This privacy policy sets out how JAR Matrix Cosmetics (JAR Matrix) uses and protects any information that you give us when you use this website.

We are Venn Helix Limited, a company incorporated in England and Wales under registration number 10101061. Our registered office is Alpha House 296 Kenton Road, Kenton, Harrow, HA3 8DD, United Kingdom. (“JAR Matrix” / “we”/ “our” / “us”).

We are committed to ensuring that your privacy is protected and we strictly adhere to the provisions of the UK GDPR (UK General Data Protection Regulation), together with the Data Protection Act 2018, any national implementing laws, regulations and secondary legislation as amended or updated from time to time in the UK, and any successor legislation to GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003 (Data Protection Legislation).

In order for JAR Matrix to provide our products and services we need to process a certain amount of data, some of which is personally identifiable.

Our Privacy Policy sets out the different kinds of personal data we process, how we collect it, what processing is carried out, who personal data is shared with, how long we keep personal data and how we safeguard it along with details of your rights relating to data protection and how to contact the ICO, the UK’s data protection regulator.

We process data on the following categories of individuals:

• Learners / System Users
• Customers & prospective customers
• Website visitors & online customers
• Articles / resources subscribers
• Suppliers, sub-contractors & freelancers
• Sub processors and other 3rd parties

Learners / System Users

To access JAR Matrix Portal, our Learning Management System (LMS), and complete training and other associated activities, users require an account. Having an account means JAR Matrix is storing the personal data you provide, and we further process this to determine training outcomes and retain certification records as well as analyse content and system usage, improve our products and services, and respond to support queries and evaluation comments. Where a learner has accessed or is allocated a JAR Matrix course, directly from JAR Matrix, JAR Matrix is the data controller.

If your login details or training has been provided by a 3rd party (e.g. your employer, another training organisation) then they will be joint data controller, along with JAR Matrix where applicable and also have access to and will be processing your personal data. Should you require any further information you should contact them directly. If you are unsure who to contact JAR Matrix may be able to assist, please email support@jarmatrix.com. Where a 3rd party has provided system access, and no JAR Matrix content is allocated to the user, then JAR Matrix is a data processer, and the relevant 3rd party sole data controller.

JAR Matrix retains learning records ad infinitum, under its commitment to lifelong learning, to enable us to provide factual information on what a learner has studied and achieved, i.e. name, courses studies, CPD gained, test results etc.

Customers & prospective customers

All customers and prospective customers have a record with our database. Along with details about the organisation and products purchased, we also store contact information for those people we know at the organisation. For customers we process this data for us to meet out contractual obligations, for prospective customers our condition for processing is legitimate interest.

Website visitors & online customers

When you place an order with us on our website, we will ask you to provide certain personal information, for example:

• your name; and
• your email address.

Please note that we require this information to be able to process your order and fulfil our contractual obligations (our condition for processing under UK GDPR). We may be unable to fulfil the contract without your personal data. If you purchase services, our third party payment provider (Stripe - you can view their privacy information here) will require additional personal information in order to process such payment (e.g. your home address). Please note that this information is not collected or stored by us. Your personal information will then be used by us to provide you with the services you ordered and to communicate with you regarding the provision of those services. We also monitor website usage and provide statistics to third parties for the purposes of improving and developing our website and the services we provide via our website. Please note that any such statistics and/or information provided to third parties will be made on a confidential basis and will not include information that can be used to identify any individual.

Communication Rules regarding Marketing Information

Please note that our marketing approach differs depending on the type of the customer.

• If you are a B2B Customer that means you have purchased from us directly either online or via our Sales Team using your organisation/professional email address.

Based on the legitimate interest we will continue to contact you with the marketing material containing information related to the products/services purchased and similar products and services that we think might be of interest to you. Legitimate interest will be the legal basis for contacting you. If you decide at any point that you don’t want to receive any marketing communication from us, you will be able to unsubscribe and opt-out, using the ability to update your preference provided within all marketing communications sent.

• If you are a B2C Customer that means you are an Individual Consumer or a Sole Trader and you have purchased/engaged with us directly usually online or via our Sales Team using your personal email address.

In order to contact you with the marketing material containing information related to the products/services purchased and similar products and services that we think might be of interest to you. When purchasing we will give you the option to opt into receiving marketing communication from us. Your consent will be the legal basis for contacting you. If you decide at any point that you don’t want to receive any marketing communication from us, you will be able to unsubscribe and opt-out, using the ability to update your preference provided within all marketing communications sent.

• If you are a Learner that means the training and learner account has been allocated to you but you haven’t purchased it directly from JAR Matrix.

We won’t be contacting you with any marketing material unless you subscribe to our Newsletter and Marketing communications via our website. Your consent will be the legal basis for contacting you. If you decide at any point that you don’t want to receive any marketing communication from us, you will be able to unsubscribe and opt-out, using the ability to update your preference provided within all marketing communications sent.

• If you are a Prospect that means that you have engaged with us as B2B organisation using your organisation/professional email address or B2C using your personal email address.

Based on the legitimate interest we will contact you with the marketing material containing information related to products and services that we think might be of interest to you. Legitimate interest will be the legal basis for contacting you. If you decide at any point that you don’t want to receive any marketing communication from us, you will be able to unsubscribe and opt-out, using the ability to update your preference provided within all marketing communications sent.

Articles / resources subscribers

When you fill out a webform to sign up to articles, download a resource, such as an infographic, or enquire about a product, we may ask you to provide certain personal information, including your:

• your name; and
• your email address.

By completing the form and ticking the relevant boxes you are providing your consent for JAR Matrix to process your personal data, and this is the legal basis we are relying on to do so. We will use the information that you give us to send you relevant emails containing JAR Matrix articles & resources communications. Some automation and profiling may be used to send emails or a series emails based on your indicated preferences and your interactions with the emails we send to you. For example, if you have enquired about a particular product we may send you a series of emails outlining features or benefits of that particular product. We regularly review your interactions with the emails we send you and remove any subscribers who have shown an extended period of inactivity. You can withdraw your consent and unsubscribe at any time by clicking the link at the bottom our email communications or by emailing us at support@jarmatrix.com. If you continue to interact with our emails or website, we will retain your data indefinitely so we can continue to send you emails. We will not sell or pass your information to third parties other than those set out above.

Suppliers, sub-contractors & freelancers

Personal data provided by suppliers is only used for purposes related to the supply of goods or services for which we have contracted.

Sub processors and other 3rd parties

JAR Matrix utilises a number of sub processors and other 3rd parties to support and enhance the delivery of our services. These are listed below.

• Stripe – our payments provider
• Erinlabs – assist with website development and maintenance
• Digital Ocean – our website host
• Campaign Monitor - marketing automation tool
• Adobe Learning Service

How do we safeguard your personal data?

Protecting your privacy is extremely important to us and we make every effort to secure your information and maintain your confidentiality in accordance all relevant Data Protection Legislation. Our systems are protected by various levels of security technology, which are designed to protect your information from any unauthorised or unlawful access, processing, accidental loss, destruction, and damage.

Please note that we may need to disclose your personal information where we:

• are under a legal duty to comply with any legal obligation or to enforce or apply our terms and conditions; or
• need to disclose it to protect our rights, property or safety of our customers or others, including the exchange of information with other companies, organisations and/or governmental bodies for the purposes of fraud protection and credit risk reduction.

Your rights

The UK GDPR provides you with the following rights:

The right of access

You can ask us to confirm that we process your personal data and provide access to and copies of the information we hold about you by contacting us at support@jarmatrix.com. We will process your request to access your information and provide this information to you free of charge unless your request is manifestly unfounded or excessive or repetitive, in which case we are entitled to charge a reasonable fee. We may also charge if you request more than one copy of the same information. We will provide the information you request as soon as possible and in any event within one month of receiving your request unless there are extenuating circumstances. If we need more information to comply with your request, we’ll let you know.

The right to rectification

If you believe personal data we hold about you is inaccurate or incomplete, or any of the information you provide to us changes, please let us know as soon as possible so that we can make the necessary changes to the information we hold for you on our database. If you wish to make any changes to your information, please contact us at support@jarmatrix.com.

We will comply with your request within one month of receiving it, unless we don’t feel its appropriate for us to do so in which case we’ll let you know why. We’ll also let you know if we need more time to comply with your request.

The right to erasure

In some circumstances, you have the right to ask us to delete personal data we hold about you. This right is available to you:

• where we no longer need your personal data for the purpose for which we collected it;
• where we have collected your personal data on the grounds of consent and you withdraw that consent;
• where you object to the processing and we don’t have any overriding legitimate interests to continuing processing the data;
• where we have unlawfully processed your personal data (i.e. we have failed to comply with UK GDPR);
• where the personal data has to be deleted to comply with a legal obligation; and
• where the personal data we process relates to the offer of online services to a child.

There are certain scenarios in which we are entitled to refuse to comply with a request. If any of those apply, we’ll let you know. To request that your information is deleted, please contact us at support@jarmatrix.com.

The right to restrict / object to processing

In some circumstances you are entitled to ask us to suppress processing of your personal data. This means we will stop actively processing your personal data but we don’t have to delete it. This right is available to you:

• if you believe the personal data we hold isn’t accurate – we’ll cease processing it until we can verify its accuracy;
• if you have objected to us processing the data (see below) – we’ll cease processing it until we have determined whether our legitimate interests override your objection;
• if the processing is unlawful; or
• if we no longer need the data but you would like us to keep it because you need it to establish, exercise or defend a legal claim.

You are entitled to object to us processing your personal data:

• if the processing is based on legitimate interests or performance of a task in the public interest or exercise of official authority;
• for direct marketing purposes (including profiling); and/or
• for the purposes of scientific or historical research and statistics.

In order to object, you must have grounds for doing so based on your particular situation. We will stop processing your data unless we can demonstrate that there are compelling legitimate grounds which override your interests, rights and freedoms or the processing is for the establishment, exercise or defence of legal claims. If you wish to restrict or object to the processing of your information, please contact us at support@jarmatrix.com.

The right to data portability

You have the right to ask us to provide your personal data in a structured, commonly used and machine-readable format so that you are able to transmit the personal data to another data controller. This right only applies:

• to personal data you provide to us;
• where processing is based on your consent or for performance of a contract (i.e. the right does not apply if we process your personal data on the grounds of legitimate interests); and
• where we carry out the processing by automated means.

If you wish to restrict or object to the processing of your information, please contact us at support@jarmatrix.com.

Rights in relation to automated decision making and profiling

Automated decision-making means making a decision solely by automated means without any human involvement. This would include, for example, an online credit reference check that makes a decision based on information you input without any human involvement.

We carry out automated decision making using your personal data as detailed under the Articles / Resources Subscribers heading above.

For further information on these rights you can contact the ICO via one of the options on their website https://ico.org.uk/global/contact-us/.

Our website may contain links to other websites. Please be aware that we are not responsible for the privacy practices of such other websites. This privacy policy applies solely to information collected on our website.

Please note that we may change our Privacy Policy from time to time. If we make any changes, these will be shown on our website and will immediately supersede any previously posted information.

For whatever reason, should you wish to lodge a complaint with the Information Commissioner’s Office, as is your right, you can do by contacting the ICO directly via one of the options on their website https://ico.org.uk/global/contact-us/.

This privacy policy was last updated on 09/05/2023.