1.1 We are committed to safeguarding the privacy of our website visitors, service
users, individual customers and customer personnel.
1.2 This policy applies where we are acting as a data controller with respect to
the personal data of such persons; in other words, where we determine the
purposes and means of the processing of that personal data.
1.3 Our website incorporates privacy controls which affect how we will process
your personal data. By using the privacy controls, you can specify whether
you would like to receive direct marketing communications and limit the
collection, sharing and publication of your personal data. You can access the
privacy controls via your account settings.
necessary for the provision of our website and services, we will ask you to
1.5 In this policy, “we”, “us” and “our” refer to JINGHMA.COM. For more information about us, see Section
The personal data that we collect
2.1 In this Section 2 we have set out the general categories of personal data that
we process and, in the case of personal data that we did not obtain directly
from you, information about the source and specific categories of that data.
2.2 We may process data enabling us to get in touch with you (“contact data”).
The contact data may include your name, email address, telephone number,
postal address and/or social media account identifiers. The source of the
contact data is you and/or your employer. If you log into our website using a
social media account, we will obtain elements of the contact data from the
relevant social media account provider.
2.3 We may process your website user account data (“account data”). The
account data may include your account identifier, name, email address,
business name, account creation and modification dates, website settings and
marketing preferences. If you log into our website using a social media
account, we will obtain elements of the account data from the relevant social
media account provider.
2.4 We may process information relating to transactions, including purchases of
goods and/or services, that you enter into with us and/or through our website
(“transaction data”). The transaction data may include your name, your
contact details, your payment card details (or other payment details) and the
transaction details. The source of the transaction data is you and/or our
payment services provider.
2.5 We may process information contained in or relating to any communication
that you send to us or that we send to you (“communication data”). The
communication data may include the communication content and metadata
associated with the communication. Our website will generate the metadata
associated with communications made using the website contact forms.
2.6 We may process data about your use of our website and services (“usage
data”). The usage 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. The source of the usage
data is our analytics tracking system.
Purposes of processing and legal bases
3.1 In this Section 3, we have set out the purposes for which we may process
personal data and the legal bases of the processing.
3.2 Operations – We may process your personal data for the purposes of
operating our website, the processing and fulfilment of orders, providing our
services, supplying our goods, generating invoices, bills and other paymentrelated documentation, and credit control. The legal basis for this processing
is our legitimate interests, namely the proper administration of our website,
services and business.
3.3 Publications – We may process account data for the purposes of publishing
such data on our website and elsewhere through our services in accordance
with your express instructions. The legal basis for this processing is consent.
3.4 Relationships and communications – We may process contact data,
account data, transaction data and/or communication data for the purposes
of managing our relationships, communicating with you (excluding
communicating for the purposes of direct marketing) by email, SMS, post,
telephone, providing support services and complaint handling. The legal basis
for this processing is our legitimate interests, namely communications with
our website visitors, service users, individual customers and customer
personnel, the maintenance of relationships, and the proper administration of
our website, services and business.
3.5 Direct marketing – We may process contact data, account data and/or
transaction data for the purposes of creating, targeting and sending direct
marketing communications by email, SMS, post and making contact by
telephone for marketing-related purposes. The legal basis for this processing
3.6 Research and analysis – We may process usage data and/or transaction
data for the purposes of researching and analysing the use of our website and
services, as well as researching and analysing other interactions with our
business. The legal basis for this processing is consent.
3.7 Record keeping – We may process your personal data for the purposes of
creating and maintaining our databases, back-up copies of our databases and
our business records generally. The legal basis for this processing is our
legitimate interests, namely ensuring that we have access to all the
information we need to properly and efficiently run our business in
accordance with this policy.
3.8 Security – We may process your personal data for the purposes of security
and the prevention of fraud and other criminal activity. The legal basis of this
processing is our legitimate interests, namely the protection of our website,
services and business, and the protection of others.
3.9 Insurance and risk management – We may process your personal data
where necessary for the purposes of obtaining or maintaining insurance
coverage, managing risks and/or obtaining professional advice. The legal
basis for this processing is our legitimate interests, namely the proper
protection of our business against risks.
3.10 Legal claims – We may process your personal data where necessary for the
establishment, exercise or defence of legal claims, whether in court
proceedings or in an administrative or out-of-court procedure. The legal basis
for this processing is our legitimate interests, namely the protection and
assertion of our legal rights, your legal rights and the legal rights of others.
3.11 Legal compliance and vital interests – We may also process your personal
data where such processing is necessary for compliance with a legal
obligation to which we are subject or in order to protect your vital interests or
the vital interests of another natural person.
Providing your personal data to others
4.1 We may disclose your personal data to our forwarders and shipping partners
insofar as reasonably necessary for the purposes of obtaining or maintaining
efficient deliveries of goods.
4.2 Your personal data held in our website database will be stored on the servers
of our hosting services providers.
4.3 Financial transactions relating to our website and services may be handled by
our payment services providers, PayPal, 2Checkout. We will share transaction
data with our payment services providers only to the extent necessary for the
purposes of processing your payments, refunding such payments and dealing
with complaints and queries relating to such payments and refunds. You can
find information about the payment services providers’ privacy policies and
practices at https://www.paypal.com/uk/webapps/mpp/ua/useragreementfull https://www.2checkout.com/legal/terms/.
4.4 In addition to the specific disclosures of personal data set out in this Section
5, we may disclose your personal data where such disclosure is necessary for
compliance with a legal obligation to which we are subject, or in order to
protect your vital interests or the vital interests of another natural person. We
may also disclose your personal data where such disclosure is necessary for
the establishment, exercise, or defence of legal claims, whether in court
proceedings or in an administrative or out-of-court procedure.
International transfers of your personal data
5.1 In this Section 5, we provide information about the circumstances in which
your personal data may be transferred to a third country under UK and/or EU
data protection law.
5.2 The hosting facilities for our website are situated in EU. The competent data
protection authorities have made an adequacy determination with respect to
the data protection laws of each of EU countries.
5.3 You acknowledge that personal data that you submit for publication through
our website or services may be available, via the internet, around the world.
We cannot prevent the use (or misuse) of such personal data by others.
Retaining and deleting personal data
6.1 This Section 6 sets out our data retention policies and procedures, which are
designed to help ensure that we comply with our legal obligations in relation
to the retention and deletion of personal data.
6.2 Personal data that we process for any purpose or purposes shall not be kept
for longer than is necessary for that purpose or those purposes.
6.3 We will retain your personal data as follows:
(a) contact data will be retained for a minimum period of 1 year following
the date of the most recent contact between you and us, and for a
maximum period of 3 years following that date;
(b) account data will be retained for a minimum period of 1 year following
the date of closure of the relevant account, and for a maximum period
of 3 years following that date;
(c) transaction data will be retained for a minimum period of 1 year
following the date of the transaction, and for a maximum period of 3
years following that date;
(d) communication data will be retained for a minimum period of 1 year
following the date of the communication in question, and for a
maximum period of 3 years following that date; and
(e) usage data will be retained for 1 year following the date of collection.
6.4 Notwithstanding the other provisions of this Section 6, we may retain your
personal data where such retention is necessary for compliance with a legal
obligation to which we are subject, or in order to protect your vital interests
or the vital interests of another natural person.
7.1 In this Section 7, we have listed the rights that you have under data
7.2 Your principal rights under data protection law are:
(a) the right to access – you can ask for copies of your personal data;
(b) the right to rectification – you can ask us to rectify inaccurate
personal data and to complete incomplete personal data;
(c) the right to erasure – you can ask us to erase your personal data;
(d) the right to restrict processing – you can ask us to restrict the
processing of your personal data;
(e) the right to object to processing – you can object to the processing
of your personal data;
(f) the right to data portability – you can ask that we transfer your
personal data to another organisation or to you;
(g) the right to complain to a supervisory authority – you can
complain about our processing of your personal data; and
(h) the right to withdraw consent – to the extent that the legal basis of
our processing of your personal data is consent, you can withdraw that
7.3 These rights are subject to certain limitations and exceptions. You can learn
more about the rights of data subjects by visiting
https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelinesrecommendations-best-practices_en and https://ico.org.uk/fororganisations/guide-to-data-protection/guide-to-the-general-data-protectionregulation-gdpr/individual-rights/.
7.4 You may exercise any of your rights in relation to your personal data by
written notice to us, using the contact details set out below.
8.1 A cookie is a file containing an identifier (a string of letters and numbers) that
is sent by a web server to a web browser and is stored by the browser. The
identifier is then sent back to the server each time the browser requests a
page from the server.
8.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent
cookie will be stored by a web browser and will remain valid until its set
expiry date, unless deleted by the user before the expiry date; a session
cookie, on the other hand, will expire at the end of the user session, when the
web browser is closed.
8.3 Cookies may not contain any information that personally identifies a user, but
personal data that we store about you may be linked to the information
stored in and obtained from cookies.
Cookies that we use
visit our website and as you navigate our website, and to help us
determine if you are logged into our website;
cart as you navigate our website;
preferences and to personalise our website for you;
to protect user accounts, including preventing fraudulent use of login
credentials, and to protect our website and services generally;
will be relevant to you;
performance of our website and services; and
Cookies used by our service providers
computer when you visit our website.
10.2 We use Google Analytics. Google Analytics gathers information about the use
of our website by means of cookies. The information gathered is used to
create reports about the use of our website. You can find out more about
Google’s use of information by visiting
https://www.google.com/policies/privacy/partners/ and you can review
11.1 Most browsers allow you to refuse to accept cookies and to delete cookies.
The methods for doing so vary from browser to browser, and from version to
version. You can however obtain up-to-date information about blocking and
deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647 (Chrome);
(b) https://support.mozilla.org/en-US/kb/enhanced-tracking-protectionfirefox-desktop (Firefox);
(c) https://help.opera.com/en/latest/security-and-privacy/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internetexplorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/en-gb/guide/safari/manage-cookies-andwebsite-data-sfri11471/mac (Safari); and
(f) https://support.microsoft.com/en-gb/help/4468242/microsoft-edgebrowsing-data-and-privacy (Edge).
11.2 Blocking all cookies will have a negative impact upon the usability of many
11.3 If you block cookies, you will not be able to use all the features on our
12.1 We may update this policy from time to time by publishing a new version on
12.2 You should check this page occasionally to ensure you are happy with any
changes to this policy.
12.3 We may notify you of significant changes to this policy by email.