JTORRY MAKEUP ACADEMY PRIVACY & COOKIE  POLICY

1. OVERVIEW OF THIS POLICY

This Privacy Policy (this “Policy”) relates to the personal information that you submit when you access and use our website and other information we automatically collect when you access the website. This Policy explains all activities regarding your information, including but not limited to how we collect, use, disclose, and secure it and the rights available to you. It only applies to the JTorry Makeup Academy website use, including the subdomains of the website. It does not extend to external websites and outgoing links that you can access from this website, including, but not limited to, any links that we will provide to social media sites and other website links. Read the privacy policy of other websites before using them.

All information collected, stored, and analyzed in this website are done so with due diligence, respect, and care, and safeguarded according to the highest standards of privacy and data protection adopted worldwide. You can be assured that we are using state-of-the-art security measures to protect personal information from being accessed by unauthorized users. 

You are required to read, understand, and agree to how we process (collection, use, disclosure, security, etc.) your information in this Policy. You are also required to read our Terms and Conditions and print a copy each for future reference. By your use of the website and your submission of the requested personal information, you hereby agree to how we process your information as described in this Policy. if you do not agree, you should not submit information.

2. WHAT INFORMATION DOES JTORRY MAKEUP ACADEMY COLLECT FROM YOU?

2.1 We collect information from and about users of our Website:

•                   Directly from you when you provide it to us.
•                   Automatically when you use the Website.

2.2 We do not collect special categories of personal data such as information relating to or about the below or information about criminal records.

•                   Health
•                   Racial or ethnic origin
•                   Political opinions
•                   Membership of a political association, professional or trade association
•                   Membership of a trade union
•                   Religious beliefs or affiliations
•                   Philosophical beliefs
•                   Sexual orientation or practices
•                   Biometric information

2.3 Information that you provide to us (“personal information”) when you use our website may include:

•                   First Name, Last Name;
•                   Email Address;
•                   Telephone number; and

2.4 This information may also include:

• Information that you provide by creating an account on the Website such as first name, last name, email address, telephone number, and address (“Contact Information”). This includes information provided at the time of registering to use the Website and requesting further services.
• Information you provide to us when you complete user surveys or surveys for research purposes such as your Contact Information.
• Information you provide to us when you report a problem with the Website such as your first name, last name, and email address.
•  Records and copies of your correspondence (including e-mail addresses and phone numbers), if you contact us.
• Your correspondence within the Website with other users (your username and location).
• Browsing, transaction, membership subscription, and downloading activities. When you visit our website, we will be tracking the products you viewed, content you have downloaded, your location, IP address, and browser type. We will be using these to show the products you’ve recently viewed, for estimating taxes and shipping, and for analytics purposes.When you purchase from us, you will be asked to provide information such as your name, email address, phone number, billing address, credit card/other payment details, and account information like your username and password. We will be storing this information for the purposes of:

• Processing your payments
• Sending you information regarding your account and order
• Providing you with PDF invoices for accounting purposes
• Setting up your account for our website
• Improving our website offerings
• Responding to your requests, such as complaints and others
• Sending you our marketing messages, if you opt to receive them

3. WHAT DOES JTORRY MAKEUP ACADEMY USE INFORMATION COLLECTED FOR?

Any information collected by us is for a purpose in relation to your use of our website, including for providing the services, processing, and delivering your orders.

•  Provide Services to you: We collect information to send you an email about our service, perform tasks required to complete a transaction, provide customer support, or provide other types of customer relationship management and fulfillment. We may also use your information to optimize or improve our Services and operations, for example, training and quality assurance.
• Fulfilling legal and compliance obligations: We collect information to fulfill our legal obligations. Examples of this may include satisfying regulatory screening requirements in connection with entity formations, responding to subpoenas and other legal requests for information, and maintaining records as required in our role as Registered Agent. We may also collect information to detect fraud or other suspicious activity.
•  Analytics: We collect information for use in performing various types of analytics. For example, we use the information to analyze how visitors interact with our website, where visitors to our website arrive from and exit to, pages visited, links clicked, text entered and mouse movements to understand site usage, to detect fraud and potential threats, and improve our services.
• To communicate with you: We collect your email address and phone number to (i) contact you regarding your use of our website/Website, (ii) respond to your questions, complaints, and queries, and (iii) send you updates regarding our services or this Policy and other agreements;
• For other purposes through your consent: We may also process your information for some other reasons which your consent will be sought before we process such information. You may also withdraw your consent at any time.

4. HOW PERSONAL DATA IS COLLECTED

4.1 Automatic Information Collection and Tracking.  

When you access and use the Website, it may use technology to automatically collect:

• Usage Details. When you access and use the Website, we may automatically collect certain details of your access to and use of the Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through the Website.
• Comment Information We collect the data that is shown in the comment form, your IP address, and browser type used.
• Contact Form Details When you send an inquiry through our Contact Form, the information you put on it, including your name, email, subject, and message, may be stored on the server for reference purposes and will remain there unless asked to be removed by you.
• Mailing List Data When you join our Mailing List, your name, email address, and other additional information will be automatically collected. Additional information can include: how much purchase/s you made, when you signed up for the mailing list, and when you updated your preferences for language, country, email client or format. You can unsubscribe from our mailing list by clicking the unsubscribe link found at the bottom of our emails.
• Subscription Information We collect your payment information for easy reference on recurring subscription payments but your sensitive card information will be encrypted by our third party payment process so it will not be visible even to any administrator.
• Cookies Please refer to the Cookies Section for more information.

4.2 If you do not want us to collect this information, please do not create an account with us.

4.3 We may also use these technologies to collect information about your activities over time and across third-party websites, Websites, or other online services (behavioral tracking).

4.4 Information Collection and Tracking Technologies.

The technologies we use for automatic information collection may include:

•  Cookies (or mobile cookies). A cookie is a small file placed on your smartphone or device. It may be possible to refuse to accept mobile cookies by activating the setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website.
• The cookies we use include “analytical” cookies. They allow us to recognize and count the number of visitors and to see how visitors move around the Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.
•  These cookies are used to collect information about how visitors use our Website. We use the information to compile reports on general user traffic, conversion statistics, and to help us improve the site. The cookies collect information anonymously.
• Please note that our advertisers may also use cookies, over which we have no control.
•  Web Beacons. Pages of the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an e-mail and for other related Website statistics (for example, recording the popularity of certain Website content and verifying system and server integrity).
• Third-Party Cookies. The Website may link to other websites owned and operated by certain trusted third parties (for example Facebook) who, for example, collect data that helps us to track conversions from Facebook ads. These other third-party websites may also use cookies or similar technologies in accordance with their separate policies. Please note that our advertisers may also use cookies, over which we have no control.  For privacy information relating to these other third-party websites, please consult their policies as Appropriate.

4.5 Data Security and Protection

We value the great importance of data security. JTorry Makeup Academy has put in place necessary suitable electronic, physical, and managerial procedures that will safeguard and secure the data collected in this website through a secure, encrypted https connection. You can rest assured that no data is taken offline or transferred to a paper copy. If there are certain parts of this website that require password access, you are responsible for keeping your password safe and secure. We recommend that you use a strong password that is at least 10 characters and with at least one of each of the following: a special character, a numerical value, and a capital letter. We will not be held liable for any damage or loss arising from your failure to secure and protect your username and password or other account information. If you decide to knowingly share your account information with others, then you agree to giving them access to your personal data at your own risk. While we endeavor to do our best to protect your personal data, transmission of information over the internet is not truly secure and we cannot guarantee the security of your data transmitted to the website.

5. HOW WE USE PERSONAL DATA AND LAWFUL BASES FOR PROCESSING

5.1 Lawful Bases for Processing under the GDPR

What are the lawful bases for processing personal data? The lawful bases for processing are set out in Article 6 of the GDPR.   At least one of these must apply whenever we process personal data. We mainly use consent, contract, legal obligations, and legitimate interests as the bases to process your data in accordance with this privacy policy.

• Consent: the individual has given clear consent for us to process their data for a specific purpose.
• Contract: the processing is necessary for a contract we have with the individual, or because they have asked us to take specific steps before entering into a contract.
•  Legal obligation: the processing is necessary for us to comply with the law (not including contractual obligations).
• Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s data which overrides those legitimate interests.

6. HOW PERSONAL DATA IS SHARED AND WITH WHOM

Data collected through this website is used only by JTorry Makeup Academy 

However we also use other organizations that may require storing or processing your data so that we can effectively cater to your specific interests or protect the data stored with us. 

• Administrative Administrative members of the JTorry Makeup Academy and other third party organizations, such as technical support or shop managers, may have access to your information to help fulfill your orders, process complaints/refunds, to maintain the website, resolve any technical issues, and other important things in order to support you. The information may include the the following:
  • • • Order information – what was purchased, when it was purchased, and where it should be sent
      • Customer information – your name, email address, billing address and other shipping details
• Analytical This website also uses Google Analytics, Facebook, and other analytical programs to track website behavior and analyze marketing activities and statistics. Information collected by these third-party organizations may be retained indefinitely to allow for more efficient historical analysis and analytical planning.
• Marketing Once you are added to our mailing list, your name and email will be collected. The data will be stored with our third party mailing list platform. Additional data that will be stored can also include: when you signed up, how you signed up, when you updated your preferences, and your preferred email format. It will use your data to predict your gender, age, country, preferred language, and preferred email client, among others.
• Payments Payments are processed by our third party payment partner that is compliant with stringent international regulations. Because of this, your personal data may be shared with an external service by our payment partner.
• Security Comments and user login information may be checked by an automated spam detection through an authorized partner/third-party organization.

Jtorry Makeup Academy does not sell or share your personal information to third parties but may share your information if the need arises such as the following:

• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our Website users is among the assets transferred.
• For any other purpose disclosed by us when you provide the information.
• For academic research.
• For any other purpose with your consent.
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce our rights arising from any contracts entered into between you and us.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.

7. WHAT ARE YOUR PRIVACY RIGHTS?

If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you have questions or comments about your privacy rights, you may email us at Info@jtorrymakeupacademy.com.

8. YOUR RIGHTS WITH RESPECT TO PERSONAL DATA.

• You can review and change your personal information by logging into the Website and visiting your account settings page.
• You may also send us an email at Info@jtorrymakeupacademy.com to request access to, correct, or delete any personal information free of charge that you have provided to us. We cannot delete your personal information except by also deleting your user account.
• We will respond to a request to access, correct, or delete any data within 30 days of the date we receive the request.
• We may not accommodate a request to change information if we believe the change would violate or breach any law or legal requirement or cause the information to be incorrect.
• If on your request, we refuse to amend, correct, or delete your personal information, we will set out our reasons for not doing so and provide you with details of how you may complain about our refusal.
• If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other Website users. Proper access and use of information provided on the Website, including User Contributions, is governed by our Terms and Conditions

9. HOW LONG PERSONAL DATA IS KEPT

We will only retain personal data for as long as is reasonably necessary and for our own purpose of collecting and using it. Upon deletion of an account, all personal data will be removed as soon as possible, and always within 90 days of the deletion.

• Comment If you leave a comment on our website, your comment and its metadata will be kept indefinitely. This is for easy recognition and approval for any follow-up comments.
• General Contact, Mailing List, and Account Registration We retain the data you submitted after signing up to our mailing list, sending us an email, submitting a form, or registering to an account on our website. We will store your personal information during registration on our website for your personal profile. Users and website administrators can view, edit, or delete personal information at any time. Your data will remain on the server until you ask us to remove it or you ask to be removed from our services.
• Subscription Your payment information will be retained so we can take your recurring payment details on record. However, your sensitive card information will be encrypted and will not be visible to any administrator.
• Cookies Please see the cookies section for more information.

10.LEGAL BASIS FOR THE PROCESSING OF PERSONAL INFORMATION

1. We rely upon both consent and legitimate business interests for processing personal information. For example, we may process PII with a User’s consent when they agree that we may place cookies on their devices, or that we can process information that they enter into a form on one of our sites.
2. It is in our interest as a business to enhance the services that we provide which may include processing your information to enable us to:

• Respond to User inquiries and to fulfill User requests
• Send Customers or Potential Customers relevant marketing information and offers
• Complete transactions
• Provide customer service
• Send administrative information
• Personalize Users’ experiences with our sites
• Do so where we are required to by law

3. We may also process Personal information when it is in our or a Users’ legitimate interests to do so and when these interests are not overridden by an individual’s data protection rights.

11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Services or Websites, you have the right to request removal of unwanted data that you publicly post on the Services or Websites. To request the removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services or Websites, but please be aware that the data may not be completely or comprehensively removed from our systems.

12.DATA SECURITY

We have implemented multiple security measures designed to secure your personal information from accidental loss and unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL technology.

The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

13.DATA BREACH PROCEDURE

We have put in place a protocol that will be activated should a breach in data occur. We will promptly secure the breach and any relevant third parties will be immediately contacted to ensure that our data security is reinforced. A thorough investigation will follow in order to determine what caused the breach, what data has been breached, and who are affected. Following the investigation, all affected parties will be duly notified to confirm what type of data has been breached and what to do. Finally, we will take the necessary steps to ensure that the same incident will not occur again.

14.COOKIE POLICY

Cookies are text files with small amounts of information that are downloaded to your personal computers, mobile phones, and other devices when you visit a website. For every subsequent visit, cookies are sent back to the website or other websites that recognize the cookie.

1. This website uses Cookies to improve your user experience and enhance the range of products and services that we offer. We have taken the necessary steps to carefully choose these Cookies and ensure that your privacy is protected and respected.
2. All Cookies used in this website are in accordance with worldwide standards including the UK and EU Cookie Law.
3. Before this website places Cookies on your computer, you will be receiving a pop-up request to signify your consent to set the Cookies. By giving your consent to place the Cookies you are enabling JTorry Makeup Academy to provide you with a better experience and service. You may deny your consent to place the Cookies but certain features of this website may not function properly or as intended.
4. This website may place the following types of Cookies:
   1. Strictly necessary cookies are important cookies for the proper operation of our website. These can include cookies that enable you to: log into secure areas of the website, use a shopping cart, or use the e-billing services.
   2. Functionality cookies are cookies that we use to recognize you when you come back to visit our website. This will allow us to personalize your website experience; greet you by your name, offer customized content for you, and remember your preferences (such as chosen language or region).
   3. Analytical/performance cookies allow us to recognize and count the number of visitors to our website and track their movements while using the website. This can greatly help us to improve how our website should work, like how to make sure that users can easily find what they are looking for.
   4. Targeting cookies allow us to record your visit to our website, the number of pages that you have visited, and the links that you have followed. We use this vital information to make sure that the content of our website and the advertising that we display on it become more relevant to your own interests. Because of this purpose, we may also share the information with third party organizations.
   5. Third party cookies allow third parties to track and determine how successful their application is or customize their application for the website users. Cookies work in such a way that we cannot access the information in these types of cookies nor can third parties. For example, if you share our content on Facebook, Twitter, or other social media sites, those third-party social media sites will send cookies to you. We don’t control those cookies and we recommend that you check those websites for more information regarding their Cookie Policy.

5. You can enable or disable Cookies in the internet browser. By default, internet browsers are set to accept Cookies automatically but you can change it. For more details on this, you can consult your internet browser’s Help menu.
6. You have the option to delete the Cookies at any time but you will lose any information that may enable you to access this website more quickly and efficiently; this includes, but not limited to, personalized settings.
7. We recommend that you ensure your browser is up-to-date. If you are not sure about adjusting your privacy settings, then we recommend that you consult with the developer of your internet browser for help and guidance.

15.CHILDREN POLICY

We do not permit users that are below the age of majority (usually 18 years in most countries) to submit personal information and purchase from us unless they have support from their parents or legal guardian. By submitting personal information to us, you represent to us that you are 18 years of age or above and that you can be bound by this Policy.

16.CHANGES TO OUR PRIVACY POLICY

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Website home page. If we make material changes to how we treat our users’ personal information, we will notify you by e-mail to the primary e-mail address specified in your account and/or through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.