Last updated: 28.04.2023

S.M.JALEEL & COMPANY LIMITED.

This Privacy Notice for S.M. Jaleel & Company Limited and all its subsidiary and affiliated companies (hereinafter collectively referred to as “Company,” “we,” “us,” or “our”), describes how and why we might collect, store, use, and/or share (“process”) your information when you use our services (“Services”), such as when you:

  • Visit our website at http://www.smjaleel.net/ or any website of ours that links to this Privacy Notice.
  • Use our application(s), such as our e-commerce site, https://www.shopsmj.com or our various Facebook, Instagram and other social media pages or any other application of ours that links to this Privacy Notice
  • Engage with us in other related ways ― including but not limited to any sales, marketing, events, contests and online polls.

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at privacyqueries@smjaleel.com

SUMMARY OF KEY POINTS

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with S.M. Jaleel & Company Limited and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information? We do not process sensitive personal information.

Do you receive any information from third parties? We may receive information from public databases, marketing partners, social media platforms, and other outside sources.

How do you process my information? We allow third parties including Google Analytics, Meta Suite, Smile.IO and UpPromote to access and process your information in order to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with the stipulated law. For instance, we use your name and contact information in order to keep you informed of the services and products we offer through subscriptions to our newsletters and whatsapp blasts. We may also allow the access and processing of your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

In what situations and with which types of parties do we share personal information? We share information in specific situations and with specific categories of third parties. The said third parties  assist us by processing your information for the purposes described above. These third parties protect your information which they are permitted to  access. More information on how these third parties do this can be found on: https://www.shopify.com/legal/privacy

https://woobox.com/privacy

https://policies.google.com/privacy?hl=en-US

https://www.facebook.com/privacy/policy/

https://smile.io/privacy-policy

https://docs.uppromote.com/set-up/affiliate-registration-form/sample-privacy-policy

How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

Want to learn more about what S.M. Jaleel & Company Limited does with any information we collect?

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE PROCESS YOUR INFORMATION?

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

5. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

7. HOW LONG DO WE KEEP YOUR INFORMATION?

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

9. DO WE COLLECT INFORMATION FROM MINORS?

10. WHAT ARE YOUR PRIVACY RIGHTS?

11. CONTROLS FOR DO-NOT-TRACK FEATURES

12. DO WE MAKE UPDATES TO THIS NOTICE?

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You.

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

  • Age
  • Contact number
  • Email address

If you use our Services we also may collect the following information if you choose to provide us with access or permission:

  • . We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application(s), to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device’s settings. If you are a citizen of Trinidad and Tobago, when you enter contests and/or online competitions which we host, we may collect data related to the region in which you are located within Trinidad and Tobago.
  • . We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our Services, we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID, and information about the features of our Services you accessed.

This information is primarily needed to maintain the security and operation of our Services, for troubleshooting, and for our internal analytics and reporting purposes.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

  • We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.We also collect Device Data using the following technologies:
  • We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

Information collected when you use our Services on social media platforms, namely the Facebook/Instagram application(s).

Third Parties such as Meta Suite, would by default access your Facebook and Instagram basic account information, including your name, email, gender, birthday, current city, and profile picture URL, as well as other information that you choose to make public. Meta Suite may also access other permissions related to your account, such as friends, check-ins, and likes, and you may choose to grant or deny us access to each individual permission. For more information regarding Facebook permissions, refer to the FacebookPermissions Reference page.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

  • To facilitate account creation and authentication and otherwise manage user accounts. We, through Third Parties, may process your information so you can create and log in to your account, as well as keep your account in working order.
  • To deliver and facilitate delivery of services to the user. We, through Third Parties, may process your information to provide you with the requested service.
  • To respond to user inquiries/offer support to users. We, through Third Parties,  may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
  • To send administrative information to you. We, through Third Parties,  may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
  • To fulfill and manage your orders. We, through Third Parties, may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.
  • To enable user-to-user communications. We, through Third Parties, may process your information if you choose to use any of our offerings that allow for communication with another user.
  • To request feedback. We, through Third Parties, may process your information when necessary to request feedback and to contact you about your use of our Services.
  • To send you marketing and promotional communications. We, through Third Parties, may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see “WHAT ARE YOUR PRIVACY RIGHTS?” below).
  • To deliver targeted advertising to you. We, through Third Parties, may process your information to develop and display personalized content and advertising tailored to your interests, location, and more.
  • To protect our Services. We, through Third Parties, may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
  • To identify usage trends. We, through Third Parties, may process information about how you use our Services to better understand how they are being used so we can improve them.
  • To determine the effectiveness of our marketing and promotional campaigns. We, through Third Parties, may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
  • To save or protect an individual’s vital interest. We, through Third Parties, may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services, to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

  • Consent. We/Third Parties we permit, may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
  • Performance of a Contract. We/Third Parties we permit, may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
  • Legitimate Interests. We/Third Parties we permit, may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
  • Send users information about special offers and discounts on our products and services
  • Develop and display personalized and relevant advertising content for our users
  • Analyze how our services are used so we can improve them to engage and retain users
  • Support our marketing activities
  • Diagnose problems and/or prevent fraudulent activities
  • Understand how our users use our products and services so we can improve user experience
  • Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
  • Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

  • If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
  • For investigations and fraud detection and prevention
  • For business transactions provided certain conditions are met
  • If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
  • For identifying injured, ill, or deceased persons and communicating with next of kin
  • If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
  • If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
  • If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
  • If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
  • If the collection is solely for journalistic, artistic, or literary purposes
  • If the information is publicly available and is specified by the regulations

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (“Third Parties”) such as Shopify, Woobox, Google Analytics, Meta Suite, Smile.IO and UpPromote who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The above-mentioned Third Parties also have their own privacy policies that govern how they collect, manage and use your data and can be found on their respective websites. The categories of Third Parties we may share personal information with are as follows:

  • Ad Networks
  • Affiliate Marketing Programs
  • Cloud Computing Services
  • Communication & Collaboration Tools
  • Data Analytics Services
  • Data Storage Service Providers
  • Finance & Accounting Tools
  • Government Entities
  • Order Fulfillment Service Providers
  • Payment Processors
  • Performance Monitoring Tools
  • Product Engineering & Design Tools
  • Retargeting Platforms
  • Sales & Marketing Tools
  • Social Networks
  • Testing Tools
  • User Account Registration & Authentication Services
  • Website Hosting Service Providers

We also may need to share your personal information in the following situations:

  • Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
  • Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.
  • Other Users. When you share personal information [(for example, by posting comments, contributions, or other content to the Services including social media platforms referenced herein)] or otherwise interact with public areas of the Services, such personal information may be viewed by all users and may be publicly made available outside the Services in perpetuity. If you interact with other users of our Services and register for our Services through a social network (such as Facebook), your contacts on the social network will see your name, profile photo, and descriptions of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Services, and view your profile.

5. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our services using a social media account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform. If you log in using Facebook, we may also request access to other permissions related to your account, such as your friends, check-ins, and likes, and you may choose to grant or deny us access to each individual permission.

We will use the information we receive only for the purposes that are described in this Privacy Notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their Privacy Notice to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps.

6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in Trinidad and Tobago and the United States of America. If you are accessing our Services from outside Trinidad and Tobago and the United States of America, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those Third Parties with whom we may share your personal information.

If you are a resident in the European Economic Area (EEA) or United Kingdom (UK), then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this Privacy Notice and applicable law.

European Commission’s Standard Contractual Clauses:

We have implemented measures to protect your personal information, including by using the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies and between us and our Third-Party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. 

7. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

9. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data  from children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services.

We use images for minors strictly for purposes linked to advertising of our brands of products geared towards children and showcasing of events hosted by us. All images of minors used for these purposes have been obtained with prior verifiable parental consent of the minors depicted therein. We may also use images of minors which are obtained from third parties including Shutterstock, Canva and Invideo solely for the purpose of advertising  our Services. Therefore, we assume no liability for any use of said images other than for which is provided in this Privacy Notice.

If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at privacyqueries@smjaleel.com

10. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK 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: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below or updating your preferences.

However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months:

CategoryExamplesCollected
A. IdentifiersContact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name  [YES]
B. Personal information categories listed in the California Customer Records statuteName, contact information, education, employment, employment history, and financial information  [NO]
C. Protected classification characteristics under California or federal lawGender and date of birth  [YES]
D. Commercial informationTransaction information, purchase history  [YES]
E. Biometric informationFingerprints and voiceprints  [NO]
F. Internet or other similar network activityBrowsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements  [NO]
G. Geolocation dataDevice location  [YES]
H. Audio, electronic, visual, thermal, olfactory, or similar informationImages and audio, video or call recordings created in connection with our business activities  [NO]
I. Professional or employment-related informationBusiness contact details in order to provide you our services at a business level or job title, work history, and professional qualifications if you apply for a job with us  [NO]
J. Education InformationStudent records and directory information  [NO]
K. Inferences drawn from other personal informationInferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics  [YES]

We may also collect other personal information outside of these categories instances where you interact with us in person, online, or by phone or mail in the context of:

  • Receiving help through our customer support channels;
  • Participation in customer surveys or contests; and
  • Facilitation in the delivery of our Services and to respond to your inquiries.

11. CONTROLS FOR DO-NOT-TRACK FEATURES

Many companies may track your web browsing behavior for analytics and advertising purposes. Some web browsers may transmit “DO NOT TRACK” (also know as “DNT”) signals to applications through which you communicate. We appreciate that some users do not want to be tracked, so they enable the “Do Not Track” (DNT) option in their browsers.

This “Do Not Track option” in your browsers, allows you to send a Do Not Track request with your browsing traffic. While websites are not obligated to comply with Do Not Track requests, we must disclose to you how we currently handle DNT requests. We currently do not change tracking practices in response to DNT settings in your web browser.

Third Parties with whom we contract, such as web analytics companies may collect information about you and your online activities from time to time and across our Services. These third parties may or may not change their tracking practices in response to DNT settings in your web browser. For more information on these third parties’ response to DNT signals, you can read their privacy policies on their respective websites.

12. DO WE MAKE UPDATES TO THIS PRIVACY NOTICE?

In Short: Yes, we will update this Privacy Notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact our Data Protection Officer/IT Team via email at:  privacyqueries@smjaleel.com

14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please visit:  privacyqueries@smjaleel.com