1 INTRODUCTION

1.1 Important information and who we are

Welcome to Juno Waters Limited’s Privacy and Data Protection Policy (“Privacy Policy”).
At Juno Waters Limited (“we”, “us”, or “our”) we are committed to protecting and 
respecting your privacy and Personal Data in compliance with the United Kingdom General 
Data Protection Regulation (“GDPR”), the Data Protection Act 2018 and all other mandatory 
laws and regulations of the United Kingdom.
This Privacy Policy explains how we collect, process and keep your data safe. The Privacy 
Policy will tell you about your privacy rights, how the law protects you, and inform our 
employees and staff members of all their obligations and protocols when processing data.
The individuals from which we may gather and use data can include:
Customers
Suppliers
Business contacts
Employees/Staff Members
Third parties connected to your customers
and any other people that the organisation has a relationship with or may need to contact.
This Privacy Policy applies to all our employees and staff members and all Personal Data 
processed at any time by us.

1.2 Who is Your Data Controller

Juno Waters Limited is your Data Controller and responsible for your Personal Data. We 
are not obliged by the GDPR to appoint a data protection officer and have not voluntarily 
appointed one at this time. Therefore, any inquiries about your data should either be sent 
to us on email at info@junobamboo.com or sent in a letter to Juno Waters Limited, 2 
Leman Street, London, E1W 9US, United Kingdom.
You have the right to make a complaint at any time to the Information Commissioner’s 
Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We 
would, however, appreciate the chance to deal with your concerns before you approach 
the ICO so please contact us in the first instance.

1.3 Processing Data on Behalf of a Controller and Processors’ responsibility to you
In discharging our responsibilities as a Data Controller we have employees who will deal 
with your data on our behalf (known as “Processors”). Therefore, the responsibilities 
described below may be assigned to an individual, or may be taken to apply to the 
organisation as a whole. The Data Controller and our Processors have the following 
responsibilities:
Ensure that all processing of Personal Data is governed by one of the legal bases 
laid out in the GDPR (see 2.2 below for more information on those bases);
Ensure that Processors authorised to process Personal Data have committed 
themselves to confidentiality or are under an appropriate statutory obligation of 
confidentiality;
Implement appropriate technical and organisational measures to ensure a level of 
security appropriate to the risk associated with the processing of Personal Data;
Obtain the prior specific or general authorisation of the Controller before engaging 
another Processor;
Assist the Controller in the fulfilment of the Controller's obligation to respond to 
requests for exercising the data subject's rights;
Make available to the Controller all information necessary to demonstrate 
compliance with the obligations laid down in the GDPR and allow for and contribute 
to audits, including inspections, conducted by the Controller or another auditor 
mandated by the Controller;
Maintain a record of all categories of processing activities carried out on behalf of a 
Controller;
Cooperate, on request, with the supervisory authority in the performance of its 
tasks;
Ensure that any person acting under the authority of the Processor who has access 
to Personal Data does not process Personal Data except on instructions from the 
Controller; and
Notify the Controller without undue delay after becoming aware of a Personal Data 
Breach;

2 LEGAL BASIS FOR DATA COLLECTION

2.1 Types of Data / Privacy Policy Scope

“Personal Data” 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).
We may collect, use, store and transfer different kinds of Personal Data about you which 
we have grouped together below. Not all of the following types of data will necessarily be 
collected from you but this is the full scope of data that we collect and when we collect it 
from you:
Profile/Identity Data: This is data relating to your first name, last name, gender, date 
of birth.
Contact Data: This is data relating to your phone number, addresses, email 
addresses, phone numbers.
Marketing and Communications Data: This is your preferences in receiving 
marketing information and other information from us.
Billing Data: This is information relating to your debit and credit card information 
such as the name attached to your payment details and your billing address.
Financial Data: These are your banking details e.g. your account number and sort 
code.
Transactional Data: This is information of details and records of all payments you 
have made for our services or products.
Technical Data: This is your IP address, browser type and version, time zone setting 
and location, operating system and platform, and other technology on the devices 
you use to engage with us.
Customer Support Data: This includes feedback and survey responses.
Usage Data: information about how you use our website, products and services.
We do not collect any Special Categories of Personal Data about you (this includes details 
about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, 
political opinions, trade union membership, information about your health, and genetic 
and biometric data). Nor do we collect any information about criminal convictions and 
offences.

2.2 The Legal Basis for Collecting That Data

There are a number of justifiable reasons under the GDPR that allow collection and 
processing of Personal Data. The main avenues we rely on are:
“Consent”: Certain situations allow us to collect your Personal Data, such as when 
you tick a box that confirms you are happy to receive email newsletters from us, or 
‘opt in’ to a service.
“Contractual Obligations”: We may require certain information from you in order 
to fulfil our contractual obligations and provide you with the promised service.
“Legal Compliance”: We’re required by law to collect and process certain types of 
data, such as fraudulent activity or other illegal actions.
“Legitimate Interest”: We might need to collect certain information from you to be 
able to meet our legitimate interests - this covers aspects that can be reasonably 
expected as part of running our business, that will not have a material impact on 
your rights, freedom or interests. Examples could be your address, so that we know 
where to deliver something to, or your name, so that we have a record of who to 
contact moving forwards.

3 HOW WE USE YOUR PERSONAL DATA

3.1 Our Uses

We will only use your Personal Data when the law allows us to. Set out below is a table 
containing the different types of Personal Data we collect and the lawful basis for 
processing that data. Please refer to section 2.2 for more information on the lawful basis 
listed in the table below.
Examples provided in the table below are indicative in nature and the purposes for which 
we use your data may be broader than described but we will never process your data 
without a legal basis for doing so and it is for a related purpose. For further inquiries 
please contact us.

3.2 Marketing and Content Updates

You will receive marketing and new content communications from us if you have created an account and chosen to opt into receiving those communications. From time to time we may make suggestions and recommendations to you about goods or services that may be of interest to you.

3.3 Change of Purpose

We will only use your Personal Data for the purposes for which we collected it, unless we 
reasonably consider that we need to use it for another reason and that reason is 
compatible with the original purpose. If you wish to get an explanation as to how the 
processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your Personal Data for an unrelated purpose, we will notify you and we 
will explain the legal basis which allows us to do so.
Please note that we may process your Personal Data without your knowledge or consent, 
in compliance with the above rules, where this is required or permitted by law.

4 YOUR RIGHTS AND HOW YOU ARE PROTECTED BY US

4.1 How Does Juno Waters Limited Protect Customers' Personal Data?
We are concerned with keeping your data secure and protecting it from inappropriate 
disclosure. Any Personal Data collected by us is only accessible by a limited number of 
employees who have special access rights to such systems and are bound by obligations 
of confidentiality. If and when we use subcontractors to store your data, we will not 
relinquish control of your Personal Data or expose it to security risks that would not have  arisen had the data remained in our possession. However, unfortunately no transmission of data over the internet is guaranteed to be completely secure. It may be possible for 
third parties not under the control of Juno Waters Limited to intercept or access 
transmissions or private communications unlawfully. While we strive to protect your 
Personal Data, we cannot ensure or warrant the security of any Personal Data you 
transmit to us. Any such transmission is done at your own risk. If you believe that your 
interaction with us is no longer secure, please contact us.

4.2 Opting Out Of Marketing Promotions

You can ask us to stop sending you marketing messages at any time by You can ask us to 
stop sending you marketing messages at any time by manually unsubscribe or emailing us 
at info@junobamboo.com.
Where you opt out of receiving these marketing messages, we will continue to retain other 
Personal Data provided to us as a result of interactions with us not related to your 
marketing preferences.

4.3 How to Request your Data and the Process for Obtaining it

You will not have to pay a fee to access your Personal Data (or to exercise any of the other 
rights). However, if your request is clearly unfounded, we could refuse to comply with your 
request.
We may need to request specific information from you to help us confirm your identity 
and ensure you have the right to access your Personal Data (or to exercise any of your 
other rights). This is a security measure to ensure that Personal Data is not disclosed to 
any person who has no right to receive it. We may also contact you to ask you for further 
information in relation to your request to speed up our response.

5 YOUR DATA AND THIRD PARTIES

5.1 Will We Share Your Data With Third Parties?

We may share non-Personal Data with third parties. We may share your Personal Data 
with subcontractors or affiliates (subject to confidentiality obligations to use it only for the 
purposes for which we disclose it to them and pursuant to our instructions).
We may also share Personal Data with interested parties in the event that Juno Waters 
Limited anticipates a change in control or the acquisition of all or part of our business or 
assets or with interested parties in connection with the licensing of our technology.
If Juno Waters Limited is sold or makes a sale or transfer, we may, in our sole discretion, 
transfer, sell or assign your Personal Data to a third party as part of or in connection with 
that transaction. Upon such transfer, the Privacy Policy of the acquiring entity may govern 
the further use of your Personal Data. In all other situations your data will still remain 
protected in accordance with this Privacy Policy (as amended from time to time).
We may share your Personal Data at any time if required for legal reasons or in order to 
enforce our terms or this Privacy Policy.

6 HOW LONG WILL WE RETAIN YOUR DATA FOR?

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes 
we collected it for. We may retain your Personal Data for a longer period than usual in the event 
of a complaint or if we reasonably believe there is a prospect of litigation in respect to our 
relationship with you.

7 AGE LIMIT FOR OUR USERS

You must not use Juno Waters Limited unless you are aged 16 or older. If you are under 16 and 
you access Juno Waters Limited by lying about your age, you must immediately stop using Juno 
Waters Limited.
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This website is not intended for children and we do not knowingly collect data relating to children.

8 INTERNATIONAL TRANSFER OF DATA

Your information may be stored and processed in the US or other countries or jurisdictions 
outside the US where Juno Waters Limited has facilities. We are currently storing data in the EU 
and so, by using Juno Waters Limited, you are permitting and consenting to the transfer of 
information, including Personal Data, outside of the US.

9 NOTIFICATION OF CHANGES AND ACCEPTANCE OF POLICY

We keep our Privacy Policy under review and will place any updates on this webpage. This 
version is dated 12 December 2019. By using Juno Waters Limited, you consent to the collection 
and use of data by us as set out in this Privacy Policy. Continued access or use of Juno Waters 
Limited will constitute your express acceptance of any modifications to this Privacy Policy.

10 INTERPRETATION

All uses of the word "including" mean "including but not limited to" and the enumerated 
examples are not intended to in any way limit the term which they serve to illustrate. Any email 
addresses set out in this policy may be used solely for the purpose for which they are stated to 
be provided, and any unrelated correspondence will be ignored. Unless otherwise required by 
law, we reserve the right to not respond to emails, even if they relate to a legitimate subject 
matter for which we have provided an email address. As a matter of common sense, you are 
more likely to get a reply if your request or question is polite, reasonable and there is no 
relatively obvious other way to deal with or answer your concern or question (e.g. FAQs, other 
areas of our website etc.).
Our staff are not authorised to contract on behalf of Juno Waters Limited, waive rights or make 
representations (whether contractual or otherwise). If anything contained in an email from a Juno 
Waters Limited address contradicts anything in this policy, our terms or any official public 
announcement on our website, or is inconsistent with or amounts to a waiver of any Juno Waters 
Limited rights, the email content will be read down to grant precedence to the latter. The only 
exception to this is genuine correspondence expressed to be from the Juno Waters Limited legal 
department.

11 TERMS OF USE

Please also see our Terms of Use which set out the terms, disclaimers, and limitations of liability 
governing your use of Juno Waters Limited