Privacy policy.
We take your privacy very seriously. Please read this Privacy Policy (hereinafter “Policy”) carefully as it contains important information on who we are and what are our information practices, meaning how and why we collect, use, disclose, sell, share, store, and retain your personal information. It also explains your rights in relation to your personal information and how to contact us or the appropriate supervisory authority(ies) in the event that you have an inquiry or a request. If there are any terms in this Policy with which you do not agree, please discontinue use of our Site and contact us immediately. Thank you.
This website https://www.justaskmoira.com/ (hereinafter “Site”) is owned by “Just Ask Moira, LLC,” a Wyoming Limited Liability Corporation. This Site is hosted at a server company called Squarespace. Their privacy policy can be found here: https://www.squarespace.com/privacy.
We only have access to/collect information that you voluntarily provide to us when you express an interest in obtaining information about us and/or the services provided by this Site, when you participate in activities on the Site, or otherwise when you contact us. The personal information that we collect depends on the context of your interactions with us and our Site, the choices you make, and the services and features of this Site that you decide to use. Unless you ask us not to, we may contact you via email in the future to tell you about specials, new services, or changes to this Policy.
As a result of your interactions with us and our Site, you are providing us with information that we collect, use, and for which we are responsible. For instance, when we are contacted by and offer our Services to individuals in the European Economic Area (EEA), we are subject to the EU General Data Protection Regulation (EU GDPR), which applies across the entire European Union. For California consumers, we are subject to the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA). We are responsible as a "controller" of that personal information for the purposes of the GDPR. We are responsible for your personal information as a "business" under the CCPA/CPRA.
All activities in which you may engage on this Site are voluntary. You are not required to provide any personal information to us unless you choose to access features on this Site that require the information. If you do not agree with the terms of this Policy, or other terms and conditions posted at https://www.justaskmoira.com/terms-conditions, then you should immediately exit this Site and discontinue using this Site. If you do not agree with the terms of this Policy, please do not provide us with personal information and leave this Site. By using this Site, you signify that you agree to the terms of this Policy.
A. Key Terms:
“We,” “Us,” “Our", or “JAM” refers to “Just Ask Moira,” “Just Ask Moira, LLC,” and “justaskmoira.com.”
“Site” refers to “https://www.justaskmoira.com/”
“You,” “Your,” “Customer,” or “Consumer” means any person or entity who visits and/or provides information to “Just Ask Moira, LLC” via this website.
“Personal information” (or “personal data”) and “sensitive personal information” shall have the meanings of any information relating to an identified or identifiable individual, and personal information revealing a consumer's social security number, driver's license and passport numbers, account numbers and credentials, precise geolocation, racial or ethnic origin, religious beliefs, or union membership, personal information concerning a consumer's health, relationship status, sex life, or sexual orientation, contents of a consumer's mail, email and text messages where the business is not the intended recipient, or citizenship and immigration status. See, Cal. Civ. Code § 1798.140(v)(1) and Cal. Civ. Code § 1798.140(ae)(1). GDPR Article 4(1).
“Categories of sources” means types or groupings of persons or entities from which a business collects personal information about consumers. See, Cal. Code Regs. tit. 11, § 7001(e).
“Cookie” is a piece of data stored on a site visitor’s hard drive to help us improve your access to the site and identify repeat visitors to our Site.
“Resident(s)” as defined by the California Code of Regulations: (1) every individual who is in the State of California for other than a temporary or transitory purpose and; (2) every individual who is domiciled in the State of California who is outside the State of California for temporary or transitory purposes. All other individuals are defined as “non-residents.” If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.
“User” refers to any individual(s) using this Site who, unless otherwise specified, coincides with the Data Subject.
“Data Subject” means the natural person to whom the Personal Data refers.
“European Union:” Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
A “legitimate interest” is when a business or commercial reason exists for us to use your information, so long as this is not overridden by your own rights and interests.
B. Personal Information that You Provide and that We Collect About You. We may collect and use the following personal information, including sensitive personal information, that you provide, and which identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
Categories of Personal Information include:
Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (“IP”) address, email address, account name, social security number, driver's license number, passport number, or other similar identifiers).
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, their name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.
Characteristics of protected classifications under California, the United States of America, or federal law.
Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies).
Professional or employment-related information.
Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA), and/or other applicable law(s).
Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Racial or ethnic origin, religious or philosophical beliefs, union membership, or citizenship or immigration status.
Contents of a consumer's mail, email, and text messages unless the business is the intended recipient of the communication.
Health information.
Relationship status and/or family information.
Sex life or sexual orientation.
If you do not provide personal information required to provide services to you, it may delay or prevent us from providing services to you. It is entirely your option as to whether to provide your personal information.
See, Cal. Civ. Code §§ 1798.110(c)(1) and 1798.130(a)(5)(B)(i); Cal. Civ. Code § 1798.140(v)(1)(A) through (K); Cal. Civ. Code § 1798.130(c); Cal. Civ. Code § 1798.140(ae); Cal. Civ. Code § 1798.130(c); and Cal. Civ. Code §1798.110(c)(5). See, also, Articles 13 and 14 of Regulation (EU) 2016/679, GDPR.
C. How Your Personal Information is Collected. We collect personal information from the following categories of sources:
You, directly in person, by telephone, text, or email (and/or via our Site (and other, commonly integrated or utilized, third-party apps such as “Facebook Messenger,” “Instagram Direct Messenger,” “Zoom,” “FaceTime,” etc.));
Third party with your consent (e.g., your bank);
Advertising networks;
Internet service providers;
Data analytics providers;
Government entities;
Operating systems and platforms;
Social networks;
Data brokers;
Publicly accessible sources (e.g., property records);
Cookies on our Site;
Our IT and security systems, including:
a. Automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email, and instant messaging systems –and–
b. Any other relevant systems.
See, Cal. Civ. Code §1798.110(c)(2). The categories listed in this section are merely examples, some of which are provided in Cal. Code Regs. tit. 11, § 7001(e). See, also Article 14(2)(f) of Regulation (EU) 2016/679, GDPR.
D. How and Why We Use the Personal Information that You Elect to Provide: Under data protection laws, we can only use your personal information if we have a proper reason for doing so, for example:
Where you have given consent.
a. We may process your data if you have given us specific consent to use your personal information for a specific purpose.To comply with our legal and regulatory obligations.
a. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).For the performance of our contract with you or to take steps at your request before entering into a contract.
a. Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.For our legitimate interests or those of a third party –or–
a. We may process your data when it is reasonably necessary to achieve our legitimate business interests, or those of a third party.Vital interests.
a. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your data or share your personal information in the following situations:
Business transfers –or–
a. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.Vendors, Consultants, and Other Third-Party Service Providers.
a. We may share your data with third-party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: Payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Site, which will enable them to collect data on our behalf about how you interact with our Site over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, pages or features, and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
Consent is only one of the bases on which we can lawfully process data under the GDPR. There are five (5) alternatives, i.e., processing is necessary for:
The performance of a contract to which the data subject is a party or to take steps at the request of the data subject before entering into a contract.
Compliance with a legal obligation to which you are subject.
Protecting the vital interests of the data subject or another natural person.
The performance of a task carried out in the public interest or in the exercise of official authority vest in you.
Legitimate interests pursued by our organization or a third party, except where such interests are overridden by interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular, where the data subject is a child.
Two areas where we can expect to need consent are:
When processing special category personal data (see, above Section “B”).
When engaging in electronic direct marketing that does not meet the conditions for soft opt-in (see, below Section “E”).
See, Article 6(1) of Regulation (EU) 2016/679, GDPR.
The list below sets out common processing operations and whether consent is required—or whether another lawful ground is more appropriate:
For conducting checks to identify customers and verify their identities, screening for financial and other sanctions or embargoes, or other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g., under health and safety regulations, the potential ground is Art 6(1)(c)–compliance with a legal obligation, but only to the extent that this is "necessary" for compliance with a legal obligation. Otherwise, Art 6(1)(f)–legitimate interests.
For gathering information as part of investigations by regulatory bodies, the potential ground is Art 6(1)(c)—but only to the extent that this is "necessary" for compliance with a legal obligation. Otherwise, Art 6(1)(f)—legitimate interests.
For ensuring business policies are adhered to, e.g., policies covering security and internet use, the potential ground is Art 6(1)(f)–legitimate interests.
For operational reasons, such as improving efficiency, training, and quality control, the potential ground is Art 6(1)(f)–legitimate interests.
For statistical analysis to help manage your business, the potential ground is Art 6(1)(f)–legitimate interests.
For preventing unauthorized access and modifications to systems, the potation grounds are Art 6(1)(c)—compliance with a legal obligation, but only to the extent that this is "necessary" for compliance with a legal obligation and Art 6(1)(f)—legitimate interests.
For statutory returns, the potential ground is Art 6(1)(c)—compliance with a legal obligation.
For staff administration and assessments, monitoring staff conduct, disciplinary matters, depending on the activity, a range of lawful grounds could apply: Art 6(1)(c)—compliance with a legal obligation, to the extent that your purposing activity is necessary to comply with a legal obligation, e.g., in relation to gender pay reporting, or Art 6(1)(f)—legitimate interests, e.g., operational efficiency, security.
For marketing, the potential ground is Art 6(1)(f)—legitimate interests.
For credit reference checks, the potential ground is Art 6(1)(f)—legitimate interests.
For external audits and quality checks, e.g., for ISO (or Investors in People) accreditation, the potential grounds are Art 6(1)(f)—legitimate interests, and Art 6(1)(a)—consent.
See, Art 6(1)(c); Art 5(1)(d); Art 6(1)(b); Art 6(1)(f); Art 6(1)(a); and Art 13 or 14 the GDPR.
What we use your personal information for: To provide our Services to you.
a. Our reasons: For the performance of our contract with you or to take steps at your request before entering into a contract.What we use your personal information for: To prevent and detect fraud against you or “Just Ask Moira, Inc.”
a. Our reasons: For our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you.What we use your personal information for: Conducting checks to identify our customers and verify their identity / Screening for financial and other sanctions or embargoes / Other processing necessary to comply with professional, legal, and regulatory obligations that apply to our business, e.g., under health and safety regulation or rules issued by our professional regulator.
a. Our reasons: To comply with our legal and regulatory obligations.What we use your personal information for: Gathering and providing information required by or relating to audits, inquiries, or investigations by regulatory bodies.
a. Our reasons: To comply with our legal and regulatory obligations.What we use your personal information for: Ensuring business policies are adhered to, e.g., policies covering security and internet use.
a. Our reasons: For our legitimate interests or those of a third party, i.e., to make sure we are following our own internal procedures so that we can deliver the best service to you.What we use your personal information for: Operational reasons, such as improving efficiency, training, and quality control.
a. Our reasons: For our legitimate interests or those of a third party, i.e., to be as efficient as we can so that we can deliver the best service for you at the best price.What we use your personal information for: Ensuring the confidentiality of commercially sensitive information.
a. Our reasons: For our legitimate interests or those of a third party, i.e., to protect trade secrets and other commercially valuable information, and to comply with our legal and regulatory obligations.What we use your personal information for: Statistical analysis to help us manage our business, e.g., in relation to our financial performance, customer base, service range, or other efficiency measures.
a. Our reasons: For our legitimate interests or those of a third party, i.e., to be as efficient as we can so that we can deliver the best service for you at the best price.What we use your personal information for: Preventing unauthorized access and modifications to systems.
a. Our reasons: For our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for us and for you, and to comply with our legal and regulatory obligations.What we use your personal information for: Updating & enhancing customer records.
a. Our reasons: For the performance of our contract with you or to take steps at your request before entering into a contract, and to comply with our legal and regulatory obligations. Further, for our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our customers about existing and new services.What we use your personal information for: Statutory returns.
a. Our reasons: To comply with our legal and regulatory obligations.What we use your personal information for: Ensuring safe working practices, staff administration, and assessments.
a. Our reasons: To comply with our legal and regulatory obligations, and for our legitimate interests or those of a third party, e.g., to make sure that we are following our own internal procedures and working efficiently so that we can deliver the best service to you.What we use your personal information for: Marketing our Services and those of selected third parties to: Existing and former customers; Third parties who have previously expressed an interest in our Services; Third parties with whom we have had no previous dealings.
a. Our reasons: For our legitimate interests or those of a third party, i.e., to promote our business to existing and former customers.What we use your personal information for: Credit reference checks via external credit reference agencies.
a. Our reasons: For our legitimate interests or those of a third party, i.e., to ensure our customers are likely to be able to pay for our Services.What we use your personal information for: External audits and quality checks, e.g., for ISO (or Investors in People) accreditation and the audit of our accounts.
a. Our reasons: For our legitimate interests or a those of a third party, i.e., to maintain our accreditations so that we can demonstrate that we operate at the highest standards, and to comply with our legal and regulatory obligations.
See, Cal. Civ. Code §1798.110(c)(3). The examples listed in this section align with the definition of “business purpose” set out under Cal. Civ. Code §1798.140(e).
E. Promotional Communications. We may use your personal information to send you updates (by email, text message, telephone, or post) about our Services, including exclusive offers, promotions, or new services.
We have a legitimate interest in processing your personal information for promotional purposes. This means that we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal information with the utmost respect, and we will never sell OR share it with other organizations [outside “Just Ask Moira, LLC”] for marketing purposes.
You have the right to opt-out of receiving promotional communications at any time by:
Contacting us at info@justaskmoira.com.
We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
In accordance with the Privacy and Electronic Communications Regulations (PECR), if you are located within the UK, we may also send you relevant advertisement or marketing information if you (1) have ever purchased or inquired about our Services, (2) at the time of your purchase or inquiry, you agreed to receive advertising or marketing information from us, and you have not elected to opt out of receiving that information.
See, Article 21 of Regulation (EU) 2016/679, GDPR; the Privacy and Electronic Communication Regulations 2003 (PECR 2003), SI 2003/ 2426 or both.
F. Where We Store Your Personal Information and Who We Share It With. Your personal information is stored in a manner that reasonably protects it from misuse and loss and from unauthorized access, modification or disclosure. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. 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 website, we will of course notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
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 https://www.getsafeonline.org/. “Get Safe Online” is supported by HM Government and leading businesses.
Cal. Civ. Code §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.
Some of these third parties may be based outside the EEA. For more information, including on how we safeguard your personal information when this situation occurs, see, below Section “M” of this Policy.
We routinely share personal information with:
Our affiliates, including entities within “Just Ask Moira, LLC”
Service providers that we use to help deliver our Services to you, such as payment service providers, warehouses, and delivery companies.
Other third parties we use to help us run our business, such as marketing agencies or website hosts.
Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers.
Credit reporting agencies.
Our insurers and brokers.
Our bank[s].
Any other entity(ies) as is/are needed.
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g., in relation to ISO [or Investors in People] accreditation and the audit of our accounts.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
We will not share your personal information with any other third party; unless, we are required to do so.
We use “cookies” on this Site. Usage of a cookie is in no way linked to any personally identifiable information on our Site. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Site.
You can also have your computer warn you whenever cookies are being used. You will have to adjust your browser settings (such as Chrome, Safari, Firefox, Internet Explorer, or other browser). There are also software products available that can manage cookies for you. Please be aware, however, that when you choose to reject cookies, this choice may limit the functionality of any website that you visit, and you may lose access to some of its features. We only use absolutely necessary cookies, which allow you to move around our Site and use its features; we also use statistic and performance cookies, for the purpose(s) of collecting information about your use of our Site in order to improve the way that our Site works, and marketing cookies, for the purpose(s) of online behavioral advertising.
This Site contains links to other websites. Please be aware that we are not responsible for the content or privacy policies of such other websites. We encourage our users to be aware when they leave our Site and to read the privacy statements (a.k.a. “privacy notices”) of any other site that collects personally identifiable information.
See, Cal. Civ. Code §1798.110(c)(4). See, also Cal. Civ. Code § 1798.81.5(b); Articles 32(1) and 32(4) of Regulation (EU) 2016/679, GDPR; Article 13(1) of Regulation (EU) 2016/679, GDPR; Article 29 Working Party Guidance—WP 260; Guidelines on transparency under Regulation 2016/679; and Articles 13(1)(e) and 14(1)(e) of Regulation (EU) 2016/679, GDPR.
G. Personal Information Sold and/or Shared. In the preceding 12 months, we have not sold or shared your personal information. We do not sell or share your personal information and will not do so in the future without providing you with notice and an opportunity to opt-out of such sale or sharing.
This Site, and the servers and parties which made this site available on a global scale, are located and operate within the United States of America. The internet laws of the United States of America and California govern any and all matters relating to this Site, including content, as well as the principles of the General Data Protection Regulation (GDPR) as they apply to residents of the European Union. Any information that you choose to provide through this Site will be transferred to the United States of America for processing. That information may then be transferred within the United States of America or back out of the United States of America to other countries outside of your country of residence, depending on the type of information, and also how it is stored by us (see, above Section “D”). If transferred to another country, said country may not have data protection laws that are as comprehensive or as protective as those in your country of residence; however, our collection, storage, and use of your personal information will at all times be governed by this Policy. By visiting our Site, you acknowledge this information, and by submitting any personal information via our Site, you hereby authorize the transferring and processing of the information that you have provided.
See, Cal. Civ. Code §1798.115(c), and Cal. Civ. Code § 1798.130(a)(5)(C) and Cal. Civ. Code § 1798.130(a)(5)(C)(i).
H. Categories of Personal Information Disclosed for a Business Purpose. In the preceding 12 months, we have not disclosed for a business purpose any personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
See, Cal. Civ. Code § 1798.130(a)(5)(C) and Cal. Civ. Code § 1798.130(a)(5)(C)(ii).
I. How Long Your Personal Information Will Be Kept. We will keep your personal information while you have an account with us or while we are providing our Services to you. Thereafter, we will keep your personal information for as long as is necessary:
To respond to any questions, complaints or claims made by you or on your behalf;
To show that we treated you fairly –or–
To keep records required by law.
We will not retain your personal information for longer than necessary for the purposes set out in this Policy. Different retention periods apply for different types of personal information. When it is no longer necessary to retain your personal information, we will delete or anonymize it.
See, Cal. Civ. Code § 1798.100(a)(3).
J. California Consumers: Your Rights Under the CCPA/CPRA. You have the right under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), and certain other privacy and data protection laws, as applicable, to exercise free of charge:
Disclosure of Personal Information We Collect About You. You have the right to know, and request disclosure of:
a. The categories of personal information we have collected about you, including sensitive personal information.
b. The categories of sources from which the personal information is collected.
c. Our business or commercial purpose for collecting, selling, or sharing personal information.
d. The categories of third parties to whom we disclose personal information, if any –and–
e. The specific pieces of personal information we have collected about you.Please note that we are not required to:
a. Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained.
b. Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information –or–
c. Provide the personal information to you more than twice in a 12-month period.Disclosure of Personal Information Sold, Shared, or Disclosed for a Business Purpose. In connection with any personal information we may sell, share, or disclose to a third party for a business purpose, you have the right to know:
a. The categories of personal information about you that we sold or shared and the categories of third parties to whom the personal information was sold or shared –and–
b. The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom the personal information was disclosed for a business purpose.
You have the right to opt-out of the sale of your personal information or sharing of your personal information for the purpose of targeted behavioral advertising. If you exercise your right to opt-out of the sale or sharing of your personal information, we will refrain from selling or sharing your personal information, unless you subsequently provide express authorization for the sale or sharing of your personal information. To opt-out of the sale or sharing of your personal information, contact us at info@justaskmoira.com.
Right to Limit Use of Sensitive Personal Information. You have the right to limit the use and disclosure of your sensitive personal information to the use which is necessary to:
a. Perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.
b. To perform the following services: (1) Helping to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate for these purposes; (2) Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer's current interaction with the business, if the consumer's personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer's experience outside the current interaction with the business; (3) Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business; and (4) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business –and–
c. As authorized by further regulations.
You have a right to know if your sensitive personal information may be used, or disclosed to a third-party vendor, service provider, contractor or agent for additional, specified purposes. To limit the use of your sensitive personal information, contact us at info@justaskmoira.com.
Right to Deletion. Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:
a. Delete your personal information from our records –and–
b. Direct any service providers or contractors to delete your personal information from their records.
c. Direct third parties to whom the business has sold or shared your personal information to delete your personal information unless this proves impossible or involves disproportionate effort.
Please note that we may not delete your personal information if it is reasonably necessary to: Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us; Help to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate for those purposes; Debug to identify and repair errors that impair existing intended functionality; Exercise free speech, ensure the right of another consumer to exercise their right of free speech, or exercise another right provided for by law; Comply with the California Electronic Communications Privacy Act; Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent; Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; Comply with an existing legal obligation; or Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Right of Correction. If we maintain inaccurate personal information about you, you have the right to request us to correct that inaccurate personal information. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information.
Protection Against Retaliation. You have the right to not be retaliated against by us because you exercised any of your rights under the CCPA/CPRA. This means we cannot, among other things:
a. Deny goods or services to you.
b. Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties.
c. Provide a different level or quality of goods or services to you –or–
d. Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services. Please note that we may charge a different price or rate or provide a different level or quality of services to you, if that difference is reasonably related to the value provided to our business by your personal information.
See, Cal. Civ. Code § 1798.130(a)(5)(A), Cal. Civ. Code § 1798.110(a) and (b), Cal. Civ. Code § 1798.115(a) and (b), Cal. Civ. Code § 1798.135(a)(1), Cal. Civ. Code § 1798.140(e)(2), (4), (5), and (8), Cal. Civ. Code § 1798.121(a), Cal. Civ. Code § 1798.18, Cal. Civ. Code § 1798.105(a) and (d), Cal. Civ. Code § 1798.106(a)-(c), Cal. Civ. Code § 1798.185(a)(7) and (8), Cal. Civ. Code § 1798.125(a)(1) and (2).
K. Your Rights Under the EU GDPR.
Right to be Informed. The right to know or be notified about the collection and use of your personal information.
Right to Access. The right to be provided with a copy of your personal information (the right of access).
Right to Rectification. The right to require us to delete your personal information—in certain situations.
Right to be Forgotten. The right to require us to restrict processing your personal information—in certain circumstances, e.g., if you contest the accuracy of the data.
Right to Data Portability. The right to receive the personal information you provided to us, in a structured, commonly used, and machine-readable format and/or transmit that data to a third party—in certain situations.
Right to Object. The right to object: At any time to your personal information being processed for direct marketing (including profiling); In certain other situations to our continued processing of your personal information, e.g., processing carried out for our legitimate interests.
Right Not to be Subject to Automated Individual Decision-Making. The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.
For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner's Office (ICO) on individual rights under the EU General Data Protection Regulation.
See, WP 260, Article 29 Working Party Guidance, and Articles 12(1), 13(2)(b), and 15-22 of Regulation (EU) 2016/679, GDPR.
L. How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Policy, you can do so by contacting us at info@justaskmoira.com. You may also write to us at 1702 Meridian Avenue Unit L, No. 184, San Jose, CA 95125.
Please note that you may only make a CCPA/CPRA-related data access or data portability disclosure request twice within a 12-month period.
If you choose to contact us directly, you will need to provide us with:
a. Enough information to identify you (e.g., your full name, address(es) (including email), telephone number(s) and customer, order, account or matter reference number).
b. Proof of your identity and address(es) (e.g., a copy of your driving license, state-issued identification card or passport, and a recent utility or credit card bill) –and–
c. A description of what right you want to exercise and the information to which your request relates.We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person's behalf.
Any personal information that we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification. For instance, depending on the type of request that you submit, we may ask you to provide certain information so that we can match the information that you provide with the information that we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate. We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
See, Cal. Civ. Code § 1798.130(a)(5)(A), 11 Cal. Code Regs. § 7060(a), (b) and (h), Cal. Civ. Code § 1798.140(ak), and Cal. Civ. Code § 1798.130(a)(7).
M. Transferring Your Personal Information Out of the EEA. To deliver services to you, it is sometimes necessary for us to share your personal information outside the EEA, e.g.:
With your and our service providers located outside the EEA;
If you are based outside the EEA –or–
Where there is an international dimension to the services we are providing to you.
These transfers are subject to special rules under European and UK data protection laws.
The following countries, to which we may transfer personal information, have been assessed by the European Commission as providing an adequate level of protection for personal information (note: this list is current as of 06/2023): Andorra, Argentina, Canada (commercial organizations), the Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Republic of Korea, Switzerland, the United Kingdom, and Uruguay.
Except for the countries listed above, these non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission. To obtain a copy of those clauses visit https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en.
If you are located outside of the United States of America, please be aware that any information that you provide will be transferred to the United States of America. By using this Site, participating in any of its services and/or features, or by otherwise contacting us, you consent to this transfer.
See, Articles 13(1)(f) and 14(1)(f) of Regulation (EU) 2016/679, GDPR.
N. How to File a GDPR Complaint. We hope that we can resolve any query or concern you raised about our use of your information.
The GDPR also gives you right to lodge a complaint with a supervisory authority, in the EEA state where you work, normally live, or where any alleged infringement of data protection laws occurred. You can find their contact details here: https://www.edpb.europa.eu/about-edpb/about-edpb/members_en. If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
See, Articles 13(2)(d) and 14(2)I of Regulation (EU) 2016/679, GDPR.
O. Changes to This Privacy Notice. This privacy notice was published on 09/12/2024, and last updated on 9/12/2024.
We may change this privacy notice from time to time–when we do, we will inform you of any material changes via our Site or other means of contact such as email. We will not provide notice of any minor updates, and you acknowledge that it is your responsibility to read any updated version(s), and that you also agree to be bound by the most updated versions of this Policy. Your first use of our Site after the date of any non-material amendments or alterations will constitute your acceptance of such changes; therefore, we recommend reviewing this Policy regularly to stay updated on any changes made. If you do not agree with or understand the contents of this Policy, please immediately stop use of our Site and contact us (see, below Section “P”).
We reserve the right to change this Policy at any time. Changes, modifications, additions, or deletions will be effective immediately on their posting to this Site. We will also revise the “last updated” date found at the very beginning of this section of the Policy when we post changes to it.
See, Article 12 of Regulation (EU) 2016/679, GDPR; Article 5(1)(a) of Regulation (EU) 2016/679, GDPR.
P. How to Contact Us. Please contact us by email or by mail if you have any questions about this Policy or the information that we hold about you.
Our contact details are shown below:
info@justaskmoira.com
1702 Meridian Avenue Unit L, No. 184, San Jose, CA 95125
See, Articles 13(1)(a) and 14(1)(a) of Regulation (EU) 2016/679, GDPR.
Q. Do You Need Extra Help? If you would like this notice in another format (for example: audio, large print, braille), please contact us (see, above Section “P”).
R. Children. Our Services are not intended for use by children under the age of 18. We do not knowingly collect personal information from anyone under the age of 18. If we become aware that personal information has been collected from a person under the age of 18, we will delete this information immediately.
S. Children’s Online Privacy Protection Act (“COPPA”) Compliance. This Site is not intended for those under 13, in compliance with COPPA, and we do not knowingly collect or request any information from or market to children under the age of 13. If we learn that we have collected or received personal information from a minor under 13, we will delete this information. If you have any reason to believe that we may have unknowingly collected data from a minor under 13, please let us know by contacting us (see, above Section “P”).
T. Other Privacy Rights. You can designate an authorized agent to make a request under the California Consumer Privacy Act ("CCPA”) on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
U. Controls for Do-Not-Track Features. Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting that you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing “DNT” signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Policy.