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What is this policy about?
- Welcome to the privacy policy for Njori Ltd. Njori Ltd, a private limited company incorporated and registered in England and Wales with company number 11082643, our registered office is at Prospect House, 50 Leigh Road, Eastleigh, United Kingdom, SO50 9DT (“us”, “we” or “our”). We respect your privacy and are committed to protecting your Personal Data. This privacy policy will inform you how we will use and disclose your Personal Data when you use our Services (regardless of where you log in from), we will explain your privacy rights and how the law in our jurisdiction protects you.
Definitions
- The definitions of the capitalised terms shall have the same meaning regardless of whether they appear in singular or in plural.
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The following capitalised terms shall have the following meanings
unless otherwise defined.
- “Account”
- means a personalised account created by our Customers to purchase our products;
- “Anonymous Data”
- means Personal Data that has been amended to the extent that it no longer contains any identifying information and thus, no longer constitutes Personal Data;
- “Comply with a Legal Obligation”
- means processing your Personal Data where it is necessary for compliance with a legal obligation that we are subject to;
- “Cookies”
- means small files of letters and numbers that we store on your browser or the hard drive of your Device if you agree. Cookies contain information that is transferred to your computer’s hard drive;
- “Customers”
- means a person who has created an Account with us to purchase anyone of our Products;
- “Data Controller”
- means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the way any Personal Data are, or are to be, processed as outlined in the Data Protection Legislation;
- “Data Processor”
- means any natural or legal person who processes the data on behalf of the Data Controller;
- “Data Protection Legislation”
- means all applicable data protection and privacy legislation in force from time to time in the UK including the General Data Protection Regulation ((EU) 2016/679); the Data Protection Act 2018; the Privacy and Electronic Communications Directive 2002/58/EC (as updated by Directive 2009/136/EC) and the Privacy and Electronic Communications Regulations 2003 (SI 2003/2426) as amended;
- “Device”
- means any electronic device, such as a computer, a phone or digital tablet, that is used to register and access your Account;
- “DO NOT TRACK (DNT)”
- means a concept which the internet industry has developed and implemented for allowing users to control the tracking of their activities across our Website;
- “Flash Cookies”
- means a text file that is sent by a web server when your browser requests content supported by Adobe Flash, a popular browser plug-in;
- “Legitimate Interest”
- means the interest of our business in conducting and managing our business to enable us to give you the best Service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interest. 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 otherwise required or permitted by law). You can obtain further information about how we assess our legitimate interest against any potential impact on you in respect of specific activities by contacting us;
- “Personal Data”
- has the meaning given to it in the Data Protection Legislation;
- “Performance of Contract”
- means processing your Personal Data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering such contract;
- “Product(s)”
- means the Njori Tempo, a smart induction cooker that enables Customers to measure, monitor and regulate temperature to compose perfect meals and other products developed and sold by us;
- “subsidiary or a holding company”
- means a subsidiary or a holding company (as the case may be) as defined in section 1159 of the Companies Act 2006;
- “Third – party Social Media Service”
- means any website or social network website through which a user can create or log in to their Account;
- “Website”
- means https://njori.com or any other website launched by us to sell and promote our Product.
Important information and who we are?
- We will collect, use and are responsible for certain personal data about you. When we do so we are subject to the Data Protection legislation, and we are responsible as ‘Data Controller’ of that Personal Data for the purposes of those laws.
- It is important that you read this privacy policy together with any other privacy policy or fair processing notice, which we may implement from time to time. This privacy policy supplements the other notices and is not intended to override them unless specifically stated.
- Our Products are not intended to be purchased by any persons under the age of 18.
- When you create an account with us or purchase anyone of our Products, we will automatically assume that we have your consent to process your Personal Data as described in this policy.
- You may change your mind at any time and withdraw your consent by contacting us. Your withdrawal will not affect the lawfulness of any processing carried out before you withdraw your consent.
Data controller
- Njori is the Data Controller in respect of certain Personal Data provided by its Customers.
- We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy, please use the details provided below to contact us with any queries you may have, including your request to exercise your legal rights.
- You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority 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.
- If you wish to contact us regarding your rights, we reserve the right to request copies of your identification or any other information that may be reasonably required to verify your identity.
Changes to your personal data
- It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if any aspect of your Personal Data changes during your relationship with us. This can be done by updating your details on your Account or by contacting us on the details below. Any previous data held on you will be deleted to the fullest extent possible.
Interacting with third party links
- Our Website may include links to third- party providers, plug-ins and applications. Clicking on any of these links or enabling those connections may allow third parties not associated with us to collect or share data about you. We do not control these third-party providers and are not responsible for their privacy statements.
- We encourage you to read the privacy policy of every website and application you visit. We accept no liability for any data that has been unlawfully processed by third parties as a result of you accessing these links.
Personal data that we collect
- Personal Data (also referred to as personal information) means any information about an individual from which that person can be identified. It does not include data where the identity has been anonymised.
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We may collect, use, store and transfer different kinds of
Personal Data about you, which include but are not limited to, the
following categories:
- “Aggregated Data”
- means data which could be derived from your Personal Data but is not considered Personal Data under the (which has been collected and processed lawfully) but is not considered to constitute Personal Data under the Data Protection Legislation. This is because the data does not directly or indirectly reveal your identity.
- “Contact Data”
- means your email address, telephone number, billing address and address for service.
- “Financial Data”
- means your bank account information and payment card details.
- “Identity Data”
- means your first name, maiden name, last name, username or similar identifier, marital status, date of birth and gender
- “Location Data”
- means the GPS technology we use to determine your current location. You can withdraw your consent at any time by disabling the settings.
- “Marketing and Communications Data”
- means your preferences in receiving marketing communications from us and our third parties and what are your communication preferences.
- “Profile Data”
- means your username and password, purchases made by you, your interests, preferences, feedback, and survey responses.
- “Special Categories of Personal Data”
- means Personal Data which is sensitive in nature and requires a higher level of protection. This means personal data about an individual’s: biometric data (where this is used for identification purposes); criminal convictions and offences; ethnic origin; genetic data; health data; political opinions; race; religious or philosophical beliefs; sex life; sexual orientation; or trade union membership.
- “Transaction Data”
- means data that includes details about any payments to and from you and the details of the products and/or Services you have purchased from us.
- “Technical Data”
- means internet protocol (IP) addresses, your log in data, browser type and version, time zone settings and location, browser plug-in types and versions, operating system and platform, and other technology on the devices Customers use to access their Account.
- “Usage Data”
- means information about how Customers use their Account to purchase our products, and Services.
- Other than background check and Location Data, we do not collet any Special Categories of Personal Data about you.
What if you do not provide personal data?
- In some circumstances, we need to collect Personal Data by law, or under the terms of a contract we have with you. If you fail to provide that data when requested, we may not be able to perform the contract which we have or are trying to enter into with you. In this case, we may have to cancel the products which you have ordered with us and terminate the User Terms we have in place with you.
- For the avoidance of doubt, we accept no liability for any losses arising from any inability to fulfil any contractual requirement as a result of your failure to provide the any Personal Data or payments required.
How your personal data is collected
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We collect most of this personal data directly from you—in person,
by telephone, text or email, via our Website, any websites or apps
which has been used in connection with our products. However, we
may also collect information:
- from publicly accessible sources, e.g. Companies House or HM Land Registry;
- directly from a third party, e.g: sanctions screening providers, credit reference agencies, customer due diligence providers;
- from a third party with your consent; and
- from Cookies on our Website.
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We collect most of this personal data directly from you—in person,
by telephone, text or email, via our Website, any websites or apps
which has been used in connection with our products. However, we
may also collect information:
How and why we use your personal data
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Under data protection law, we can only use your Personal Data if
we have a proper reason for doing so, most commonly, we will use
your Personal Data in the following circumstances:
- to comply with our legal and regulatory obligations;
- for the performance of our contract with you or to take steps at your request before entering into a contract;
- for our legitimate interest o0r those of a third party and your interests and fundamental rights do not override those interests; or
- where you have given consent.
- A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
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The table below explains what we use and process your Personal
Data for and our reasons for doing so:
Purpose/ Activity Type of data Lawful Basis for Processing Including Basis of Legitimate Interest To register you as a new Customer - Identity
- Contact
Performance of a contract with you. To process and deliver your order including: - Manage payments, fees and charges
- Collect and recover money owed to us
- Identity
- Contact
- Financial
- Transaction
- Marketing and Communications
- Performance of a contract with you; and
- Necessary for our legitimate interest (to recover debts due to us).
To manage our relationship with you which will include: - Notifying you about changes to our terms or privacy policy
- Asking you to leave a review or take a survey
- Identity
- Contact
- Financial
- Transaction
- Marketing and Communications
- Performance of a contract with you;
- Necessary to comply with a legal obligation; and
- Necessary for our legitimate interests (to keep our records updated and to study how Customers use our products/services).
To enable you to partake in a prize draw, competition or complete a survey - Identity
- Contact
- Financial
- Transaction
- Marketing and Communications
- Performance of a contract with you; and
- Necessary for our legitimate interests (to study how customers use our products, to develop them and grow our business).
To administer and protect our business and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) - Identity
- Contact
- Technical
- 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 reorganisation or group restructuring exercise)
- Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you - Identity
- Contact
- Profile
- Usage
- Marketing and Communications
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) To use data analytics to improve our Website, products/services, marketing, customer relationships and experiences - Technical
- Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy) To make suggestions and recommendations to you about goods or services that may be of interest to you - Identity
- Contact
- Technical
- Usage
- Profile
- Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our business) - We will only use your Personal Data for the purposes for which we collected it. There may be times where we consider it necessary to use your Personal Data for another reason which is compatible with the original purpose. We may process your Personal Data without your knowledge or consent, but only where it is compliance with the rules set out above. For further information on how your Personal Data may be used for another reason, please contact us.
- 1We may process your Personal Data without your knowledge or consent, in compliance with the above rules and where this is required by law. If we use your Personal Data for any unrelated purpose, we will contact you as soon as reasonably practicable.
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Under data protection law, we can only use your Personal Data if
we have a proper reason for doing so, most commonly, we will use
your Personal Data in the following circumstances:
Data security
- We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In additional, 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.
- We have put in place procedures to deal with any suspected breach of any Personal Data and we will notify you and any applicable regulator when we are legally required to do so.
Data retention
- By law we have to keep basic information about our Customers for six (6) years after the Customer deletes their Account for tax purposes. You can ask us to delete your data in some circumstances.
- We will anonymise your Personal Data for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
How long will we use your personal data for?
- In accordance with General Data Protection, we will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Once these have been satisfied, the Personal Data will either be deleted or amended to the extent that it would be considered Anonymous Data.
- We will consider the nature and sensitivity of the Personal Data and any potential risk of harm from unauthorised use or disclosure of your Personal Data when determining the appropriate retention period. We will consider other means and applicable legal requirements for when we process your Personal Data.
- You can ask us to delete your Personal Data. In some circumstances we may 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.
When will we disclose your personal data?
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We may have to share your Personal Data, including but not limited
to the following and for the purposes set out in the table in
Paragraph 10 above:
- External Third Parties;
- Internal Third Parties;
- Specific third parties listed in the table above;
- Third Parties we use to help deliver our Products to you e.g: payment service providers, warehouses and delivery companies;
- Any third party who help us run our business;
- Third Parities which have been approved by you, e.g: Social Media sites
- Credit reference agencies;
- Our insurers and brokers;
- Our banks; and
- Third parties top whom we may choose to sell, transfer, merge parts of our business or assets where we seek to acquire other businesses or merge with them. If a change takes place, the new owners may use your Personal Data under the same terms as set out in this privacy policy;
- All third parties are required to respect the security of your Personal Data and to treat it in accordance with the law. We will not allow our third-party service providers to use your Personal Data for their own purposes and without our instructions.
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We may have to share your Personal Data, including but not limited
to the following and for the purposes set out in the table in
Paragraph 10 above:
Your legal rights
- You have rights under the Data Protection Legislation in relation to your Personal Data.
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You have the right to:
- “Request access”
- to your Personal Data. This enables you to receive a copy of the Personal Data we hold about you.
- “Request correction”
- of the Personal Data that We hold about you. This enables you to have any incomplete or inaccurate data corrected, we may need to verify the accuracy of the new data you provide to us.
- “Request erasure”
- of your Personal Data. 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. Where We may have processed your information unlawfully or where We are required to erase your Personal Data to comply with the Data Protection Legislation. 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”
- only in circumstances where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where We are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that We have compelling legitimate grounds to process your information which override your rights and freedoms.
- “Request restriction of processing”
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This enables you to ask us to suspend the processing of your Personal Data in 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.
- “Request the transfer”
- We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. 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. In addition, this does not provide you with routine access to our systems and processes and only the extraction of your Personal Data.
- “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 or Services to you. We will advise you if this is the case at the time you withdraw your consent.
- In the event you wish to exercise your rights set out in the above table, please contact us.
- You will not have to pay a fee to access your Personal Data (or any other right) however, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive., Alternatively, we may refuse to comply with your request.
- We may implement our security measures, such as requesting specific information about you to ensure that your Personal Data is not disclosed to any unauthorised person. We may also contact you to ask you for further information in relation to your request to speed up our response.
- We will use all reasonable endeavours to respond to all legitimate requests within a reasonable time of the time we receive all of the information required to complete your request. Occasionally it may take us longer than expected 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.
Marketing and promotional offers
- By accessing our Website, and not opting out of our marketing and promotional offers, you are consenting us to use your Identity Data, Contact Data, Account Data, Technical Data, Usage Data and Marketing and Communications Data and form a view of Services that we think may interest you.
- You may withdraw your consent for us to contact you, at any time by selecting the opt out link on any of our marketing emails or contacting us.
- It is possible that you may receive marketing communications from us, if you have requested information on any of our Products or if you have used us before or if you have provided your details to us when you have entered into any competition or registering for a promotion. In each case, you will be consenting for us to use your Personal Data to contact you, prior to you exercising your right to opt out.
Changes to this policy
- We may change this policy from time to time, when we do, we will inform you by posting an update on our Website or by emailing you to the email address linked to your Account.
How to contact us
- Please contact us by post or email if you have any questions about this privacy policy or the information, we hold about you.
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Our contract details are:
Write to us at: Prospect House, 50 Leigh Road, Eastleigh, United Kingdom, SO50 9DT
Email us at: info@njori.com