Privacy Policy

Last updated: 5th May 2023

Jellyfish Connect Ltd takes its responsibilities under data protection legislation seriously and respects the privacy of our customers. This Policy aims to clearly tell you how we collect, use and disclose your personal data in connection with the use of all websites, applications, and other online products and services provided by us that link to this Policy and all related subdomains and online and offline services related thereto.

This Privacy Policy contains the following sections:

• Who we are
• Purpose of this Privacy Policy
• How we collect your personal data
• Types of information we may collect about you, purposes for which we use your information and our legal basis to do so
• Cookies, similar technologies, and online advertising
• How do we help to keep your data safe and secure?
• Data retention
• Disclosing information to others
• Data transfers
• Your rights and choices
• Additional privacy information for California and other United States residents
• Questions
• Changes to this Privacy Policy

Who we are

Jellyfish Connect Ltd (‘Jellyfish’ or ‘we’, ‘our’ or ‘us’) has registered offices at 31 London Road, Reigate, Surrey, RH2 9SS, UK and the company number 6889858.

Jellyfish Connect Ltd consists of the following products and services (‘Services’):

• magazine.co.uk website and its associated magazine subscription websites.
• Pocketmags.com website and its associated digital magazine applications and digital publishing services.

Jellyfish Connect Ltd is registered with the Information Commissioner’s Office (with the registration number ZA192111), and abides by the requirements of the Data Protection Act 2018, the Privacy and Electronic Communications Regulations 2003, the General Data Protection Regulation (EU) 2016/ 679 (GDPR), and the UK GDPR.

Jellyfish Connect Ltd is the controller of your personal data provided to, or collected by or for, or processed in connection with the above Services. Each Service has its own Terms & Conditions which are entered into when making a purchase or creating an account.

Purpose of this Privacy Policy

We are committed to respecting and protecting the personal data gathered via our websites and applications whilst it is in our care, using it only in accordance with this Privacy Policy and our Cookie Policy. We collect your personal data because it helps us to understand your needs, improves our Services and guides the way in which we interact and communicate with you about our products and services now and in the future.

Please note that our Services may contain links to products and websites that are owned and operated by third parties. These products will have their own privacy policies which you should review if you choose to visit these products or websites. We are not responsible for the privacy practices of third parties.

In certain circumstances we will need to disclose your data to the owner of a product (‘Product Owner’) you have purchased from us to facilitate its fulfilment, in this case the Product Owner will be a data controller. In these circumstances, the Product Owner will handle your data according to their own Privacy Policy and may use your data for the purposes of sending occasional email communications relating to similar products and services if you have agreed to receive these. Should you subsequently wish to opt out of their email communications, you will need to unsubscribe from their emails directly. Further details will be included in the individual Service’s Terms & Conditions and at point of purchase.

How we collect your personal data

We collect personal data that you submit to us directly, such as when you register with us, when you purchase a product or subscription, and when you engage with us and our email correspondence.

We may also collect personal data automatically when you interact with one of our Services, for example when you browse our websites or applications.

Types of information we may collect about you, purposes for which we use your information and our legal basis to do so.

We collect both personal and anonymous data when you send us information or use one of our Services. Personal data is that which can personally identify you, such as name, email address, and unique device information. Anonymous data is that which cannot identify you and which is typically used in aggregate to better understand our customers. We may combine the information we collect through the Services with information we collect automatically or receive from other sources and use such combined information in accordance with this Policy. Your browsing activity may be tracked across different websites and different devices or apps. To do this our technology partners may disclose data, such as your browsing patterns, geo-location and device identifiers, and will match the information of the browser and devices that appear to be used by the same person. Further information about the types of data we collect, the purposes for its use and the legal bases we rely on to process your personal data are set out below:

Information from users and website visitors:

Type of data collected	Purpose(s) and legal bases for use
Information you provide when registering for an account on our website or app, including contact details such as name, postal address, e-mail address, telephone number.	We use these details to register you on our system and provide you with a service, for example by: responding to your queries about our products and services; fulfilling your requests for our products and services; sending you service communications (for example, a welcome/registration email, forgotten password email, a receipt or availability notification related to your purchase(s), support correspondence or a notification regarding changes to your service); ensuring the provision of purchases you have made; checking that your postcode is valid for delivery; checking your age for age-restricted items; communicating with you on any concerns arising to the provision of the service. This processing is necessary for the performance of our contract with you or in order to take steps at your request prior to entering into a contract. We also use these details to send you email marketing communications. When you provide your details to us, we will inform you of our intention to send you such messages. You will have a clear opportunity to opt-out at this point and in every subsequent communication. We have a legitimate business interest in sending marketing communications.
Surveys, Promotions, Sweepstakes and feedback	If you decide to participate in any surveys, promotions, or sweepstakes, or give us feedback, you may provide certain information, such as basic contact information and other information relevant to the survey, promotion, or sweepstakes. We use this information for the performance of our contract and for other legitimate business interests.
Information you provide when completing a financial transaction via our website or app, including your payment details (debit/credit card number and expiry date or bank account details etc.).	We use these details to fulfil the service requested, for bookkeeping, audit and for performance analysis. This processing is necessary for the performance of our contract with you and for us to meet our legal obligations, such as keeping records for tax purposes.
Information about your use of our websites and applications, including your IP address.. We may use cookies and similar technologies to collect this information (e.g. web beacons, pixels, ad tags ). We also collect general geolocation information derived from your IP address We also collect data on how you interact with our digital products, such as if you have read and interacted with a digital magazine in an app or online.	We use this information to meet our legitimate business interests, including to: manage, monitor and optimise how customers interact with our Services, to enhance their experience over time; improve your experience on our website; improve our products and Services; understand how our websites, products and apps are used and performing; determine the effectiveness of promotional campaigns and advertising. We may use analytics services to provide us and Product Owners with statistical information. Further details can be found in our Cookie Policy.
Information about your device or system, including information about the device you are using when accessing our website or app, such as the operating system, your browser type, the URL of the previous website you visited, your ISP and unique device identifiers.	Collecting this information allows us to meet certain legitimate business interests, such as to: recognise you next time you visit our website or app, to provide you with a personal experience, for example to display prices in your local currency and suggest products you might like; understand the number of website visits from certain countries, and to block disruptive or abusive use of our Services; personalise or improve the way that our product or advertising is presented to you on our Services and that of third parties, such as based on location, gender (if known) and interests (based on browsing and purchase habits); enhance the security of our network and information systems. We use analytic and reporting technologies to record and collect data from you. This information, such as your browser type, the URL of the previous website you visited, your ISP, operating system, cannot be easily used to personally identify you. To learn more please review the “Cookies, similar technologies, and online advertising” section below and see our Cookie Policy.
Information about your transactions, including details of any purchase from us, such as a print subscription, a digital magazine or a subscription box.	We collect this information as it is necessary for us to fulfil our contract with you. It is also necessary for us to meet certain legal obligations, such as bookkeeping, reporting and audits. We also use this information for performance analysis, which is a legitimate business interest.
Your communications with us, including the content of any messages, queries or complaints you send to us.	We use this information to respond to your communication, which may be necessary for the performance of our contract with you or may fall within our legal obligations.

Information from Suppliers, Vendors, Business Partners, and Similar Businesses

Type of data collected	Purpose(s) and legal bases for use
Contact and Business Information	If you are a company or other organisation that we engage with, or a representative of the foregoing, we may collect your name, phone number, email address, and postal address, government identifier, and business name, industry, locations, other information related to your employer, and any other information you choose to provide us, including through third-party portals and platforms. We use this information for the performance of our contract and for other legitimate business interests. It is also necessary for us to meet certain legal obligations, such as bookkeeping, reporting and audits.
Financial and Transactional Information	If we need to make payments to you or receive payments from you, we may collect financial account and related transactional information. We use this information for the performance of our contract and for other legitimate business interests. It is also necessary for us to meet certain legal obligations, such as bookkeeping, reporting and audits.
Communications	If you contact us, we may receive information such as your name, email address, and phone number. We also will receive the contents of any communications you have with us. This might include requests, questions, and/or issues regarding your orders, your account, our Services, or other topics you might raise. We use this information for the performance of our contract and for other legitimate business interests.
Events and Programs	If you register for or attend an event or program that we host, sponsor, or attend, we may receive information such as your name, email address, phone number, and other information related to your attendance at the event or program from those who interact with or express interest in us or our Services. We use this information for the performance of our contract and for other legitimate business interests.
Surveys, Promotions, Sweepstakes and feedback	If you decide to participate in any surveys, promotions, or sweepstakes, or give us feedback, you may provide certain information, such as basic contact information and other information relevant to the survey, promotion, or sweepstakes. We use this information for the performance of our contract and for other legitimate business interests.
Information about your use of our websites and applications, including your IP address and device identifiers. We may use cookies and similar technologies to collect this information (e.g. web beacons, pixels, ad tags).	We will only use your personal data when the law allows us to. Most commonly we will use your personal data in the following circumstances: Where necessary to perform the contract we are about to enter into or have entered into with you. Where it is necessary for our legitimate interest (or those of a third party) and your interests and fundamental rights do not override those interests. Where we need to comply with a legal obligation.
We also collect general geolocation information derived from your IP address	Collecting this information allows us to: recognise you next time you visit our website or app, to provide you with a personal experience, for example to display prices in your local currency and suggest products you might like; understand the number of website visits from certain countries, and to block disruptive or abusive use of our Services; personalise or improve the way that our product or advertising is presented to you on our Services and that of third parties, such as based on location, gender (if known) and interests (based on browsing and purchase habits); enhance the security of our network and information systems. We use analytic and reporting technologies to record and collect data from you. This information, such as your browser type, the URL of the previous website you visited, your ISP, operating system, cannot be easily used to personally identify you. To learn more please review the “Cookies, similar technologies, and online advertising” section below and see our Cookie Policy.

In specific circumstances we also rely on the lawful basis of consent (i.e. where you actively agree to a specific use of your personal data) or our legal obligations to process your data (i.e. where we are obliged to hold your personal data or disclose it, for example for tax reasons, or prevention of crime). We may also have a legitimate interest in disclosing your data in the context of the merger or acquisition of the company, or to process your data for use in legal proceedings, where such proceedings are ongoing or anticipated.

We have balanced our legitimate interests with those of our customers. If you would like further information or to object to us using your data for such purposes, please contact privacy@jellyfishconnect.com.

Cookies, similar technologies, and online advertising

We and our service providers may collect information through the use of “cookies” and similar technologies, such as tracking pixels, to distinguish you from other users of our website, to help us improve your experience of our website and our services, to understand how you navigate through and interact with our services, to learn what content is popular, to enhance the services and provide you with a more relevant and personalised experience, for authentication and advertising purposes, to save your preferences, for fraud detection and security, and to collect certain usage and device information as described above. For detailed information regarding the Cookies we use and the purposes we use them for, please refer to our Cookie Policy. We may also collect this kind of information when you interact with email messages or other communications we send you. Cookies are small text files that web servers place on your device; they are designed to store basic information and to help websites and apps recognise your browser. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be accessed every time you use our services. Tracking pixels (sometimes referred to as web beacons or clear GIFs) are tiny electronic tags with a unique identifier embedded in websites, online ads, and/or email; they are designed to collect usage information like ad impressions or clicks and email open rates, measure the popularity of our services and associated advertising, and access cookies. We and our vendors (including Google Analytics) also use these technologies and the information collected by them for data analytics purposes. Please note that if you delete or choose not to accept cookies from us, you may miss out on certain features of our services.

We may allow third-party advertising technologies (e.g., ad networks and ad servers, and others) on our services that use cookies and similar technologies to deliver relevant and targeted content and advertising to you as you browse the internet. The ads may be based on various factors such as the content of the page you are visiting, information you provide, your searches, demographic data, and other information we collect about you. These ads may be based on your current activity or your activity over time and across other websites and online services and may be tailored to your interests.

We sometimes also associate cookies with de-identified data linked to or derived from data you have submitted to us (e.g., your email address) and disclose such information with to advertising partners and vendors in hashed, non-human-readable form to provide you with more relevant ads when you visit other websites and mobile applications.

The use of cookies or other tracking technologies that may be placed on devices you use to access our website by non-affiliated third parties is governed by the privacy policies of those third parties. If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your devices to deliver tailored advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out link or the Digital Advertising Alliance’s Consumer Opt-Out link to opt out of receiving tailored advertising from companies that participate in those programs. To opt out of Google Analytics for display advertising or customise Google display network ads, visit the Google Ads Settings page.

If you are a U.S. resident, please see the “Additional privacy information for California and other United States residents” supplement for additional ways to opt out of targeted advertising under U.S. law.

Please note that these opt-outs apply per browser and per device, so you will have to opt out for each device—and each browser on each device—through which you access our Services. In addition, the opt-outs do not apply to advertisements in mobile applications.

How do we help to keep your data safe and secure?

The security of your personal data is important to us. We have put in place appropriate security measures to reduce the risk of loss, misuse, unauthorised access, disclosure, or modification of your information. However, no method of transmission over the internet and no means of electronic or physical storage is absolutely secure. We follow generally accepted industry standards to protect the personal data submitted to us, both during transmission and once we receive it (e.g., encryption of more sensitive data elements such as payment information). When you give your personal data to Jellyfish we will process that data in accordance with our responsibilities.

To prevent unauthorised access, to maintain data accuracy and to ensure the correct usage of information, we monitor and adjust our physical, electronic and managerial procedures to safeguard and secure your personal data while in our care, or in the care of any outside suppliers with whom we may contract to process your data on our behalf. Any outside suppliers are under strict contractual terms to mirror the security policies that we currently have in place.

Data retention

We will keep personal data only for as long as we need it to maintain our relationship with our contacts, provide them with the products, services or information they have requested, to inform our research into the preferences of our customers /clients, to comply with the law, to ensure we do not communicate with individuals that have asked us not to, and for other necessary purposes, like resolving disputes, enforcing our agreements, and for fraud prevention and related security purposes.. When we no longer need the information, we will dispose of it securely, using specialist companies to do this work for us if necessary.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

If you opt out of email marketing, we maintain your email on our suppression list for an extended time to comply with your request. We may delete or de-identify your information sooner if we receive a verifiable deletion request, subject to exemptions under applicable law. We may retain cached or archived copies of your information.

Disclosing information to others

Primarily we use your information within Jellyfish in order to provide you with the service or product you have selected.

We will only disclose your information to specific third parties in the following circumstances:

• To facilitate the service of a physical product, for example providing appropriate details (such as name, address, payment details as applicable) to the Product Owner of a print magazine subscription or subscription box.
• We may use partners to help manage, monitor and optimise our Services to help us measure the effectiveness of our advertising, communications and how visitors use the Services.
• If you have provided consent to receive marketing correspondence from the Product Owner of a product you have purchased through one of our Services, your data will be disclosed to them and/or the data processor authorised to operate on their behalf for the specific purposes to which you consented. In each of the above cases, the Product Owner will have their own privacy policy which will cover their use of your personal data.
• Where we need to do so in order to provide a service you have requested. For example online transactions with us are secured using the SSL encryption method and hosted with our third party payment providers including Stripe, MPP Global Solutions Ltd, SagePay Europe Ltd and PayPal. This is to provide enhanced security and protection to our customers. All our payments processed via PayPal are processed via PayPal References Transactions.
• We may use certain third party services to verify your identity in certain circumstances, such as that your postcode is valid for delivery, age for age restricted products and company checks.
• It may be necessary to disclose information to certain third party industry bodies, such as the ABC or BPA, for audit and accreditation purposes, to confirm that sales have taken place.
• To improve the service and advertising that you receive (on our Services and third party websites and apps). These activities may involve the use of cookies or similar technologies. For more information please review the “Cookies, similar technologies, and online advertising” section below and read our Cookie Policy.
• If disclosure is required or permitted by law. We will always ensure that those requesting the information have the legal right to do so.

If another company should purchase any of our companies or assets, including our database, that company will have the right of possession of the personal data collected by us and will assume the rights and obligations formerly attributable to us.

Data Transfers

We may transfer your personal data to a Product Owner based outside the UK or European Economic Area (EEA), in a country with less stringent data protection laws. Where we do so we take the necessary steps to comply with applicable legal requirements and ensure any necessary appropriate safeguards (such as Standard Contractual Clauses) are in place, so that your personal data is treated securely and your rights are respected. For further information about the documents we use to protect your information when it is transferred outside your country or region, please submit a request to privacy@jellyfishconnect.com.

Your rights and choices

Depending on where you live, you may have the following rights and choices under data protection laws:

Rights regarding your information. Depending on your jurisdiction, you may have the right to make certain requests regarding your “personal information” or “personal data” (as such terms are defined under applicable law). Specifically, you may have the following rights:

Direct Marketing: You have the right to object to receiving direct marketing from us. You can unsubscribe from our marketing emails via the unsubscribe link provided in the emails or by emailing us at privacy@jellyfishconnect.com. Please note that it may take us some time, consistent with our legal obligations, to process your request. Even if you opt out from receiving marketing messages from us, you will continue to receive administrative messages from us, such as order confirmations, updates to our policies and practices, or other communications regarding our relationship or transactions with you.

Access: You have the right to be provided with the information we hold for you or general information about the categories of personal data we process about you. This is known as a ‘Subject Access Request’.

Rectification: If the information we hold for you is incorrect or needs amending, please let us know and we will update our records. Where available, you may view and amend these yourself in the My Account area of the relevant Service’s website.

Delete Data/Right to erasure and Account Closure - you can ask us to erase or delete all of your personal data and record with us. If at any time you would like to close and delete an account please contact privacy@jellyfishconnect.com. Your personal data will be removed from our active user database and will be deleted assuming that you are current with all payment obligations, that Jellyfish does not believe it reasonably necessary to keep such information for any pending legal action, and that we are under no other legal obligation to retain such information. Please be aware that any unfulfilled subscriptions may be cancelled without refund, you will have to re-register in order to use the respective Service again, and any existing purchases will be forfeited. It is your responsibility to request a refund from Jellyfish or the appropriate merchant or Product Owner.

Restrict processing: You have the right 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,
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Data portability: You have the right to have provided to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that 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.

Withdraw consent: Where we are relying on consent to process your personal data, you have the right to withdraw your consent at any time and we will stop processing 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.

Non-discrimination: We are committed to ensuring that you will not be denied services, charged a different price, or provided a different level or quality of services just because you exercised your rights under applicable law. Please note, however, that we may need some personal data in order to provide you our services, which means that we may not be able to provide some of our services if you refuse to provide your personal data.

We may need to take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name and email address.

Depending on your jurisdiction, you may be permitted to designate an authorised agent to submit certain requests on your behalf. In order for an authorised agent to be verified, you must provide the authorised agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorised agent’s request.

Depending on applicable law, you may have the right to appeal our decision to deny your request, if applicable. If we deny your request, we will provide you with information on how to appeal the decision, if applicable, in our communications with you.

If you would like further information regarding your legal rights or would like to exercise any of them, please email us at privacy@jellyfishconnect.com or fill out this form. If you are a United States resident, please see the “Additional privacy information for California and Other United States residents” supplement for some additional information about your rights under U.S. law.

Questions

If you have any questions or complaints regarding this Privacy Policy please email privacy@jellyfishconnect.com or write to our Data Protection Officer at Jellyfish Connect Ltd, 31 London Road, Reigate, Surrey, RH2 9SS, UK.

If contacting us does not resolve your complaint, we are registered with the Information Commissioner’s Office who can be contacted if you have concerns about our practices and do not feel we are able to satisfactorily answer your concerns.

Changes to this Privacy Policy

We may update this Policy from time to time in our sole discretion. You can know if the Policy has changed since the last time you reviewed it by checking the “Last Updated” date at the top of this webpage. We encourage you to look for updates and changes to this Policy periodically. If we make a material change to this Policy, we will endeavor to notify you through the services, by email, and/or by other legally permissible communication as required by applicable law. Your continued use of the services after any changes to this Policy are in effect constitutes your acceptance of revisions to the Policy.