March 2023

JMM PUBLISHING LTD

The address 167-169 Great Portland Street is located in London, postal code W1W 5PF.

Company number 12642117 and VAT GB 364 3536 90

Browsing the Site and using its services involves the collection and processing of Users' personal data. This has made it essential to establish a Personal Data Protection Policy in order to ensure compliance with the directives relating to the processing of personal data, as defined by current laws and regulations.

The Site's Confidentiality Policy has been drawn up in compliance with the directives of the Data Protection Commission (CPD). It aims to inform users about the processing of their personal data and the commitments made and measures implemented to ensure the protection of the personal data of visitors to the Site. This policy has been drawn up in accordance with the following rules:

Personal Information Safeguarding Legislation 2018;

The European Personal Data Regulations 2018;

Legislation implementing the European Data Protection Regulation 2018.

The version presented on the Site represents the policy currently in force. The Seller may modify it at its discretion to comply with current legal requirements. In the event of a change to the Privacy Policy, Users will be informed and asked to agree to the new provisions.

By browsing our Site, Users acknowledge that they have read, understood and agree to our privacy policy. If you have any questions about this policy, please contact : contact.urqi1@gmail.com.

Personal information refers to any information that directly or indirectly identifies a person (surname, first name, email address, telephone number, address, etc.).

In this regard, the RGPD characterises personal information as follows: "any data relating to a recognised or recognisable individual (referred to as a 'data subject'); a 'recognisable individual' is any individual who can be identified, directly or indirectly, in particular by means of an identifier such as a name, an identification number, location information, an online identifier, or by one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual".

Under Article 8 of European Regulation 2016/679 and the Data Protection Act, only adolescents aged 15 and over are allowed to give their consent to the processing of their personal data.

Users under the age of fifteen (15) are asked to obtain the authorisation of a legal guardian, as required by the Seller, for their personal information to be collected and for them to be able to access the services offered by the Site.

The Seller cannot be held responsible if a user provides personal data relating to a minor under the age of fifteen (15).

Your agreement is required.

When using the Site, the User is required to provide certain personal information on several occasions (for the purposes mentioned in article 5). By transmitting this information, the User therefore gives his/her authorisation for the Seller to collect and use his/her personal data, solely for the purposes specified in article 5 of the Policy. This authorisation, combined with other justifications, constitutes the legal basis for the processing of the data collected.

The Seller undertakes to collect and process only the data essential for the purposes specified. We promise our Users that we will never use their data for purposes other than those specified here. In the event that a new service or functionality requiring the use of additional data is introduced on the Site, we undertake to obtain the consent of our Users again before launching this new service.

Whenever the Site handles personal data, the Seller undertakes to take all necessary precautions to ensure the accuracy and adequacy of the personal data with regard to the purposes for which it is used.

We collect the User's information solely for the following purposes:

5.1 Account creation option

Users can register on the site by creating an account. To do so, they must provide the following information: surname, first name and e-mail address. This information is collected for the following purposes:

• Confirmation that their account has been registered;
• Setting up a user account ;
• Interactions with the Customer ;
• After-sales service management.

The execution of a contract constitutes the legal basis, following the completion of an order, with the acceptance of these conditions by the party concerned.

5.2 Completing the order

To place an order on the Site, Customers must provide the following information: surname, first name, e-mail address and billing address.

User information and communication data are used exclusively for the purposes of :

• Confirmation of the customer's order ;
• Execution of the customer's order ;
• Delivery of services included in the order ;
• Post-sales customer service proposal.

Customers are informed that when they place an order, they will receive transaction-related communications from the Vendor (such as invoices, password changes and personality test results). They may unsubscribe from these communications at any time by following the instructions provided in the e-mails sent by the Vendor.

The legal basis is based on the fulfilment of a contract following the issue of an order, the latter being in accordance with these terms.

5.3 Payment of benefits

Payment for purchases on the Site is made via our payment service provider STRIPE, which manages the Customer's payment information as the party responsible. The Seller does not have access to the Customer's payment information.

5.4 Subscription

When the Customer makes a purchase on the Site, they are automatically subscribed to the Vendor's Subscription in accordance with the General Terms and Conditions of Sale (GTCS). If the subscription is not cancelled within 24 hours of being taken out, it will be automatically renewed each month by tacit agreement.

The information provided by the Customer at the time of ordering is that used to finalise the subscription and serves the following purposes:

• Offer registration services ;
• Subscription administration (billing, cancellation, renewal) ;
• Provide after-sales support.

5.5 Contact form

A contact form is available on the Site. In order to process his request, the User is required to indicate his surname, first name, e-mail address and telephone number. Only the User's personal and communication details will be used for the purposes of :

• Managing user requests ;
• Provide a response to the user's request, based on the user's consent.

5.6 Analysis

When visiting the Site, Users may be asked to enter their personal connection details (cookies, tracers).

Connection information and navigation data are used exclusively for statistical studies (analysis of site activity and improvement of the user experience) and for other purposes described in the cookie policy.

The procedure is essential to meet the Seller's legitimate objectives, in particular to provide Users with an optimised and smooth browsing experience.

Connection data is also used to prevent and combat computer fraud.

The legal basis is based on compliance with a legal constraint.

We scrupulously respect the legal data retention periods, retaining Users' information only for as long as is strictly necessary to achieve the purposes for which it was collected.

The retention periods are defined as follows:

• Identity information of non-customer Users (surname, first name): this is deleted or rendered anonymous three (3) years after the last exchange with the User, unless the User has made a request (in accordance with the RGPD) which has led to the deletion of his/her information;

• Contact information for non-customer Users (email, telephone number, physical address): this is deleted or made anonymous three (3) years after the last exchange with the User, unless the User has made a request (in accordance with the RGPD) which has resulted in the deletion of their information;

• Information concerning Customers who have made a purchase: this is deleted five (5) years after the end of the commercial relationship with the Customer, unless the Customer has made a request (in accordance with the RGPD) for the deletion of his/her data;

• Connection data: stored, in accordance with the cookies policy, for a period of up to 13 months (unless otherwise stated in article 13).

When formulating our data management policy, we put in place a reference framework for the retention period of information, designed following the advice of the Data Protection Commission.

In addition, the Seller may keep personal data in order to comply with its legal or regulatory obligations, to facilitate the exercise of users' rights, or for statistical purposes. When the retention period for personal data expires, it will be deleted or made anonymous.

The information collected via the Site is intended solely for the recipients mentioned.

7.1 Website hosting

The Site is hosted by Namecheap, located at 8 rue de la Ville l'Évêque, 75008 Paris. https://www.namecheap.com/

The hosting operator accesses information as part of its duties dedicated to hosting the Site. Its access to user data is restricted and linked to the provision of its services, with a contractual obligation to comply with the laws in force relating to the protection of personal data.

See the Namecheap policy for more information.

7.2 Third-party suppliers

The Site and the Seller use services provided by third parties to offer certain functionalities. These third-party services have limited access to Users' information solely for the purpose of providing these services and are contractually bound to comply with the laws in force on the protection of personal data.

Payment processing for orders placed on the Site is handled by Stripe.

Statistical information relating to users, such as cookies, is used to optimise the user experience and develop the site's capabilities. Users are advised to consult the site's cookies policy.

7.3 Legal responsibilities

The Vendor may also share information with third parties and competent authorities in order to comply with legal, judicial, fiscal or regulatory requirements. It assures Users that personal data will never be passed on to an unauthorised third party without first obtaining the User's consent, which must be voluntary, informed, explicit and given in writing.

The Seller is prohibited from handling, receiving or redirecting data collected from its users to a country outside the European Union or considered "non-compliant" by the European Commission without first notifying the data holder and receiving its consent.

The Seller has implemented all necessary and appropriate precautionary measures, in accordance with current standards, to ensure the protection of your data within a secure framework, thus preventing its destruction, loss, modification, disclosure or unauthorised access. Despite our best efforts, it is important to note that no means of transmission via the Internet or method of electronic storage is infallible. Consequently, we cannot promise total security. In the event of a security breach, we will notify affected users so that they can take the necessary measures. Our incident notification methods are designed to comply with our legal obligations at both national and European level.

If the integrity and confidentiality of your information is compromised, the data controller promises to follow established procedures in accordance with the Data Protection Act 2018 and the General Data Protection Regulation (GDPR).

The Seller shall refrain from any resale or outsourcing of User information.

9.1 Right of access, modification and deletion

Users may consult, update, modify or request the deletion of data concerning them by sending an e-mail to the person responsible for processing personal data, specifying the purpose of the request to the following e-mail address: contact.urqi1@gmail.com.

9.2 Transferability rights

The User has the right to request the portability of his/her personal data, held by the Site or by the Seller, to another site, by sending a request for the portability of his/her personal data to the data controller, by sending an e-mail to the address provided above.

9.3 Right to restrict and object to data processing

The User has the right to request the limitation of or to oppose the processing of his/her data by the Seller, without the latter being able to refuse, unless it can be shown that there are legitimate and overriding reasons, which may take precedence over the interests and rights and freedoms of the User.

The User must make a request to the data controller to limit the processing of his/her personal data, by sending an e-mail to the address provided above.

9.4 Right not to be subject to a decision taken solely on the basis of automated processing

In accordance with the provisions of Regulation 2016/679, the User has the right not to be subject to a decision based exclusively on an automated process if the decision produces legal effects concerning him or her or significantly affects him or her in a similar way.

9.5 Right to decide what happens to data

Users are reminded that they can organise what the future of the collection and processing of their data should be in the event of their death, in accordance with the Data Protection Act 2018.

10.1 How to assert your rights

To exercise any of your rights, simply :

• Compose a letter to the Seller and send it to the Seller's main office address;
• Or send an e-mail to the following address contact.urqi1@gmail.com.

By providing your surname, first name and address and attaching proof of identity.

Carlo Ela is in charge of data processing and can be contacted at the following address contact.urqi1@gmail.com.

Requests will be processed within a period of one month, unless the Seller presents a valid and justified reason for extending this period.

10.2 Appeal to the Data Protection Commission

If the Seller does not meet the User's expectations, the User may appeal to the Data Protection Commission via https://www.dataprotection.ie/.

11.1 What does a Cookie mean?

Users are advised that a cookie is a small file saved on their device (whether a computer, tablet or mobile phone) by our Site when it is consulted. This file does not contain any personal data, but establishes a connection between the user's device and their browsing choices and experience on our Site, such as location, language chosen or letter size.

11.2 User agreement

When using "cookie" type files that require personal information to be stored and examined, the User's consent is systematically sought. This consent remains in force for thirteen (13) months, with certain exceptions mentioned in the table in Article 13, after which the User's consent must be obtained again.

In accordance with Decision S.I. No. 336/2011 - European Community Electronic Communications Networks and Services Regulations 2011 (Confidentiality and Electronic Communications), the Seller hereby notifies Users of the Site that cookies collect certain data stored in the memory of the hard disk. This data is used to create statistics relating to Site traffic and to offer tailored services based on the choices made during previous visits.

A warning banner, displayed as an alert, is addressed to each User who visits the Site to ask them whether they accept cookies before continuing. To ensure that the User's consent is clear, informed and unambiguous, this banner will remain visible until the User has made their choice and navigated further on the Site.

Cookies will not be deposited or read without the User's prior consent:

• When someone accesses the Site, whether on the home page or on a specific page via a search engine, and decides not to continue browsing: doing nothing cannot be considered as an expression of will;
• Or if the user selects the link in the banner to adjust the cookie settings and chooses, where applicable, not to authorise cookies.

Our site uses and collects cookies for the following reasons:

• To analyse statistical data and information concerning the flow of visitors to our site in order to improve its effectiveness;
• To offer our visitors a smooth browsing experience by adjusting the appearance of our Site according to the display parameters of the user's device;
• To keep the information entered on the Site by the User.

All Users have the option of refusing the installation of "Cookies" by adjusting their browser settings as follows:

• Launch a browsing session in private mode ;
• Set your cookies using the "Cookies" widget on the main page of our site;
• Adjust your computer settings so that you are notified to accept, personalise or decline cookies for each site visited or in general;

Or any other method available to the User.

The User may, at any time, communicate and change his/her preferences concerning Cookies. The Seller shall not be held responsible for the effects on the operation of the Site and the services offered resulting from :

• Users who reject cookies ;
• And/or the site being unable to record or access the Cookies necessary for its operation due to the User's decision.

Users can set their browser parameters to define their preferences regarding the use of cookies:

Concerning Microsoft EdgeTM : https://support.microsoft.com/en-us/microsoft-edge

For SafariTM : http://docs.info.apple.com/article.html?path=Safari/3.0/fr/9277.html

For ChromeTM : http://support.google.com/chrome/bin/answer.py?hl=fr&hlrm=en&answer=95647

For FirefoxTM : http://support.mozilla.org/fr/kb/Activer%20et%20d%C3%A9sactiver%20les%20cookies

For OperaTM, visit the following link: http://help.opera.com/Windows/10.20/fr/cookies.html

Users have the option of customising their browser to accept or reject Cookies individually before they are installed, or to delete Cookies from their device. It is important to note that if the user configures their browser to reject Cookies, some parts of our Site may not be functional, and neither the Seller nor the host can be held responsible for this limitation.

The Seller has the right to change this Policy at any time. If changes are made to this Policy, they will be posted directly on the Site. If the User does not accept the terms of the updated policy, he or she may choose to stop using the Site's Services and no longer consult it.

By using this Site, the User confirms that he/she has read and understood our privacy policy and consents to its terms, including the collection and processing of his/her personal information and the use of cookies.