1. Introduction

This Privacy Policy for The JJ Club Group Ltd (doing business as The JJ Club) (‘we’, ‘us’, or ‘our’) describes how and why we collect, store, use, and share (‘process’) your personal information when you use our services (‘Services’), including when you:

• Visit our informational website at www.thejjclub.co.uk (‘Our Site’)

• Download and use The JJ Club mobile application (‘the App’), available on the Apple App Store and Google Play Store

• Engage with us in other related ways, including when you register your interest, contact us, or participate in our events
  

Our Site is an informational website only. All membership sign-ups, subscriptions, and in-app purchases take place exclusively within the App, processed by Apple (via Apple In-App Purchase) or Google (via Google Play Billing).

Questions or concerns? Please read this policy in full to understand your privacy rights and choices. If you do not agree with our practices, please do not use our Services. For any questions, contact us at hello@thejj.club.

2. Summary of Key Points

In Short: Here are the highlights. Read the full policy below for detail.

What personal information do we process? We collect information you provide when creating an account, using the App, or contacting us, as well as certain information collected automatically.

Do we process sensitive personal information? No.

Do we collect information from third parties? Limited technical and analytics data may be received from third-party service providers.

How do we process your information? We process your information to provide and improve our Services, manage your membership, communicate with you, and comply with our legal obligations.

Who do we share your information with? We share data with certain third-party service providers who support our operations. We do not sell your data.

How do we keep your information safe? We use appropriate technical and organisational security measures, though no transmission over the internet can be guaranteed 100% secure.

What are your rights? Under UK GDPR, you have rights to access, correct, delete, and port your data, among others. See Section 12 for details.

How do you exercise your rights? Contact us at hello@thejj.club or submit a data subject access request as described in Section 15.

3. What Information Do We Collect?

Personal Information You Provide to Us

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

We collect personal information you provide when you register on the App, contact us, or participate in activities through our Services. This may include:

• Full name

• Email address

• Phone number

• Mailing address

• Date of birth

• Password and account credentials

• Contact preferences

• Interests and preferences

All personal information you provide must be accurate, complete, and kept up to date.

Payment Data

All payments for membership and in-app purchases are processed exclusively by Apple (via Apple In-App Purchase) or Google (via Google Play Billing), depending on the platform you use. We do not directly collect, store, or process your payment card or financial details. Please refer to Apple’s and Google’s respective privacy policies for information on how they handle your payment data:

• Apple Privacy Policy: www.apple.com/legal/privacy

• Google Privacy Policy: policies.google.com/privacy

Information Automatically Collected

In Short: Some information is collected automatically when you use the App or visit Our Site.

We automatically collect certain information when you use the App or visit Our Site. This does not reveal your specific identity but may include:

Log and Usage Data: Diagnostic, usage, and performance data including IP address, device information, browser type, activity timestamps, pages or screens viewed, features used, and error reports.

Device Data: Information about your mobile device or computer, including device identifiers, operating system, hardware model, mobile carrier, and app version.

Location Data: General location data inferred from your IP address. The App does not collect precise GPS location data unless you explicitly grant permission.

Push Notification Data: If you enable push notifications, we collect the device token required to send you notifications. You can disable push notifications at any time in your device settings.

4. How Do We Process Your Information?

In Short: We process your information to provide and improve our Services, manage your membership, communicate with you, and comply with law.

Specifically, we process your personal information to:

• Create and manage your Account and membership

• Process your membership subscription via Apple or Google

• Deliver the Services, including event bookings, member perks, and partner offers

• Respond to your enquiries and provide customer support

• Send you administrative information, including membership confirmations, renewal reminders, and policy updates

• Send you marketing communications, where you have given consent (you can opt out at any time)

• Send push notifications about events, offers, and membership updates (where enabled)

• Analyse how the App and Our Site are used so we can improve them

• Ensure the security and integrity of our Services

• Comply with our legal obligations

5. Legal Bases for Processing

In Short: We only process your information when we have a valid legal reason to do so under UK GDPR.

The legal bases we rely on include:

Consent: Where you have given us explicit permission, such as for marketing emails or push notifications. You may withdraw consent at any time.

Performance of a Contract: Where processing is necessary to fulfil our membership agreement with you, including managing your account and delivering our Services.

Legitimate Interests: Where processing is necessary for our legitimate business interests, such as improving our Services, fraud prevention, and direct marketing to existing members, provided these interests do not override your rights.

Legal Obligations: Where processing is necessary to comply with a legal obligation, such as responding to lawful requests from authorities or maintaining financial records.

Vital Interests: In rare circumstances, where processing is necessary to protect someone’s life.

6. When and With Whom Do We Share Your Information?

In Short: We share information only as necessary with trusted third parties who support our operations.

We may share your personal data with the following categories of third parties:

• Technology and infrastructure service providers (e.g. cloud hosting, app analytics)

• Marketing and communications platforms (e.g. email marketing tools)

• Apple and Google, in connection with in-app purchases and subscription management

• Event and Partner service providers, where necessary to fulfil a booked Service

• Analytics providers (e.g. Google Analytics)

We require all third parties to respect the security of your personal data and to process it only on our documented instructions and in accordance with applicable data protection law.

We may also share your information:

Business Transfers: In connection with a merger, acquisition, or sale of all or part of our business.

Affiliates: With our parent company or subsidiaries, subject to this policy.

Legal Requirements: Where required to comply with a legal obligation or to protect the rights and safety of our users or the public.

We do not sell your personal data to third parties.

Where personal data is transferred outside the UK, we ensure appropriate safeguards are in place in accordance with UK GDPR.

7. Third-Party Websites and Services

In Short: We are not responsible for the privacy practices of third-party websites or services we link to.

The App and Our Site may contain links to third-party websites or services, including those of our Partners. These third parties operate their own privacy policies, which we encourage you to review. We are not responsible for the content, security, or privacy practices of any third-party sites or services.

8. Cookies and Tracking Technologies

In Short: Our website uses cookies. The App uses analytics SDKs to help us understand usage.

Website Cookies

Our Site (www.thejjclub.co.uk) uses cookies to improve your browsing experience and to understand how visitors use it. As Our Site is informational only, cookies are primarily used for analytics and basic functionality, not for transactions or account management.

App Analytics

The App may use third-party analytics tools (such as Firebase or equivalent) to collect anonymised usage data, including screens visited, features used, and crash reports. This data is used solely to improve the App’s performance and user experience. No personally identifiable information is shared with analytics providers beyond what is necessary for these purposes.

To opt out of Google Analytics tracking on Our Site, you can use the Google Analytics opt-out tool at: tools.google.com/dlpage/gaoptout.

More detail on the cookies used on Our Site is set out in the Cookie Policy section below.

9. How Long Do We Keep Your Information?

In Short: We retain your information only for as long as necessary.

We keep your personal information only for as long as necessary for the purposes set out in this policy, unless a longer retention period is required by law (for example, for tax or accounting purposes).

We will not keep your personal information for longer than twelve (12) months after the termination of your account, except where required by law.

When your information is no longer needed, we will securely delete or anonymise it.

10. How Do We Keep Your Information Safe?

In Short: We use appropriate technical and organisational measures to protect your data.

We have implemented technical and organisational security measures to protect your personal information from unauthorised access, loss, misuse, or alteration. However, no electronic transmission over the internet or data storage system can be guaranteed to be 100% secure. You use our Services at your own risk and should always access them from a secure environment.

11. Do We Collect Information From Minors?

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

We do not knowingly collect, solicit, or market to children under the age of 18. By using the App, you confirm that you are at least 18 years old, or that you are the parent or guardian of a minor and consent to their use of the Services under your supervision.

If we become aware that we have collected personal information from a child under 18 without parental consent, we will promptly delete it. Please contact us at hello@thejj.club if you have any concerns.

12. Your Privacy Rights

In Short: You have rights under UK GDPR to access, correct, and control your personal data.

Under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, you have the following rights:

• The right to be informed about how we use your data

• The right to access a copy of your personal data

• The right to rectification if your data is inaccurate or incomplete

• The right to erasure (‘the right to be forgotten’)

• The right to restrict processing

• The right to data portability

• The right to object to processing, including for direct marketing

• Rights in relation to automated decision-making and profiling

To exercise any of these rights, please contact us at hello@thejj.club. We will respond within one month in accordance with applicable data protection law. There is no fee for making a request, unless it is manifestly unfounded or excessive.

If you believe we are processing your data unlawfully, you have the right to complain to the Information Commissioner’s Office (ICO) at ico.org.uk. We would, however, appreciate the chance to address your concerns first.

Withdrawing Consent

Where we rely on your consent as the legal basis for processing, you may withdraw it at any time by contacting us at hello@thejj.club. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

Opting Out of Marketing

You can unsubscribe from marketing emails at any time by clicking the unsubscribe link in any marketing email, or by contacting us. You can disable push notifications at any time via your device settings. Opting out of marketing does not affect service-related communications necessary for the operation of your account.

Your Account

You can review and update your account information at any time via the ‘My Membership’ section of the App, or by contacting us. If you request account deletion, we will deactivate or delete your account and data from our active databases, subject to any retention requirements under law.

13. Do-Not-Track Features

Some browsers and mobile operating systems include a Do-Not-Track (‘DNT’) feature. As no uniform standard for DNT has been finalised, we do not currently respond to DNT signals. If a recognised standard is adopted in future, we will update this policy accordingly.

14. Updates to This Policy

In Short: Yes, we will update this policy as necessary to remain compliant.

We may update this privacy policy from time to time. The updated version will be indicated by an updated date at the top of this policy. If we make material changes, we will notify you via the App or by email. We encourage you to review this policy periodically.

15. How to Contact Us or Exercise Your Rights

If you have questions or comments about this policy, or wish to exercise your data rights, please contact us:

The JJ Club Group Ltd

1 Canada Square, 37th Floor, Canary Wharf, London, England, E14 5AA

Email: hello@thejj.club

To submit a formal data subject access request, please email us at hello@thejj.club with the subject line ‘Data Subject Access Request’. We will respond within one month.