What does this policy cover?
This policy describes how Jadala Corp (also referred to as “Jadala” , “we” or “us”) will make use of your data when you view, use, sign up for an account, edit or contribute to Jadala Corp properties, websites or applications, including Parlia.com.
This Policy also describes your data protection rights, including a right to object to some of the processing which Jadala carries out. More information about your rights, and how to exercise them, is set out in the “What rights do I have?” section.
What information do we collect?
We collect and process personal data about you when you interact with us through our websites or applications. This includes:
- your name, username and password,
- data to help us understand your demographic such as your age, gender and income;
- your email address,
- your bio that you share with us,
- your personal website or social media accounts,
- your political views,
- your religious and philosophical beliefs
- your ethnicity
- your opinions that you share with us,
- your marketing preferences, including any consents you have given us;
- your payment details (where you have purchased a product or service from us);
- information related to the browser or device you use to access our website; and
- your location.
Special categories of personal data
When you edit your profile to contain; or answer questions that may reveal your racial or ethnic origin, political opinions, religious or philosophical beliefs, health or sex life you are providing us with what is known as ‘special category’ data. The law requires enhanced protection for this data, for example we must seek your consent for processing (see below).
Our site and services are intended for users who are 18 years or older. Accordingly, we do not knowingly collect information from children under 13 years old. If we become aware that we have collected information from a child under 13 years old, we will delete such information from our records. If you are a parent or legal guardian and believe your child has given us information and you did not provide consent, please contact us at firstname.lastname@example.org.
What information do we receive from third parties?
We receive information about you from third parties and combine it with the information you provide to us to build a profile about you (e.g. social media; marketing information providers; etc.) We use this profile to personalise your Parlia feed and help us to decide what your interests are so that we can suggest the most relevant questions and content to you. If you want to know more about this profiling, you can contact us using the contact details below.
Where we combine data and build a profile about you, we may generate new personal data about you. We will use and store that data in the ways set out in this notice.
Where it is relevant to our research partners, we may collect information from public registers and combine it with information we hold about you.
Where we work with research partners, they may provide us with the outcome of their research.
How do we use this information, and what is the legal basis for this use?
We process this personal data for the following purposes:
To fulfil a contract, or take steps linked to a contract: this is relevant where you sign up for and contribute to one of our sites or applications. This includes communicating with you and providing customer services.
As required by Jadala to conduct our business and pursue our legitimate interests, in particular:
- we will use the information you provide to build Parlia as the encyclopedia of opinion;
- we will use your information to manage your account and provide any products and services you have requested, and respond to any comments or complaints you may send us;
- we will use your information to build a profile about you so that we can identify questions, surveys and research projects that may be of interest to you or that our research partners may be interested in receiving your feedback on;
- we will use your information to keep track of how you are interacting with us so that we can redeem any relevant incentives we have offered to you;
- we monitor use of our websites and online services, and use your information to help us monitor, improve and protect our products, content, services and websites, both online and offline;
- we use information you provide to personalise our website, products and services for you;
- if you provide a credit or debit card as payment, we also use third parties to check the validity of the sort code, account number and card number you submit in order to prevent fraud (see data sharing below);
- we monitor user accounts to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law;
- we use information you provide to investigate any complaints received from you or from others, about our website or our products or services;
- we will use data in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation);
- we use data of some individuals to invite them to take part in market research; and
- we may use your information to produce pseudonymised respondent data for our research partners.
Where you give us consent:
- where we process special categories of data (see above) we do so on the basis of your explicit consent;
- we will send you direct marketing in relation to our relevant products and services, or other products and services provided by us, our affiliates and carefully selected partners;
- we place cookies and use similar technologies in accordance with our Cookies Policy and the information provided to you when those technologies are used; and
- on other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time.
For purposes which are required by law:
- for example, where we need parental consent to provide online services to children, we may collect and process the information of the relevant parent.
In response to requests by government or law enforcement authorities conducting an investigation.
Relying on our legitimate interests
We have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests, which we have described above. You can obtain information about our balancing tests by contacting us using the details set out later in this notice.
Withdrawing consent or otherwise objecting to direct marketing
Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by following the instructions in the communication where this is an electronic message, or by contacting us using the details set out below.
Who will we share this data with, where and when?
Sharing with third parties
We will share your personal data with our subsidiary Jadala Ltd. based in the UK for development of our website services, traffic analysis, and for marketing and communication activities.
We share your information with our research partners including research institutions, think tanks and commercial organisations. We generally do this on a pseudonymised or anonymised basis and we have contractual protections in place to prevent our research partners from attempting to re-identify you. Sometimes it benefits our research partners to combine the information we have about you with information they hold about you, in which case we will ask for your permission before we provide any information they can use to directly identify you.
Personal data will also be shared with third party service providers, who will process it on behalf of Jadala for the purposes identified above. In particular, we use third party providers of website hosting, maintenance, site development, website improvements & user experience optimization, speed improvements, performance, site security, cookie consent, traffic analysis and anonymisation and aggregation of your responses to questions and surveys.
Personal data may be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws.
In the event that the business is sold or integrated with another business, your details will be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business.
Sending your data to other countries
Data may be sent outside the EEA to the USA in working with other companies in the Jadala group some of our research partners, service providers for the delivery of our services.
Where information is transferred outside the UK and the EEA, and where this is to a stakeholder or vendor in a country that is not subject to an adequacy decision by the EU Commission or equivalent decision in UK law, data is adequately protected by standard contractual clauses approved by the relevant body in the UK (the UK government or the ICO) or EU (the European Commission), or a partner or service provider’s Processor Binding Corporate Rules. A copy of the relevant mechanism can be provided for your review on request to email@example.com.
What rights do I have?
If you are a California resident, please see our California Rights section below. If you are located in the EEA or the UK, you have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this data to another controller.
In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in both the GDPR and in the Data Protection Act 2018. We will inform you of relevant exemptions we rely upon when responding to any request you make.
To exercise any of these rights, or to obtain other information, you can get in touch with us – or our data protection officer – using the details set out below. If you have unresolved concerns, you have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred.
Your California Privacy Rights
If you are a California resident, you may have additional rights under the California Consumer Privacy Act (“CCPA”). “Personal information,” as used in this section, has the meaning found under Sec. 1798.140(o) of the California Consumer Privacy Act (“CCPA”).
To the extent we collected your personal information while you were acting in your capacity as an owner, director, officer, employee, or contractor of a business (our “B2B Contacts”), then these California Specific Rights do not yet apply to you.
Additionally, if we collected personal information about you in your role as an applicant, employee, or independent contractor, this policy does not apply to you.
Right to Know
You may have the right to request more information about how we have handled your personal information in the previous 12 months, including:
- The categories and specific pieces of personal information we collected about you;
- The categories of sources from which we collected that information;
- Our business or commercial purpose for collecting that information;
- The categories of third parties, if any, with whom we shared that information;
- The categories of personal information we disclosed about you for a business purpose; and
- If applicable, the categories of personal information we sold about you and the categories of third parties to which we sold the personal information.
Right to Access
You may have the right to receive a copy of your personal information. You may exercise this right twice per 12-month period.
Right to Request Deletion
Under certain conditions, you may have the right to request that we delete your personal information. However, we may decline to process this request if we believe we have an applicable exception under the law.
Right to Opt-Out of Sale
The CCPA requires notice and an opportunity to opt-out from certain disclosures of personal information considered to be a “sale” under the law. To the extent we are considered to be “selling” your personal information, you have the ability to opt-out by modifying your cookie settings.
In the previous 12 months we have sold the following categories of personal information via cookies:
Your marketing preferences.
Our site is not intended for use by individuals under the age of 18. Accordingly, we do not knowingly collect, disclose, or sell information from individuals under 16 years old.
Disclosure of Personal Information for a Business Purpose
As stated above, when we share personal information with third parties it is typically anonymized or pseudonymized. In the previous 12 months we have disclosed the following information for our business purposes:
Account data – to our service providers so that they can perform services on our behalf.
To exercise any of the above rights, or to obtain other information, you can get in touch with us – or our data protection officer – using the details set out below.
Before responding to your request, we must first verify your identity using personal information you recently provided to us. If we are not able to verify your request we will contact you for more information. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for the denial.
In order to verify your identity we need you to provide us with the your log-in details.
For account creation and any contributions to the site, including wiki editing or opinion contribution the provision of information is mandatory: if relevant data is not provided, then we will not be able to provide basic site functionality, or services. All other provision of your information is optional. This does not affect your right to withdraw your consent to processing and our obligation to stop processing any data that relies on your consent.
How do I get in touch with you?
We hope that we can satisfy queries you may have about the way we process your data. If you have any concerns about how we process your data, or would like to opt out of direct marketing, you can get in touch at firstname.lastname@example.org or by writing to Jadala Ltd, Somerset House Exchange, The Strand, London W1R 2LA.
## Which Jadala entity is my data controller, and which affiliates might my data be shared with?
The data controller for your information is Jadala, Ltd., Somerset House Exchange, The Strand, London WC2R 1LA. email@example.com
We may share your data with our US entity Jadala Corp, 251 Little Falls Drive, City of Wilmington, Delaware 19808, United States. firstname.lastname@example.org
How long will you retain my data?
Parlia is an encyclopedia of opinion. In order to fulfil this purpose we will retain the data you provide relating to your profile and the questions you ask and answer indefinitely, or until you ask us to stop (which you can do by contacting us using the details below).
Where we otherwise process your data, we do this for as long as you are an active user of our sites and for 10 years after this.
Where we process personal data with your consent or for marketing purposes, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely so that we can respect your request in future.
Where we process personal data for site security purposes, we retain it for 12 months.
Where we process personal data in connection with performing a contract or for a competition, we keep the data for 10 years from your last interaction with us.