(Last updated, 20 April, 2020)

At Molly Joseph, LLC (“Molly Joseph” or the “Company”), we take your privacy and its protection seriously. All efforts are made to implement suitable technical and administrative controls in our endeavour to keep your personal information protected at all times. We request and utilize a very limited amount of information for purposes of logging into the website with your username or in the event we store your username, email address, and/or order history, or where our Website password protects certain pages and only enough to verify the validity of your account (“Account”). This Privacy Policy outlines how your personal information is held and managed, and we ask that you read through it carefully. Please understand that, by visiting the Molly Joseph website (“Website”) and utilizing its services, you agree to accept the terms and conditions of this Privacy Policy. 

1. Purpose for the Collection of Personal Data

Your personal information (“Personal Information”) is collected and used for the following reasons:

  1. to provide you with our services;
  2. to make more of such services available to you where possible and appropriate;
  3. for the purposes of security and control; 
  4. to satisfy regulatory and legal requirements, and for historical and statistical purposes.
  5. to send email updates, of which you can opt out at any time. 

2. Information We Collect

  1. The Personal Information which we may request to use and process shall include, without limitation:
  2. Any of the information that you provide to us when completing account registration, as well other data that you voluntarily submit via the Website or email.
  3. Correspondence made with us via the Website, email, web chat or through other means of communication.
  4. All transaction history, whether this takes place via the Website or other means of communication. 
  5. Website logins and their details, including traffic data, GeoIP location data, browser/device data, weblogs, activity logs, and other traffic information recorded in our system. 
  6. Survey participations or any other customer assessments that we may carry out from time to time.

3. Disclosing Personal Information to Third Parties

  1. We do not sell or rent your personal data to third parties. We may disclose your Personal Information if required by law, regulation, or other legal subpoena or warrant. We may also disclose your personal information to a regulatory or law enforcement agency if we believe it to be necessary to protect the legitimate interests of the Company, its customers or any third party. Personal Information will only be disclosed to third parties in the following cases: 
    1. Where we are required to do so by law; 
    2. If the Website needs to share data with its payment processors to facilitate payment transactions in accordance with their privacy policies.
    3. To comply with our legal and regulatory duties and responsibilities to the relevant licensing and regulatory authorities as well as all duties and responsibilities owed under any other applicable legislation and to any other applicable regulators in other jurisdictions. 
    4. When the Company believes that disclosure is necessary to protect the Company’s or the account holder’s safety, or the safety of others, investigate fraud, or respond to a government request.
    5. If our marketing service providers require the data to carry out their tasks.
  2. In cases of the account holder’s prior consent, we use third-party data processors to process limited personal data on our behalf. Such service providers support the Website, especially relating to hosting and operating the website, marketing, analytics, improving the website, and sending email newsletters. We shall ensure that the transfer of the Personal Information to the recipient is compliant with applicable laws (“Data Protection Legislation”) and that the same obligations are imposed on the processor as is imposed on us under any applicable service agreements. Our Website may also include social media features (e.g. “share” or “like” buttons). Such features are provided by third-party social media platforms such as Facebook, Google, or Twitter. Where data is collected in this way, its processing is governed by the privacy policy of the respective social media platforms. In addition to the above, we may also release Personal Information if we acquire any new businesses. Should the Company undergo any changes to its structure such as a merger, acquisition by another company or a partial acquisition, it is most likely that our customers’ Personal Information will be included within the sale or transfer. We will, as part of this Privacy Policy, inform our account holders by email prior to affecting such transfer of Personal Information. Please note our content may link to third party websites to provide relevant references. We are not responsible for such external content, which may contain separate privacy policies and data processing disclosures.

4. Protection of Your Personal Information

We hereby acknowledge that in collecting and processing your Personal Information for the purposes of managing your Account, we are bound by strict legal provisions on the protection of personal data. Consequently, we endeavour to protect your personal information and respect your privacy in accordance with best business practices and applicable regulations. Being committed to providing secure services to account holders, we will take all reasonable precautions to ensure that all the data that you have submitted to us remains safe. Account holder Accounts can only be accessed with the account holder’s unique ID and password. In the event two-factor authentication (2FA) is required as additional protection from unauthorised use of your account, you are responsible for keeping your login information confidential and making sure it cannot be accessed by another person. 

5. Access to Your Personal Information

We may pass information that you have given us to other entities within our group of companies and to our business partners. These companies include our parent companies, their parent companies, and all of the subsidiaries of these respective companies, as well as other companies with whom we carry out business and hold necessary agreements. Data processing of your information may be undertaken by this or another company in the group of companies, which may use a third party to fulfill such data processing needs. Employees of the Company, which may include customer support agents, customer retention team members, account managers, as well as other selected employees, shall also have access to your Personal Information for the purpose of executing their duties and providing you with assistance. Our employees who have access to, or are associated with the processing of the Account holder’s personal information, have signed confidentiality agreements to respect the confidential nature of the account holder’s information pursuant to applicable merchant, data protection and privacy laws. In order to provide you with an efficient service, we and/or our service providers might require transferring your personal data from one country to another in the European Union (EU) and European Free Trade Association (EFTA) regions and also to some data processors that may be based outside of the European Economic Area (EEA). Therefore, by browsing the Website and communicating electronically with us, you acknowledge and agree to our (or our suppliers or subcontractors) processing of your data in these countries. We shall always use our best efforts to ensure that your information and data are treated securely and in accordance with this Privacy Policy.

6. Cookies

  1. When you visit the Website, our system automatically collects information about your visit, such as your browser, IP address, and the referring website. This collection may be done in conjunction with our platform providers and partners. We may also receive such data from general demographic or usage data provided by visitors to our Website. We do not use automatically collected information to identify you personally without receiving additional consent. To collect the information in question, we use cookies and similar tracking tools.
  2. Cookies are small text files that are stored on your computer or equipment when you visit our web pages. Some cookies are essential for the Website to operate, while others improve your Website experience and help us deliver a better service. Below are the types of cookies we may use and their purposes. 
  3. Required cookies: enable the navigation and basic functionality of the websites, e.g., access to member areas of the Website. 
  4. Functional cookies: allow us to analyse your website usage and your selections on the website (e.g. your session key, language, or region), so we can save these settings and offer you a more personalised experience. 
  5. Advertising cookies: allow us to gauge how effective our content marketing is. These cookies are provided by our partners to track website visits and new account holder registrations from advertising. We do not share your personal information (such as name or email) to affiliated partners except for site visit data collected directly by such advertising cookies. However your site visit data may be linked with other personal information collected through other sources by the providers. The latter external data processing is governed by the privacy notices and policies of these third-party providers. 
  6. In addition to the above, we use a number of third party service providers who also set cookies on this Website, in order to deliver the services that they are providing to us. Such services include, but are not limited to, helping us to improve your experience by tracking your activity on the Website, measuring the effectiveness of the Website and the effectiveness of our marketing campaigns. Most online browsers automatically accept cookies. If you prefer, it is possible to block some or all cookies, or to delete cookies that have already been set by modifying your browser settings. However, we recommend that you do not block or delete your cookies as this may restrict your use of our Website. 

7. Privacy Commitment

In order to ensure that your personal information remains confidential, our privacy guidelines are communicated to every employee of the Company. Where the Website of the Company contains links to other sites, the Company does not share your personal information with those sites, and is in no way responsible for the privacy policies of those sites. We would advise you to make yourself aware of the privacy policies of any such site. If our privacy policy changes, and/or we plan to use your personal information in a way that is different from stated to you at the time of collection, you will be informed immediately and accordingly.

8. Disclaimer

The Privacy Policy of GenAqua is subject to change at any time and it is advised that you review it periodically to check for changes. However, in the event a change in this Privacy Policy occurs, we will inform you accordingly.

9. Data Retention

You may decide to have your Account closed at any time. Following closure of your Account, we will retain your personal data on record for as long as required by law. This data shall only be used should it be required by competent authorities in cases of enquiries regarding financial and fiscal records. You are to note that due to US and European tax ID regulations, we are required to retain an account holder’s personal data during the operative period of an Account for a minimum of five years from the last account holder transaction or account closure. Therefore, requests for erasure prior to the lapse of this period cannot be considered.

10. Contacting Us

You may always contact us in regards to this Policy should you wish to: 

  1. Confirm the accuracy of the personal information we have collected about you.
  2. Enquire about our use of your personal information.
  3. Prohibit future use of your data for direct marketing purposes. 
  4. Update or rectify any information that you have provided us. 

 

Note: It is illegal to provide us with false information about you and it is your responsibility to ensure that we are always updated with your correct data. In addition, as per Article 77 of the GDPR, you have the right to lodge a complaint related to your data processing to a supervisory authority, in particular in the member state of your habitual residence, place of work or place of an alleged infringement.