This document details the Company’s policy for privacy and states how the Company, through its platform, app or website, collects, handles and processes data of its customers and visitors. It explicitly describes whether that information is kept confidential, or is shared with or sold to third parties.

1. Review and Update of the Policy

By using the JamDoughnut service, we collect personal information about you including the way you use the service. By registering to use the platform and the service, you give us your permission to process your personal information for the purposes set out in this Privacy Policy (the “Privacy Policy”).

This Policy will occasionally be updated. Rest assured, whenever this happens we’ll notify you.

This Policy was last updated on 11th March, 2021.

2. Summary
We are fully committed to respecting your privacy and believe you should have control of your data and access to the benefits and money saving opportunities it can provide. This is just one reason why we created JamDoughnut and this Policy covers what we collect and how we manage, use and protect it. We ask that you please read this Privacy Policy as it contains important information on:
• the personal information we collect about you;
• how will we use your information;
• who your information might be shared with;
• how we keep your data secure; and
• your rights to your information.

Below is a summary of some important parts of this Privacy Policy but it is definitely not a substitute for reading the whole Policy.
Our uses of your information include:
• enabling you to access and use the JamDoughnut service;
• optimising and personalising your experience on our platform and improving aspects of our service;
• research (e.g. measuring how many people consider changing provider);
• arranging communication between you and a new service provider; and
• if required, we will disclose any regulatory or governmental bodies with your information.

3. Who we are and how to contact us

The JamDoughnut App and Website are operated by JamDoughnut Limited (“JamDoughnut”, “Company” “we” or “us”). JamDoughnut is a “Data Controller” for the purposes of UK data protection legislation, i.e. we are responsible for, and control the processing of, your personal information.

JamDoughnut’s registered office is Treviot House, 186-192 High Road, Ilford, Essex, United Kingdom, IG1 1LR, our registered company number is 12277192 and our ICO number is ZA759668. You can check our registration on the Data Protection Public Register by visiting https://ico.org.uk/esdwebpages.

If you have any questions about these Terms, the Privacy Policy or your rights in respect of our processing of your personal information, please contact us at privacy@JamDoughnut.com.

4. The personal information we collect about you
a) Information you might provide us prior to registering for our service.
If you visit our website before registering for our service, we may ask you to provide your mobile number. If we do, we’ll then send you a text message with a link to download the app.
b) Information you provide us while registering for our service.
We will ask for your name, email address, mobile number and biometric information (if you wish to use Touch ID or Face ID authentication).
c) Records of Payments you have made from your bank account or credit card provider.
We will ask you to give us read-only access to records your bank holds about payments made from your bank account or credit card provider holds about payments you’ve made. These may include both payments to your utility providers as well as the other payments made from your bank account or credit card. See the section below on “Bank payment information” for more details about this.

5. How will we use your information?
We will use your information to:
• enable you to access and use the service;
• optimise and personalise your experience on our platform and to improve aspects of our services;
• customise our services to your particular preferences;
• aggregate and anonymise your information so that we can conduct statistical analysis, behavioural analysis and research (e.g. measuring how many people consider changing provider). This research is only undertaken by us and only disclosed by us to selected third parties in an anonymised aggregated format that does not identify you personally;
• carry out customer profiling and analyse service provider purchasing preferences;
• notify you of any changes to our platform or to our services that may affect you;
• detect and prevent fraud;
• administer your account with us; and
• if you agree, let you know about other products or services that may be of interest to you – see the “Marketing” section below.

Bank payment information
We use a world-leading tool developed and provided by one of our specialist partners to provide JamDoughnut with read-only access to your payment data as recorded by your bank or credit card provider. Our partner will keep your bank or card credentials in a secure manner – if you wish to read our partner’s privacy policy please email us at privacy@JamDoughnut.com. JamDoughnut never has access to your cardholder data or bank account or credit card provider login passwords.

Other services
If you express a desire to change service provider (which may be either a utility company, telecom service, or other service provider) when using JamDoughnut, we will obtain some further information from you to facilitate this. To provide you with provider recommendations, we use technology partners who facilitate a switch directly with your new provider. We strongly advise you to review the terms and privacy policy of any household service provider you consider switching to with JamDoughnut – it’s important to ensure you are happy with how they will use your information before you initiate the switching process. Some service providers will use your personal information to assess your personal or household circumstances (including information about any third party who is named as living at your address) and verify the information that you have provided. Some service providers may carry out checks with fraud prevention and credit reference agencies to assess your insurance risk, verify your identity, help prevent fraud and to provide you with their best service plan options. If providers do these checks, they will be visible to other organisations. Both public data (e.g. the electoral roll) and private data (e.g. your personal credit history) may be checked in this way. Providing this service involves our engaging in automated profiling of your information to determine whether you are eligible for certain service provider offers. We use appropriate mathematical or statistical procedures and implement appropriate technological or organisational measures to enable inaccuracies to be corrected and to minimise the risk of errors in conducting this profiling activity.

Marketing
We might like to send you information via the JamDoughnut app or by email or text message (SMS) about service providers and their special offers which may be of interest to you. We will only ask whether you would like us to send you marketing messages when you confirm certain actions. We will not send you marketing information without your consent. If you have consented to receive marketing from us, you can opt out at any time. See “What rights do you have?” below for further information.

6. Whom your information may be shared with
As part of the service, we may disclose your personal information to:
• Our third-party technology partners who provide us with access to your utility or other service provider’s payment information and the ability to switch your service providers;
• Our system infrastructure and platform partners;
• Law enforcement agencies and financial or other regulatory authorities in connection with any investigation to help prevent unlawful activity;
• Ombudsman services for resolving any complaints that you may have; and
• Our business partners in accordance with the “Marketing” section above.
If you decide to switch service provider using our platform, your new provider’s use of the information that you and we provide them about you will be held by them for the purposes set out in their own privacy policy. We strongly advise you to carefully review the privacy policy of any service provider you ask us to initiate contact with and you are strongly advised to read your chosen provider’s privacy policy. Please do not ask us to progress switching you to a new provider until you have satisfied yourself as to the purposes for which the provider will use your personal information. We have no responsibility for the uses to which a provider puts your personal information.

7. How we keep your data secure
We use technical and organisational measures to safeguard your personal data, as outlined below:
• Access to your account is controlled by device level fingerprint and passcode requirements;
• We use secure servers with all information transmitted over industry standard Secure Socket Layer (SSL) connections;
• The JamDoughnut infrastructure and database is hosted on an industry leading technology platform that implements all levels of security controls to safeguard against potential application level weakness and recognizes any potential threats.
• Our technology platform meets a broad set of international and industry-specific compliance standards as well as country-specific standards to ensure your data is kept secure.
• Your personal information which we collect is sent to and stored on secure servers located in the EU. Such storage is necessary in order to process the information for the purposes of providing our service. Personal information may be transferred by third parties mentioned in the circumstances described above, which may be situated outside the European Economic Area (EEA) and may be processed by staff operating outside the EEA. Where we (or our partners) transfer your personal information outside the EEA we will take all reasonable steps to ensure that your privacy rights continue to be protected.
• You can request descriptions of our third party technology providers’ security practices regarding bank credentials by emailing us at privacy@JamDoughnut.com.
While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that are transferred from you or to you via the internet. If you have any particular concerns about your information, please contact us (see “How to contact us?” above).

8. What is the legal basis for our processing your information?
For some uses of your information (for example, direct marketing activity), the legal basis for our processing of your personal data is your consent. In other cases (for example providing you with details of potential switching opportunities), the legal basis is that the processing is necessary to provide you with the service you have contracted with us to provide. In other cases, the legal basis is our legitimate interest (and those of our technology partner who facilitates switching of providers) in engaging in commerce and offering products and services of value to you. Any consent you provide may be withdrawn at any time by emailing us at privacy@JamDoughnut.com.

9. How long will we retain your data?
We will ensure that all of your personally identifiable information is permanently deleted within the timeframe required by regulation and law after you have requested us to delete it by emailing us at privacy@JamDoughnut.com. If you close your account or it becomes inactive, we will archive and/or delete your data as required by regulation and the law. We will not keep your data for longer than there is a business need or the law requires.

10. What rights do you have?
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights:
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”)
This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you.
This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data
This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request
Object to processing of your personal data
Where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data
This enables you to ask us to suspend the processing of your personal data in the following scenarios:
(a) if you want us to establish the data’s accuracy;
(b) where our use of the data is unlawful but you do not want us to erase it;
(c) 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; or
(d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party
We will provide 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.

11. Other information
Withdraw consent
At any time where we are relying on consent to process 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.
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.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
What you can do to keep your information safe
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
If you make a complaint to us and think we have not dealt with it to your satisfaction, you may send your complaint to the Information Commissioner for investigation. For more information on the Information Commissioner, and how to make a complaint, please visit their website at ico.org.uk. Our ICO company reference is ZA759668.