Privacy Policy
1. **INTRODUCTION**
1.1. We are committed to respecting and protecting your privacy. This Privacy Policy sets out the type of information we collect from you and what we do with that information.
1.2. Please read this Privacy Policy carefully as by visiting our website (https://getjarvis.com), using our mobile Application(s) (App) or opening a Pension Jar account, you will be bound by the terms of this Privacy Policy.
1.3. We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website.
1.4. Our website incorporates privacy controls which affect how we will process your personal data.
1.5. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information. You can access the privacy controls via account settings within the App.
1.6. If you have signed up to a Pension Jar account this Privacy Policy should be read together with our Customer Terms & Conditions.
1.7. In this policy, “we”, “us” and “our” refer to Pension Jar.
2. **ABOUT US**
2.1. For the purpose of this Privacy Policy and the Data Protection Act 2018, Pension Jar Limited of 238 Green Lane, London, SE9 3TL is the ‘data controller’.
3. **INFORMATION WE MAY COLLECT FROM YOU**
3.1. During the course of opening a Pension Jar account, the information you give to us may include your name, address, email address, phone number, date of birth, National Insurance number, bank account and other financial details, copies of personal identification documents (such as your passport or driving licence) and photographs or other descriptions of your likeness. You may also provide us with certain information by filling in other forms, entering competitions or promotions or by corresponding with us by phone, email, or text message.
3.2. When you visit our website or use our App, we may collect or receive your IP address, URL, browser information, plug-in types, operating system and platform, as well as your login information. We work closely with third parties (e.g., business partners, technical, payment and delivery service providers, advertising networks, tracking and analytics providers (including Google), search information providers, lead generation agencies, and credit reference agencies) and may receive information about you from them, such as your clickstream through our website and App, the products you viewed, and page interactions.
3.3. We, or our third-party providers, may also use cookies to collect information about you. This helps us to provide you with a good experience while you use our website and our App. See our Cookie Policy for more details.
4. **WHAT WE USE YOUR INFORMATION FOR**
4.1. We use the information we collect about you to:
- a. Verify your identity and to conduct anti-money laundering checks.
- b. Provide you with the products and services you have requested.
- c. Carry out our contractual obligations in relation to contracts entered into with you or with our business partners and service providers.
- d. Notify you about changes to our products or services.
- e. Ensure that content from our website and our App is presented in the most effective manner for you and your devices.
- f. Administer our website and App for internal operations such as troubleshooting, data analysis, testing, and research purposes.
- g. Help maintain the safety and security of our website and App.
- h. Make suggestions to you (and other customers) about our products or services via email, SMS, targeted social media, and our in-App secure notification center.
- i. Measure or understand the effectiveness of advertising we send to you and deliver relevant advertising to you.
5. **PROCESSING OF DATA**
5.1. We will access, utilize, and share the information as necessary to fulfill our contractual obligations to you or any subsequent requests for support by you, including sharing personal data with third-party entities as required.
5.2. We may process data about your use of our website and services ("usage data"). This data includes your IP address, geographic location, browser type and version, operating system, referral source, length of visit, page views, and navigation paths. The source of usage data is our analytics tracking system, and it may be processed to analyze website usage. The legal basis for this processing is our legitimate interest in monitoring and improving our website and services.
5.3. We may use third-party analytics services (such as Google Analytics) to evaluate your use of the platform. These services analyze performance metrics, compile activity reports, and evaluate mobile and internet usage. They use cookies and other technologies to analyze the data, and you consent to this processing per this Privacy Policy. For more information, see Google's Analytics page at https://www.google.com/analytics.
5.4. We may process your account data ("account data"). The data may include your name and email address for providing services, securing the website, maintaining backups, and communicating with you. The legal basis for this processing is the performance of a contract between you and us.
5.5. We may process your personal data that is provided during service use ("service data"). It may be processed for service delivery, ensuring website security, maintaining backups, and communication. The legal basis for processing is our legitimate interest, performance of a contract, and steps taken to enter into a contract.
5.6. We may process notification data for email communications and newsletters. The legal basis is consent.
5.7. We may process correspondence data, including the content and metadata of any communication. Website forms generate metadata, and this data may be processed for communication and record-keeping purposes. The legal basis is our legitimate interest in proper administration.
5.8. We may process personal data for the establishment, exercise, or defense of legal claims. The legal basis is our legitimate interest in legal rights protection.
5.9. We may process personal data to obtain insurance, manage risks, or obtain advice. The legal basis is our legitimate interest in protecting the business.
5.10. We may process personal data where necessary for compliance with a legal obligation or to protect your vital interests.
6. **DISCLOSING YOUR PERSONAL DATA**
6.1. Advertisers and advertising networks require information to select and serve relevant adverts to you and others. While we don't disclose information about identifiable individuals to advertisers, we may provide anonymized information.
6.2. Analytics and search engine providers assist us in optimizing our site.
6.3. If we sell or buy any business, we may disclose your personal information to prospective sellers or buyers.
6.4. If our assets are acquired, personal information will be transferred.
6.5. We will disclose your personal information if required by legal obligations, to enforce our agreements, or for fraud protection and credit risk reduction.
7. **SECURITY OF YOUR INFORMATION**
7.1. Once received, we use strict procedures to prevent unauthorized access. Unfortunately, data transmission via the internet isn't fully secure, so transmission is at your own risk.
7.2. Passwords and PINs used to access the App must remain confidential.
7.3. Our website hosting facilities are in the UK, and assets will transfer if acquired.
7.4. Personal data submitted for publication online may be accessible globally.
8. **RETAINING AND DELETING PERSONAL DATA**
8.1. Personal data processed for any purpose won't be kept longer than necessary.
8.2. We may retain personal data as needed for legal obligations or vital interest protection.
8.3. To request data erasure, contact us at support@pensionjar.com.
9. **CHANGES TO THIS PRIVACY POLICY**
9.1. Changes will be published on our website, so review periodically.
9.2. We will notify you via email if appropriate.
10. **YOUR INFORMATION RIGHTS**
10.1. You have the following rights regarding your data:
- a. **Right to access**: Request copies or modification of the data we hold about you.
- b. **Right to correct**: Rectify inaccurate or incomplete data.
- c. **Right to erase**: Request data removal from our systems.
- d. **Right to restrict**: Limit our data usage.
- e. **Right to data portability**: Move, copy, or transfer your data.
- f. **Right to object**: Oppose data usage for our legitimate interests.
10.2. For inquiries, exercising rights, or withdrawing consent, contact us at support@pensionjar.com.
