Jam Coding Ltd (hereinafter “Jam Coding Ltd” or “us” or “we”) is committed to respecting your privacy and is compliant with EU General Data Protection Regulation (GDPR) 2018. Jam Coding Ltd Privacy Policy Statement is designed to help you understand how we collect, use and protect your information when you visit our website and when you generally request information on our products and services whether in person, via email, post, telephone or fax.

Our details

Jam Coding Ltd, company number 11941837, has a registered office address at Blackburn Technology Management Centre, Challenge Way, BB1 5QB

Collection of Personal Information

During the course of dealing with Jam Coding Ltd, we will ask you to provide us with personal information (Your Personal Data). This document is important as it allows us to explain to you what we will need to do with Your Personal Data, and the various rights you have in relation to Your Personal Data.

What do we mean by “Your Personal Data”?

Your Personal Data means any information that describes or relates to your personal circumstances.   Your Personal Data may identify you directly, for example your name, address, date or birth, contact details,  but also include billing information or payment details. As a Provider of Children’s services we also need consent to collect and use information in relation to them, which can include, for example, name, date of birth, gender, medical details (only relevant for emergency purposes) and any other support needs.

The basis upon which we deal with Your Personal Data

When we contact you about our services and requirements, we do so on the basis that both parties are entering a contract for the supply of services. In order to perform that contract, we have the right to use Your Personal Data for the purposes detailed.

Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:

• To comply with our legal and regulatory obligations;
• For the performance of our contract with you or to take steps at your request before entering a contract;
• For our legitimate interests or those of a third party; or
• Where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

We also use your personal information for:

• The provision of products and services to you. This allows us to perform our contract with you or take steps at your request before entering a contract.
• To prevent and detect fraud against you or our companies. This allows us to minimise fraud which could be damaging for both parties.
• To conduct checks to identify customers and verify this identity. This includes other processing required to comply with professional, legal and regulatory obligations the apply to our business. This allows us to comply with our legal and regulatory obligations.
• Gathering and providing information required by or relating to audits, enquiries, investigation by governing bodies. This allows us to comply with our legal and regulatory obligations.
• To ensure business policies are adhered to. For example security and internet usage. This allows us to comply with our legal and regulatory obligations as well as our own internal procedures.
• Operational reasons, to allow us to improve efficiency, training and quality control within our businesses. This is for our legitimate interests or those of a third party allowing us to be efficient in providing, and communicating, our products and services to our clients.
• To ensure confidentiality of commercially sensitive information. For our legitimate interests or those of a third party.
• Statistical analysis to help us manage our business. For example in relation to financial performance, customer base, products or other efficiencies. This will allow us to deliver the best service possible for our clients.
• Preventing unauthorised access and modifications to systems. Allowing us to prevent activity that in unauthorised and could be damaging to both parties and for our legitimate interests.
• Updating and enhancing customer records to allow us to comply with our legal and regulatory obligations and for our legitimate interests. For example, making sure we have up to date contact information in order to communicate about existing or new products with our customers.
• To ensure safe working practices, staff administration and assessments to allow us to deliver our services safely and efficiently.
• To market our services [and those of selected third parties] to:
  • existing and former customers;
  • third parties who have expressed an interest in our services;
  • third parties with whom we have had o previous dealings

For our legitimate interests and those of a third party. For example, to promote our business to existing and former customers.

• Credit reference checks via external credit reference agencies. For our legitimate interests or those of a third party. For example, to ensure customers are able to pay for our products and services where required.
• To communicate promotions and updates to you via email, text message, telephone, post or other digital medium. We have a legitimate interest in processing your personal information for promotional purposes. This means we do not need your consent to send you promotional communications. However, where your consent is needed, we will ask for this separately and clearly. We will always treat your personal information with the utmost respect and never sell or share it with other organisation outside of the Jam Coding group of companies. You have the right to opt out of communications at any time by:
  • Contacting us at info@jamcodingv2.toradigital.co.uk with the email subject ‘opt out’.
  • Using the unsubscribe link in emails or ‘STOP’ number/reply in texts
  • Updating your marketing preferences in your customer account (where available)

We may ask you to confirm or update your marketing preferences if you instruct us to provide further products or services in the future, or if there are changes in the law, regulation, or the structure of the business.

We may need to share information with third parties who help deliver services and run our business, though we endeavour to ensure they take appropriate protection measures.

Alternatively, when the contract between us has come to an end for whatever reason, we have the right to use Your Personal Data provided it is in our legitimate business interest to do so and your rights are not affected.

On occasion, we may need to use Your Personal data to meet a legal, compliance or other regulatory obligation to which we are subject.

The basis upon which we will process certain parts of Your Personal Data

If you have parental responsibility for children, it is a requirement that we will record information on our systems that relates to those children and we have your consent to do so.

How do we collect Your Personal Data?

We will collect and record Your Personal Data from a variety of sources, but mainly directly from you. This can be in person, by telephone, text or email and/or via our website and apps. However, we may also collect information:

• Directly from a third party, e.g:
  • Credit reference agencies;
  • Customer due diligence providers;
• From a third party with your consent
• Via our IT systems, e.g:
  • Our Customer Management Systems
  • Our online payment platforms such as Stripe or PayPal
  • Our internal file storage.
• From cookies on our website (see details below);

Cookie definition/details:

A cookie is a small piece of information that is placed on your computer when you visit certain websites. When we refer to “cookies” we include other technologies with similar purposes, such as tags and identifiers. Find out more about the use of cookies on com/.

When you first visit our sites using a new browser, or if you visit in private browsing mode, we will provide you with a cookies permission banner seeking your consent to use of cookies as required by law. From this banner you will be able to access our cookies management tool.

By clicking OK or clicking through to any part of the site, we will start to manage your visit using cookies.

Out of these cookies, the cookies that are categorised as necessary are stored on your browser as they are essential for the working of basic functionalities of the website. We also use third-party cookies that help us analyse and understand how you use this website. These cookies will be stored in your browser only with your consent. You also have the option to opt-out of these cookies. But opting out of some of these cookies may have an effect on your browsing experience. We also use third party cookies for the purposes of marketing and to help us to understand how our users use the website.

What happens to Your Personal Data when it is disclosed to us?

In the course of handling Your Personal Data, we will:

• Record and store Your Personal Data in our paper files, mobile devices and on our computer systems (email, server, hard drives, cloud facilities etc). This information can only be accessed by employees, selected third parties and service providers.
• Use Your Personal Data for the purposes of responding to any queries you may have or to inform you of any developments in relation to our services.

Security and retention of Your Personal Data

Your privacy is important to us and we will keep Your Personal Data secure in accordance with our legal responsibilities. We will take reasonable steps to safeguard Your Personal Data against it being accessed unlawfully or maliciously by a third party.

Your Personal Data will be retained by us either electronically or in paper format for a minimum of six years, though we may retain records indefinitely, especially in instances whereby we may require the information in the future.

Your rights in relation to Your Personal Data

You can:

• request copies of Your Personal Data that is under our control
• ask us to further explain how we use Your Personal Data
• ask us to correct, delete or require us to restrict or stop using Your Personal Data (details as to the extent to which we can do this will be provided at the time of any such request)
• change the basis of any consent you may have provided to enable us to market to you in the future (including withdrawing any consent in its entirety)

How to make contact with our Firm in relation to the use of Your Personal Data

If you have any complaints, questions or comments about this document, or wish to make contact in order to exercise any of your rights set out within it please contact:

• Mr R. Grogan (Data Protection Officer) on 01254 480 470 or
• By email to info@jamcodingv2.toradigital.co.uk or
• In writing at Jam Coding Ltd, Blackburn Technology Management Centre, Blackburn, BB1 5QB.

If we feel we have a legal right not to deal with your request, or to action it in different way to how you have requested, we will inform you of this at the time.

You should also make contact with us as soon as possible on you becoming aware of any unauthorised disclosure of Your Personal Data, so that we may investigate and fulfil our own regulatory obligations.

If you have any concerns or complaints as to how we have handled Your Personal Data you may lodge a complaint with the UK’s data protection regulator, the ICO, who can be contacted through their website at https://ico.org.uk/global/contact-us/ or by writing to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.