1.0 Introduction

1.1    We are firmly committed to safeguarding the privacy of (our website visitors and service users).

1.2    This applies to areas where we are acting as custodians of data concerning the personal data of (our website visitors and service users); put differently, where we decide the way and manner we handle the handle data.

1.3    We utilize cookies on our website. To the extent that those cookies are not strictly necessary for the provision of (our website and services), we will ask for your consent to utilize cookies in invent that you are a first time visitor to our site.

1.4    Our privacy control influences how we employ your data on our site website. By utilizing the privacy controls, you can (specify whether you would like to receive direct marketing communications and limit the publication of your information).

1.5    Under this policy, “we,” “us” and “our” refer to (Just a Vegan).

2.0 How We Use Your Personalized Data

2.1    This Section spells out amongst other things the generic class of the personalized data, the intent surrounding the use of the data as well as the legal foundation for it.

2.2    We may run (particulars on how you make use of our site and services) (“usage data”). This data may include (your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency, and pattern of your service use) derived from (our analytics tracking system). This data may be handled (for the purposes of analyzing the use of the website and services). The legal foundation for this processing is (consent) OR (our legit interests, namely monitoring and improving our site and services) OR as may be specified.

2.3    We may handle (your account data) (“account data“). The account information may contain your name and email address; the source of the data is you or your proprietor; the account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our site and services, maintaining back-ups of our databases and communicating with you. The legal basis for this handling is (consent) OR our legitimate concerns, namely the proper administration of our website and business OR the performance of a contract between you and us or initiating steps, at your request, to venture into such agreement OR as may be specified.

2.4    We may preside over your information contained in your profile on our website (“profile data“). This data may consist of your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The profile data may be handled for the purposes of enabling and monitoring your use of our website and services. The legal base for this handling is (consent) OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us or taking steps, at your request, to enter into such an agreement OR as may be specified.

2.5    We may handle the data that you provide in the course of the use of our services (“service data“). This data may include (specified information). The origin of this data is (you or your employer). The service data may be handled (for the purposes of operating our website, providing our services, ensuring the security of our site and services, maintaining back-ups of our databases and communicating with you). The legal base for this processing is (consent) OR our legitimate interests, namely (the proper administration of our website and business) OR the performance of a contract between you and us or initiating steps, at your request, to venture into such agreement OR as may be specified.

2.6    We may manage information that you post for publication on our website or through our services (“publication data“). The data may be utilized (for the purposes of enabling such writing and administering our site and services). The legal foundation for this processing is (consent) OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us or initiating steps, at your request, to venture into such agreement OR as may be specified.

2.7    We may handle information contained in any inquiry you submit to us regarding goods or services (“inquiry data“). These data may be processed for the purposes of offering, marketing and selling related products or services to you. The legal rationale for this processing is (consent) OR as may be specified.

2.8    We may manage information relating to our customer relationships, including customer contact information (“customer relationship data“). This data may take into account (your name, employer, job title or role, contact details, and information contained in communications between you and us or your employer). The origin of the customer relationship data is (you or your employer). Also, this data may be processed (for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers). The legal principle behind this handling is (consent) OR our legitimate concerns, namely (the proper management of our customer relationships) OR as may be specified.

2.9    We may act on information relating to transactions, including purchases of goods and services that you enter into with us or through our website (“transaction data“). This data may comprise details of your contact, card, and the transaction. The transaction data may be taken care of (for the purpose of supplying the purchased goods and services and keeping proper records of those transactions). The legal foundation for this handling is the performance of a contract between you and us or putting in place measures at your request, to enter into such agreement and our legit interests, namely the proper administration of our website and business OR as may be specified.

2.10  We may act upon information that you provide to us for the purpose of subscribing to our email notifications or newsletters (“notification data“). This data may be utilized for the purposes of sending you the relevant notifications or newsletters. The legal backing for this processing is (consent) OR (the performance of a contract between you and us or putting in place measures, at your discretion, to enter into such an understanding OR as may be specified.

2.11  We may handle information contained in or relating to any communication that you send to us (“correspondence data“). This may include the communication content and metadata associated with the connection. Our website will generate the metadata related to communications made using the website’s contact forms. Also, this data may be processed for the purposes of communicating with you and record-keeping. The legal base for this handling is our legitimate concerns, namely (the proper administration of our website, business, and communications with users) OR as may be specified.

2.12  We may utilize (any of your data identified in this policy) were necessary for (the initiation, exercise or plea of legal claims, whether in legal proceedings or an administrative or out-of-court procedure). The legal principle for utilizing this data is our legitimate concerns, namely (the protection and assertion of our constitutional rights, your legal rights and the legal rights of others).

2.13  We may handle (any of your data identified in this policy) where necessary for (the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice). The legal foundation for this handling is our legitimate sake, namely (the proper protection of our business against threats).

2.14  In addition to the specific intents for which we may manage your data set out in this part (section 2), we may also lead (any of your personal data) where such handling is necessary for compliance with a legal obligation to which we are subject, or so as to safeguard your vital interests or the essential interests of another natural person.

2.15  Please do not furnish us with any person’s data without any formal request from us.

3.0 Providing Your Data to a Third Party

3.1    We may reveal (your data) to any member of our group of companies (this means our subsidiaries, our ultimate holding company, and all its subsidiaries) as may be required by circumstance, and as set out by the legal base of this policy.

3.2    We may reveal (your personal data) to (our insurers or professional advisers) as may be required within reasonable limits for (obtaining or maintaining insurance coverage, managing risks, obtaining expert advice, or the establishment, application or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure).

3.3    We may reveal (specific personal data category or categories) to (our suppliers or subcontractors) as may be required within reasonable limits for (specific purposes).

3.4    Financial transactions relating to (our website and services) [are] OR [may be] managed by our Payment Gateway Service (PGS). We will share transaction data with our PGS only to the extent required for (processing your payments, refunding such payments and resolving complaints and queries pertaining to such payments and refunds).

3.5    We may reveal (your inquiry data) to (one or more of those selected third party suppliers of merchandise and services identified on our site) for (enabling them to contact you so that they can offer, market and sell you material products or services). Each of such third party will act as a data controller with the inquiry data that we supply to it; and upon contacting you, each such third party will furnish to you a copy of its privacy policy, which will govern that third party’s use of your data).

3.6    In addition to the specific revelation of personal data set out in this Section 3; we may reveal your data where such admission is necessary for compliance with a legal obligation to which we are subject, or to safeguard your vital interests or that of another natural person. We may also reveal your data where such revelation is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or an administrative or out-of-court procedure.

4.0 International Transfer of Your Data

4.1    In this Section, we supply information about the circumstances in which your data may be channeled to [countries outside the European Economic Area (EEA)].

4.2    The hosting facilities for our website are domiciled in (France). The European Commission has introduced “adequacy decision” for (the data protection laws as it concerns each of these nations). Transfers to (each of these nations) will be protected by appropriate safeguards, namely (the use of standard data protection clauses espoused or sanctioned by the European Commission, OR specify proper safeguards and means of obtaining a copy.

4.3    You acknowledge that (personal data that you present for publication via our website or services) may be available, through the internet, worldwide. We cannot forestall the utilization (or otherwise) of such personal data by others.

5.0 Retaining and Deleting Personal Data

5.1    This Section covers our data retention policies and procedure, which are formulated in line with our legal obligations on retention and deletion of personalized data.

5.2    Any personalized data that we handle shall not be held indefinitely beyond the ideal intent of use.
However, we may hold your data where it becomes necessary for the sake of adherence to a legal obligation to which we are subject, or to protect your vital interests or that of another natural person.

6.0 Policy Amendments

6.1    We may update this policy periodically base on prevailing circumstances without any prior notice to our users.

6.2    We (may) OR (will) apprise you of (changes) OR (necessary changes) to this policy (by email or via the private messaging system on our website). Even so, we strongly advise that you take time out to visit this section of our website to acquaint yourself with these changes at regular time intervals (as we cannot assure you this at all times).

7.0 Your Rights

7.1    The rights that you have under the data protection law are concisely expressed in this section. You are advised to read the relevant rules and guidance from the regulatory authorities as not all these are captured here.

7.2    Your fundamental rights under the data protection law are in the areas of access, rectification, erasure, restriction of processing, object to processing, data portability, make a complaint to a supervisory authority and consent withdrawal.

7.3    You have the right to either accept or decline any request to process your data and other additional information to the degree that other natural parties are not affected negatively. This information may include the category of the data, data receiver, and details relating to the intent of handling the personalized data.

7.4    You may seek redress in the event of any falsification of your private data via a formal request or notification to us.

7.5    In some situations you have the right to seek erasure of your private data without undue delay. Such as when the personalized data is not required for further handling, you withdrew earlier given consent, obvious objection to the illegitimate administration or direct marketing of private data. However, the right to erasure may be overruled to exercise the right to freedom of expression and information, to comply with a legal obligation or in favor of compliance with legitimate claims.

7.6    You are at liberty to limit the handling of your data in certain conditions which include: repugn the integrity of the data, unlawful processing and erasure, the irrelevance of the data for our administration except for the validation and defense of legal claims.
Nonetheless, your data will be processed solely in pursuit of legitimate claims beyond personal interest where handling has been restricted.

7.7    You have the right to be averse with our handling of your data on personal grounds but this could be overridden by a (persuasive legitimate) interest more superior to yours should certain circumstances demand such.

7.8    You have the right to dissent our handling of your private data for direct marketing purposes (including profiling for such purposes). We will cease to handle the data for that purpose in the event of such.

7.9    You have the right to dissent to the processing of your private data for the sake of inquiry on own grounds in the absence of a significant legitimate public stake.

7.10  Insofar as the legal basis for the processing of your private data is:

(a)    consent; or

(b)    that the handling is a requisite for carrying out a contract or an undertaking before any contractual obligations in which case is machine-driven. You may place a request for a printable copy of this without infringement to the liberty of other individuals.

7.11  You have the right to seek redress where you perceive that our handling of your private information conflicts with the data protection laws through an appropriate channel (supervisory authority).

7.12  You are at liberty to draw back your consent whenever you decide, but any processing before your withdrawal will be treated as legitimate.

7.13  You may exercise any of your rights to your private data either through a written (formal) request to us or other means in addition to those specified here.

8.0 Cookies that We Use

8.1  We utilize cookies (identify cookies) for the following reasons:

(a)    Certification – we employ cookies to detect your presence on our site pages (validate our site visitors);

(b)   Status – we use cookies to ascertain whether you logged into our website or not;

(c)    Personalisation – we utilize cookies to personalize your surfing experience whenever you visit our site base on preferences;

(d)    Security – we use cookies as a means of safeguarding our website and activities on our site which may not be limited to the prevention of fraudulent schemes by some users.

(e)    Advertisement – we utilize cookies for the placement of relevant Ads for our visitors;

(f)     Analysis – we employ cookies to enable us to examine the use and performance of our site and services by users; and

(g)    Consent – we use cookies to manage your preferences subject to your approval or acceptance.

N.B: We strongly recommend that you research about cookies for more about them.

9.0 Cookies Used by Our Service Providers

9.1  Our service providers use cookies which may be stash away on your computer whenever you visit our website.

9.2  We employ Google Analytics to examine the use of our site. It collects this information via the use of cookies then creates reports concerning the use of our website. You may visit here for Google’s privacy policy.

9.3  We publish Google AdSense targeted advertisements on our website. Google is responsible for custom-made Ads which you on our site or other sites across the web. It does this by tracking your activities across the various web platforms and places Ads that reflects your preference over the network using cookies. You may wish to act on this by visiting the following link if you feel obsessed or merely opt out here temporarily or permanently here.

10.0 Cookies Management

10.1  You should visit the support page or settings tab of the browser you use to surf the web to learn more about how to manage cookies on these browsers.

10.2  Blocking cookies is counterproductive and will hinder the use of all features on our site as well as most websites.

10.3  You can contact us using the contact form by navigating to the contact tab of this website or via this medium here.

11.0 Credit

This document was created utilizing a template from SEQ Legal