PRIVACY POLICY

This Privacy Policy applies to the website www.sjagroup.co.uk which is operated by SJA Group Limited, a company registered in England and Wales under number 10717369 with its registered office at 77 Station Road, Sidcup, Kent, DA15 7DN  (“SJA Group”, “we”, “our” or “us”).

This Privacy Policy is provided in accordance with SJA Groups obligations under applicable privacy and data protection law, including UK GDPR. For the purposes of this Privacy Policy, the term “personal data” means any information which identifies you or which allows you to be identified when combined with other information. It does not include data where the identity has been removed (anonymous data).

SJA Group is a data controller and a data processor. SJA Group may also be a data processor where it processes personal data belonging to another party under their instruction and control. This Privacy Policy primarily applies in the context where SJA Group is a data controller.

Collection of your Personal Information

SJA Group may collect and process personal data,

We may collect and process data about others that you provide us, including information that you provide by filling in forms on the Platform.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, and social media accounts.

Contact Data includes billing address, delivery address, email address and telephone numbers.

Financial Data includes bank account and payment card details.

Transaction Data includes details about payments to and from you and other details of services you have purchased from us.

Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device model and other technology on the devices you use to access this website or our Platform.

Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

Usage Data includes information about how you use our website and services.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy. This information is used for the operation of the website and the services provided by SJA Group, and to provide general statistics regarding use of the SJA Group website and services.

We do not collect any Special Categories of Personal Data about you (such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) or information about criminal convictions and offences.

Where we are unable to collect any necessary data from you, you may find that some services are not available to you.

How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your details in person, by filling in forms on our website, by corresponding with us by post, phone, email, social media or otherwise. This includes personal data you provide when you:

request our products or services;

meet with one of our employees or consultants;

participate in an event which we have organised;

complete a form on our website requesting us to contact you;

subscribe to our publications or newsletter;

request marketing to be sent to you;

enter a competition, promotion or survey;

submit an application for a role within SJA Group; or

make a complaint or give us some feedback.

Use of Cookies

The SJA Group website may use “cookies” to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. This helps us to provide you with a good experience when you browse our website and allows us to improve our website.

As you interact with our website, we may collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details. 

Automated technologies through the use of our website or services. In your use of our website or services (including receiving our newsletter), certain Usage Data is transmitted to us such as the device you are using, your IP address and other such data.

Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:

Technical Data or Usage Data from analytics providers or search information providers.

Employment, Identity and Contact Data from third party recruitment agencies.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see cookie policy.

Purposes for which we will process your personal data

SJA Group collects and uses your personal information to operate its website(s) and mobile applications and deliver the services you have requested. Most commonly, we will use your personal data in the following circumstances:

Where we need to comply with a legal or regulatory obligation.

Where we need to perform the contract we are about to enter into or have entered into with you.

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Where direct marketing is sent to you, we will rely on your consent. You have the right to withdraw this consent at any time by contacting us.

Below is a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you have any questions about how we use your personal data..

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer

(a) Identity
(b) Contact

Performance of a contract with you

To process and deliver services including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us

(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications

(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications

(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity
(b) Contact
(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, software, Platform, products/services, marketing, customer relationships and experiences

(a) Technical
(b) Usage

Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile

Necessary for our legitimate interests (to develop our products/services and grow our business)

SJA Group may also use your information to inform you of other products or services available from SJA Group and our partners. SJA Group may also contact you via surveys to conduct research about your opinion of our website and services. SJA Group does not sell, rent or lease or provide in any other way its customer information.

SJA Group may keep track of the websites and pages our users visit within SJA Group and which services our users access. This data is used to deliver customised content within SJA Group to customers whose behaviour indicates that they are interested in a particular subject area.

Transfer of Personal Data

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions and applicable law.

SJA Group may share data with the third parties set out below for the purposes set out in the table above:

Affiliates of SJA Group;

Our third-party service providers who perform functions on our behalf in connection with the operation of our business such as IT service providers and system administrators, third parties who host and manage data or provide programming or technical support, deliver our products and services, conduct reference checks on candidates on our behalf etc;

Professional advisers including lawyers, bankers, auditors and who provide consultancy, banking, legal, insurance and accounting services; and

Our third-party analytics partners to analyse website traffic and understand customer needs and trends or our third-party marketing service providers to help us to communicate with. This is expressly with your consent.

All such third parties are required to maintain the confidentiality of your information.

We may also transfer your personal data to third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

Whenever we transfer your personal data out of the EEA or UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know

If you wish to know more about the safeguards in place, please contact us.

Data retention

SJA Group will only retain your personal data for as long as necessary to fulfil the purposes we collected it.

Any information we hold is reviewed regularly and any data deemed no-longer relevant is deleted. You can request details of retention periods for different aspects of your personal data by contacting via our contact form.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for analytical, research and statistical purposes and to help us to improve our products and services, in which case this is no longer personal data and we may use this information indefinitely without further notice to you.

Children Under Thirteen

SJA Group does not knowingly collect personally identifiable information from children under the age of thirteen.

Opt-Out & Unsubscribe

We respect your privacy and give you an opportunity to opt-out of receiving announcements of certain information. Users may opt-out of receiving any or all communications from SJA Group by contacting us or selecting the “Unsubscribe” option on their email.

Your  Rights

You have the right to:

Request access to your personal data (commonly known as a “subject access request”). 

Request correction of the personal data that we hold about you. 

Request erasure of your personal data. 

Object to processing of your personal data where we are relying on a legitimate interest 

Request restriction of processing of your personal data. 

Request the transfer of your personal data to you or to a third party. 

Withdraw consent at any time where we are relying on consent to process your personal data. 

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

Changes to this Privacy Policy

SJA Group will occasionally update this Privacy Policy to reflect company and customer feedback and any changes in data protection regulations. SJA Group encourages you to periodically review this Privacy Policy to be informed of how SJA Group is protecting your information.

Contact Information

SJA Group welcomes your questions or comments regarding this Privacy Policy. If you believe that SJA Group has not adhered to this Privacy Policy, please contact SJA Group at:

SJA Group Limited
77 Station Road
Sidcup
Kent
DA15 7DN

Questions, comments and requests regarding this privacy policy are welcome and should be addressed via our contact form.

Correct as of 10th January 2024