Privacy Policy

JLL Global LTD Privacy Policy

Effective Date: February 22, 2021

We recognise the importance of protecting and respecting your personal data and we take data privacy very seriously. This Privacy Policy explains the types of personal data we may collect about you; how we use, store and keep that information safe; with whom we share the information; your rights and key contact information. We will use your personal data only for the purposes and in the manner set out in this privacy policy.

  1. Introduction

1.1 This policy applies where we are acting as a data controller with respect to the personal data we may collect about you when you interact with us (including, but not limited to, corporate and individual customers and their connected parties); in other words, where we determine the purposes and means of the processing of that personal data.

1.2 Our “Services” include, but are not limited to:product sales, affiliate programs, delivery methods, To provide you with our Services we need to collect information about you. Our aim is not to be intrusive, and we won’t ask you unnecessary questions. Any information we receive about you will be subject to strict controls to minimise the risk of misuse – including unauthorised access to, or disclosure of, your personal data.

1.3 Our Services can be accessed via our web application, mobile web application or mobile application (“App” or “Apps”). In addition, customers may access information about our company and our Services via our Apps(s). 

1.4 We use cookies on our stores and Apps. Insofar as those cookies are not strictly necessary for the provision of our Apps and services, we will ask you to consent to our use of cookies when you first visit our Apps.

1.5 Our service incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications from us. You can access the privacy controls via your account settings after creating an account.

1.6 In this policy, “Influencer Markets”, "we", "us" and "our" refer to JLL Global Limited and its subsidiaries.

1.7 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

1.8 Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by sending an email to info@influencermarkets.com.

  1. The Data We Collect About You

2.1 Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

In this Section 2 we have set out:

(a) the general categories of personal data that we may process;

(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;

We may also collect, use and share aggregated and/or anonymised data (“Aggregated Data”) such as statistical or demographic data for analytical purposes. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Apps/App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

2.2 We may process data about the technology you use to access our Apps ("technical data"). 

The technical data may include your IP address, geographical location, browser type and version, computer operating system and platform, mobile device operating system and mobile device identifier provided by your mobile device operating system, the name of your internet service provider or mobile carrier, mobile number, browser plug-in types and versions and other technology on the devices you use to access our Apps or Apps.

We capture technical data through your use of our Apps and through your use of our Services. 

2.3 We may request from you and process identification details ("identity data").

The identity data includes your first name and last name and it may also include your gender.

The source of the identity data is information you provide directly through our Apps or Web site.

2.4 We may request from you and process contact data ("contact data"). 

The contact data may include your billing address, delivery address, mobile number and email address. 

The source of the contact data is information you provide directly through our Apps or Web site. 

2.5 We may request from you and process additional account details ("account data").

The account data may include your username (email address), your login data, purchases or orders made by you, your interests, preferences, feedback and survey responses.

The source of the account data is information you provide, on request directly through our Apps or Web site.

2.6 We may request from you and process payment details ("financial data").

The financial data may include the payment method and card association used to process your payments for your orders. We do not store or process your card details ourselves, they are processed and automatically stored via one of our contracted third party service providers. We encrypt your payment card details in your browser and securely transfer this data to our relevant third party payment provider to process a payment.

The source of the financial data is information you provide, on request directly through our Apps or Web site.

2.7 We may process data about your use of our Apps, products and services ("usage data"). 

The usage data may include the referral source that directed you to our Apps, length of visit, page views and App navigation paths, as well as information about the timing, frequency and pattern of your service use. 

We capture usage data through your use of our Apps and through your use of our Services. 

2.8 We may process information relating to transactions, including Services, that you enter into with us through our Apps ("transaction data").

The transaction data may include details about transactions you have made on our Apps including the payments to and from you and any other details you have provided in respect of an order, along with other details of products and services you have purchased from us. 

2.9 We may process information contained in any enquiry you submit to us regarding goods and/or services ("enquiry data"). 

The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. 

The legal basis for this processing is consent.

2.10 We may process information relating to our business customer relationships, including business customer contact information ("business customer relationship data").

The business customer relationship data may include your name, your employer or agent, your job title or role, your contact details, and information contained in communications between us and you or your employer.

The source of the business customer relationship data is you or your employer or agent. 

2.11 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("marketing and communications data"). 

The marketing and communications data includes your preferences in receiving marketing from us and your communication preferences.

2.12 We may process information contained in or relating to any communication that you send to us ("correspondence data"). 

The correspondence data may include the communication content and metadata associated with the communication, including questionnaires, surveys and competitions. 

The correspondence data may be processed for the purposes of communicating with you and record-keeping. 

2.13 We may process personal information about other individuals in the course of dealing with you (“connected party data”).

The connected party data may include details of directors and shareholders of a company, or the other party to a joint account.

The source of the connected party data is information you or your employer or agent provide directly.

2.14 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.
  1. Purpose and basis for using your personal data

We have set out below, in a table format, a description of the purposes for which we may use your personal data, and which of the legal bases we rely on to do so. Where appropriate, we have also identified what our legitimate interests are.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer or seller or agent or promotor

(a) Identity

(b) Contact

(c) Account

(d) Business customer relationship

(e) Connected party

The performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract. 

We may also use some of the data for our legitimate interests, namely

  1. the proper administration of our business
  2. the proper protection of our business against risks
  3. ensuring our customer service quality standards are met

To process and deliver your order, including:

  1. Sharing your personal data with a relevant Seller (see Section 5 – Providing your personal data to others);
  2. Sharing your personal data with a relevant delivery service (see Section 5 - Providing your personal data to others);
  3. Managing payments, fees and charges; and
  4. Managing your enquiries and queries through our Customer Service team – this may include recording calls to our teams.

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Enquiry

(f) Marketing and Communications

The performance of a contract between you and us. 

We may also use some of the data for our legitimate interests, namely

  1. the proper administration of our business
  2. the proper protection of our business against risks
  3. ensuring our customer service quality standards are met

To collect and recover money owed to us in respect of your order

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

We may use the data for our legitimate interests, namely

  1. the proper administration of our business
  2. to recover debts due to us

To perform fraud risk assessments

(a) Identity

(b) Contact

(c) Business customer relationship

(d) Connected party

(e) Financial

(f) Transaction

(g) Technical

We may use the data for our legitimate interests, namely

  1. the proper administration of our business
  2. the proper protection of our business against fraud risks
  3. ensuring payments are not fraudulent

To notify you in relation to our legal obligations and documents, including changes to our terms or Privacy Policy

(a) Identity

(b) Contact

(c) Account

(d) Business customer relationship

(e) Marketing and Communications

We may use the data for our legitimate interests, namely

  1. the proper administration of our business
  2. ensuring our customers, agents and promoters are updated on these changes

To help us improve our service and/or product offering to our customers, including asking you to leave a review or constructing and/or asking you to take a survey, or provide customer insights

(a) Identity

(b) Contact

(c) Account

(d) Marketing and Communications

(e) Usage


We may use the data for our legitimate interests, namely

  1. to understand and improve how customers use our Apps 
  2. to improve our service and/or product offering to our customers
  3. to develop and grow our business

To enable customers to partake in a prize draw or competition

(a) Identity

(b) Contact

(c) Account

(d) Usage

(e) Marketing and Communications

Performance of a contract with you to fulfil a promotion and run a competition or prize draw.

We may also use the data for our legitimate interests, namely

  1. to understand the interests and behaviour of our customer base more effectively
  2. to develop and grow our business

To administer and protect our business, Apps 

(a) Identity

(b) Contact

(c) Account

(d) Business customer relationship

(e) Technical

(f) Usage


We may use the data for our legitimate interests, namely

  1. analysing the use of our Apps and Services
  2. monitoring and improving our existing Apps and services
  3. developing new Apps and services
  4. ensuring that content is presented in the most effective manner for you and your device
  5. allowing us to manage risk and to detect, prevent, and/or remediate fraud or other illegal or prohibited activities
  6. monitoring account access and usage to prevent fraud, including to protect your account from fraudulent activity and to allow us to alert you and/or relevant law enforcement agencies if we detect such fraudulent activity on your account
  7. administering our Apps and for internal business administration and operations purposes, including troubleshooting, data analysis, testing, research, statistical and survey purposes
  8. as part of our efforts to keep our site safe and secure, including managing and protecting our information technology infrastructure
  9. in the context of a business reorganisation or group restructuring exercise

To deliver relevant App content, advertisements and other marketing material to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(c) Account

(d) Usage

(e) Marketing and Communications

(f) Technical

We may use the data for our legitimate interests, namely

  1. to analyse how customers use our products and services 
  2. to develop and grow our business
  3. to inform and guide our marketing strategy
  4. to improve our product and service offering to you

Please note that where cookies are used for this purpose, this is covered separately by our Cookie Policy https://www.influencermarkets.com/pages/cookie-policy

To use data analytics to improve our Apps, products and services, marketing, customer relationships and experiences

(a) Technical

(b) Account

(c) Usage

We may use the data for our legitimate interests, namely

  1. to keep our Apps up to date and relevant
  2. to characterise types of customers for our products and services
  3. to develop and grow our business
  4. to inform and guide our marketing strategy

Please note that where cookies are used for this purpose, this is covered by our Cookie Policyhttps://www.influencermarkets.com/pages/cookie-policy .

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Account

We may use the data for our legitimate interests, namely

  1. to improve our product and service offering to you
  2. to develop and grow our business

3.1 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

3.2 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

3.3 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

3.4 Please do not supply any other person's personal data to us, unless we prompt you to do so.

3.5 Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, where you do not provide suitable delivery instructions to provide you with goods or services). In this case, we may have to cancel a product or service you have through us but we will notify you if this is the case at the time.

  1. Automated decision-making

4.1 We may use your personal data for automated decision making or otherwise profiling you, if you are a potential customer, for the purposes of targeting marketing at you and where this is done, this is undertaken for our legitimate interests of ensuring our marketing is relevant to its audience. For example, we may classify an appropriate audience for a promotion by what products on our Apps you have previously looked at or expressed an interest in.

4.2 We use Shopify to provide our suite of services including payments, marketing, shipping and customer engagement tools. Shopify's risk and fraud screening makes use of automated decision-making, where Shopify might automatically block a payment card number or IP address after a certain number of unsuccessful payment attempts. Shopify does not believe this has a significant legal effect on customers because the automated blocking lasts only for a short period of time.

  1. Providing your personal data to others

We also collect from and share data with the following providers:

5.1    The delivery/fulfilment organisation: we will share your personal data (name, address, gender, billing address, email, telephone and mobile  phone number as well as any personalisation details you've provided as part of your order) with partner  with whom you have placed an order so that they can fulfil and manage your order as part of the sales process we provide under our Customer Terms and Conditions. Any order placed is deemed to be an instruction from you to share your personal data in this way. The Seller will act as an independent data controller, on a stand-alone basis, and process your personal data in accordance with their own policies and security measures. We are not responsible for protecting your information when it is under their control, but you may exercise against such Seller all of the rights which you would otherwise be able to exercise against us as set out in this Privacy Policy.

5.2 The delivery/fulfilment centre will be as identified on our site. You will be able to contact the Seller directly through our Apps with any questions or concerns.

5.3    the delivery/fulfilment centre will process your personal data (including name, address, gender, billing address, email and telephone number as well as any personalisation details if supplied by you) for the purposes identified above, namely, to manage your order.

5.4 In all other respects, the delivery/fulfilment centre shall be responsible for treating your personal data in accordance with Data Protection Laws including in the same way that we do as set out in Sections 7, 8 and 10 below.

5.5 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

5.6 We work with third-party payment service providers who give us data about you which is necessary to perform our contract with you: primarily this is financial and transaction data. They tell us that you have paid for your products and, where relevant and/or necessary they will provide us with your Contact Data and Transaction Data. Occasionally we may also provide details to third-party payment service providers but only to the extent necessary for the purposes of refunding such payments and dealing with chargebacks, complaints and queries relating to such payments and refunds. 

5.7 In addition to the specific disclosures of personal data set out in this Section 5, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

5.8 If you are referred to us by a third party – either via our affiliate network, franchise partners or via specific promotions – depending on the arrangement, we may notify them when you conduct a transaction.

5.9 As with any business, it is possible that in the future we could buy, merge with, or be acquired by, another company. We may disclose your information to the prospective seller or buyer of such business or assets, along with its professional advisers. If we or a substantial proportion of our assets are acquired by a third party, information held by us about our customers will be one of the transferred assets, and such successor company would continue to be bound by this Privacy Policy unless and until it is amended.

5.10 We may share your IP address with analytics and search engine providers that assist us in the improvement and optimisation of our Apps. See also our Cookie Policy.

The lawful bases for sharing and processing this data are set out in the table in section 3 above and please refer to the list of providers for further information and is available on request, please contact info@influencermarkets.com.

  1. International transfers of your personal data

6.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

6.2 We have third-party service providers in countries outside of the EEA who assist with Service provision and fulfilment. Relevant information that we collect from you may be transferred to, and stored in, a country outside the EEA. It may also be processed by staff operating outside the EEA who work for us or for our third-party service providers. These staff may be engaged in the fulfilment of your request, the processing of your payment details and the provision of support services. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. Transfer of your relevant personal data to countries outside the EEA will be limited for compelling legitimate interest, namely, to comply with our obligations in fulfilment of our Services in the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

6.3 The laws in some countries may not provide as much legal protection for your information as in the EEA. In these circumstances, our policy to protect your data is to rely on findings of adequacy by the European Commission (for countries in scope of those findings), the EU-US Privacy Shield (for transfers to the USA) or standard contractual clauses adopted by the European Commission or the UK Information Commissioner (for all other countries). 

6.4 By submitting your information and making use of our Services, you agree to such transfers, storing or processing. We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this Privacy Policy.

6.6 We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

6.7 Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

  1. Retaining and deleting personal data

7.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

7.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

7.3 It is not possible for us to specify in advance the periods for which your personal data will be retained. The criteria for determining the duration for which we retain your personal data are whether it is necessary: 

  • to maintain an ongoing relationship with you (e.g. to provide our Services to you or where you are lawfully included in our direct marketing lists and have not unsubscribed); 
  • in connection with the lawful purposes set out in this policy, or where we have a valid legal basis; or 
  • to comply with any applicable limitation period under applicable law, and a reasonable amount thereafter 

In general, we will keep our records for up to 6 years after you have terminated your relationship with us, unless the law prescribes a longer period.

Once the periods above have concluded, we will either: 

  • permanently delete or destroy the relevant personal data; 
  • archive your personal data so that it is beyond use; or 
  • anonymise the relevant personal data

7.4 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

  1. Security of personal data

8.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the accidental loss, unauthorised used or accessed, misuse, alteration or disclosure of your personal data.

8.2 We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

8.3 The following personal data will be stored securely by us: account data, identification data, recipient data, card payment data

8.4 Data relating to your enquiries and financial transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.

8.5 Data that is sent from our Apps to our web server, or from our web server to our Apps, will be protected using encryption technology.

8.6 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

8.7 You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our Apps confidential and we will not ask you for your password (except when you log in to our Apps).

8.8 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

  1. Amendments

9.1 We may update this policy from time to time by publishing a new version on our Apps.

9.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

9.3 We may notify you of significant changes to this policy by email or through the private messaging system on our Apps.

  1. Your rights

10.1 In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

10.2 Your principal rights under data protection law are:

(a) the right to access;

(b) the right to rectification;

(c) the right to erasure;

(d) the right to restrict processing;

(e) the right to object to processing;

(f) the right to data portability;

(g) the right to complain to a supervisory authority; and

(h) the right to withdraw consent.

10.3 Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. We reserve the right to charge a reasonable fee (reflecting the costs of providing the information) or to refuse to respond where requests are manifestly unfounded or excessive: in this case, we will explain the situation to you and we will inform you about your rights.

10.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

10.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: you withdraw consent to consent-based processing; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

10.6 In some circumstances you have the right to restrict the processing of your personal data. 

10.7 In some circumstances you have the right to object to the processing of your personal data.

10.8 To the extent that the legal basis for our processing of your personal data is:

(a) consent; or

(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

10.9 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

10.10 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

10.11 You can contact us at info@influencermarkets.com if you want to enforce any of these rights.  We will comply with our legal obligations as regards Your rights as a data subject. Any request for access to your personal data must be in writing and we will endeavour to respond within a reasonable period and in any event within one month (three months for complex or numerous requests), in compliance with Data Protection Legislation.

  1. Third party websites

11.1 Where our Apps includes hyperlinks to, and details of, third party websites, we have no control over, and are not responsible for, the privacy policies and practices of third parties.

  1. Personal data of children

12.1 Our Apps and services are targeted at persons over the age of 18.

12.2 If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.

  1. Updating information

13.1 You can correct the personal data we hold about you through the “My Account” option when logged into your account. Please check this information regularly and update as necessary. If you have any difficulties updating your personal data, or if we have personal data that you cannot update through the “My Account” option, please let us know if such personal information that we hold about you needs to be corrected or updated.

  1. Acting as a data processor

14.1 Insofar as we act as a data processor rather than a data controller, this policy shall not apply. Our legal obligations as a data processor are instead set out in the contract between us and the relevant data controller.

  1. Our details

15.1 Our Apps are owned and operated by JLL Global ltd, 27 Lauriston street, Edinburgh. Scotland EH3 9DQ