Privacy Policy

This policy intends to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it.

If for any reason any part of this Privacy Notice is not clear enough for you, please do get in touch with our Legal & Compliance Team on legal@journeyfurther.com as we’d welcome any feedback to make it even better for you. This is because we really do care about data privacy and we know that when you share your information with us, it’s because you trust us, and we are committed to maintaining that trust.

As the data privacy world has a lot of technical legal words and phrases, we’ve created a Glossary at the end of this Privacy Notice to explain these terms and phrases. For any words and phrases in this Privacy Notice that start with a capital letter, take a look at the Glossary.

 

1. A little summary on us

We are a performance marketing agency providing various marketing and advertising services to our clients. Our company structure consists of three legal entities which are incorporated in England & Wales and fall under the Journey Further brand and collectively form a group. This Privacy Notice applies to the entire group and covers all website users, candidates and prospective and existing clients and suppliers that engage with us.

 

2. Some important legal stuff

Our Legal & Compliance Team keep up to date with Data Protection Laws and have read the full 261 pages of the European Union’s General Data Protection Regulation 2016/679 (“EU GDPR”) in order to make sure that we comply with all of our obligations in it as well as those now subsequently in the UK GDPR. The UK GDPR is the UK’s version of the EU GDPR and comprises of the Data Protection Act 2018 and the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 (SI 2019/419)).

Data Protection Laws have created the concepts of a “Data Controller” and a “Data Processor” and Journey Further fits into each concept albeit in different circumstances. For example, we are a Data Controller when candidates are applying to join us and a Data Processor when we are performing some of our services for our clients. To keep us (and all other organisations) in check, we are supervised by the Information Commissioner’s Office (“ICO”) which is the data protection supervisory authority in England & Wales.

 

3. Different types of personal data in a nutshell

We collect, use, store and transfer different kinds of Personal Data depending on our relationship with you. In general, we collect the following types:

  • Identity Data (e.g., first name, maidan name, last name, title, data of birth).
  • Contact Data (e.g., phone number, email address, business address and billing address).
  • Communications & Marketing Data (e.g., your preferences in respect of cookies and marketing).
  • Financial Data (e.g., bank account details, value added tax numbers).
  • Profile Data (e.g., agreements you have entered into with us such as our terms and conditions).
  • Transaction Data (e.g., invoices, payment details).
  • Technical Data (e.g., internet protocol addresses, browser type and version, time zone settings and location).
  • Usage Data (e.g., information about how you use our website).

We also collect, use and share “Aggregated Data” such as statistical or demographic data for other purposes including research and analysis. Aggregated Data could be derived from your Personal Data but is not considered Personal Data under Data Protection Laws as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website 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 Notice.

We occasionally collect some Special Category Personal Data about you (such as information about your health where you are a prospective member of staff). We only collect this type of Personal Data when we have a legal ground in which to do so (i.e., you have given us your Consent and chosen to provide us with this data). We do not collect any Criminal Convictions Data except in the employment context and where we are permitted by law to do so when completing background checks on prospective staff.

 

4. “I am a website user”

What do we collect? We collect Technical Data and Usage Data (for tracking purposes). We also collect Identity Data, Contact Data and Communications & Marketing Data (if you decide to contact us and/or subscribe to our awesome Book Club).

How do we collect this? As you interact with our website, we automatically collect this data about you by using cookies and similar technologies (check out our Cookies Notice here). We also collect this data through our direct interactions with you such as when you contact us through our website.

What’s our legal ground(s) for Processing? One or more of the following apply:

  • Consent (i.e., in that you are choosing to provide us with your details so that we can contact you).
  • Legitimate Interests (i.e., its necessary for our Legitimate Interests in running and developing our business including our marketing strategy).
  • Legal obligation (i.e., its necessary for us to comply with a legal obligation such as in the instance where you no longer wish to be contacted for direct marketing purposes).

 

5. “I am a participant in a competition”

What do we collect? We collect Technical Data and Usage Data (for tracking purposes). We also collect Identity Data, Contact Data and Communications & Marketing Data (if and where you agree for us to contact you with newsworthy updates).

How do we collect this? As you interact with our website, we automatically collect this data about you by using cookies and similar technologies (check out our Cookies Notice here). We also collect this data through our direct interactions with you such as when you sign-up to participate in one of our competitions.

What’s our legal ground(s) for Processing? One or more of the following apply:

  • Contract (i.e., in that you have entered into our terms and conditions for participation in the competition)
  • Legitimate Interests (i.e., its necessary for our Legitimate Interests in running and developing our business including our marketing strategy).
  • Legal obligation (i.e., its necessary for us to comply with a legal obligation such as in the instance where you no longer wish to be contacted for direct marketing purposes).

 

6. “I am a candidate applying for a job”

What do we collect? We collect Technical Data and Usage Data (for tracking purposes). We also collect Identity Data, Contact Data and Communications & Marketing Data (such as information submitted as part of your application to join us).

How do we collect this? As you interact with our website, we automatically collect this data about you by using cookies and similar technologies (check out our Cookies Notice here). We also collect this data through our direct interactions with you and third parties (such as recruitment agencies or your references).

What’s our legal ground(s) for Processing? One or more of the following apply:

  • Consent (i.e., in that you are choosing to provide us with your details so that we can contact you about a vacancy).
  • Contract (i.e., in that we need this information to potentially enter into a contract with you).

 

7. “I am a potential or existing client”

What do we collect? We collect Technical Data and Usage Data (for tracking purposes). We also collect Identity Data, Contact Data, Financial Data, Transaction Data, Profile Data and Communications & Marketing Data (for when you enter into our terms and conditions for services).

How do we collect this? As you interact with our website, we automatically collect this data about you by using cookies and similar technologies (check out our Cookies Notice here). We also collect this data through our direct interactions with you and third parties (as detailed below).

What’s our legal ground(s) for Processing? One or more of the following apply:

  • Contract (i.e., in that we need this information to enter into or perform a contract with you).
  • Legitimate Interests (i.e., its necessary for our Legitimate Interests in recovering debts due to us from you).
  • Legal obligation (i.e., its necessary for us to comply with a legal obligation such as in respect to our financial, tax and legal affairs).

 

8. “I am a potential or existing supplier”

What do we collect? We collect Technical Data and Usage Data (for tracking purposes). We also collect Identity Data, Contact Data, Financial Data, Transaction Data and Profile Data (for when we are engaging you for your services).

How do we collect this? As you interact with our website, we automatically collect this data about you by using cookies and similar technologies (check out our Cookies Notice here). We also collect this data through our direct interactions with you (i.e., we will hold Personal Data on your staff that have engaged with us).

What’s our legal ground(s) for Processing? One or more of the following apply:

  • Contract (i.e., in that we need this information to enter into or perform a contract with you).
  • Legitimate Interests (i.e., its necessary for our Legitimate Interests in keeping records to develop our business strategy).
  • Legal obligation (i.e., its necessary for us to comply with a legal obligation such as in respect to our financial, tax and legal affairs).

 

9. Sharing your personal data

We will only share your Personal Data when necessary and have outlined examples of the types of organisations with whom we would share it with:

  • Technology companies that provide us with desktop and cloud-based products, solutions and services (as we will need their support in order to communicate with you and/or deliver our services, e.g., Slack, Google, Facebook).
  • Professional advisers such as law firms, banks and accountancy firms (as we need to engage with them for the purposes of our business).
  • Third parties to whom we may be in contact with to sell, transfer or merge parts of our business or assets, or to attempt to acquire or merge with other companies (as we may need to disclose some of your Personal Data).
  • Regulators and other governmental authorities (as we need to engage with them for the purposes of our business).

We require all third parties to respect the security of your Personal Data and to treat it in accordance with Data Protection Laws. We enter into contractual agreements with all of our third parties (with the exception of regulators and governmental authorities) which include the appropriate data protection clauses.

 

10. In the digital world, data can travel rapidly across borders

Whenever your Personal Data travels outside of the UK and/or the EEA, we ensure that it’s protected by putting in one of the following safeguards:

  • 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.
  • We will only transfer your Personal Data where we have entered into specific contracts with an organisation outside of the UK and/or the EEA which states that they will ensure that your Personal Data has the same level of protection as if it were in the UK and/or the EEA.

If you want to find out the specific mechanism used when transferring your Personal Data out of the UK and/or the EEA, please contact our Legal & Compliance Team.

 

11. We like data, but we don’t keep it for longer than necessary

We will only keep your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you (although, of course, we really don’t want to be in that situation).

To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we Process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

As a note, in some circumstances we will anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information without further notice to you.

 

12. Your data = your rights

Under certain circumstances, you have specific rights in respect of the Personal Data that we Process about you. Your rights include:

  • the right of access to the Personal Data we hold about you.
  • the right to rectify (i.e., correct) your Personal Data where it is inaccurate or incomplete.
  • the right to delete your Personal Data, but only in specific circumstances, for example where the Personal Data is no longer necessary in relation to the purpose for which it was originally collected or Processed. It may not therefore always be possible for us to delete all of the information we hold about you if you request this, for example, if we have an ongoing contractual relationship with you.
  • the right to restrict Processing in specific circumstances, for example while we are reviewing the accuracy or completeness of data or deciding on whether any request for erasure is valid.
  • the right to object to Processing in cases where Processing is based upon our Legitimate Interests or where Processing is for direct marketing purposes (including profiling).
  • the right to data portability which means the right to receive, move, copy or transfer your Personal Data to another Data Controller. You have the right to this when we are Processing your Personal Data based on Consent or on a contract and the Processing is carried out by automated means.
  • the right to lodge a complaint with the ICO.

If you wish to exercise any of the rights set out above, please contact our Legal & Compliance Team. You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity. This is a security measure also in your own interest 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.

We try to respond to all legitimate requests within 1 month. Occasionally it could take us longer than 1 month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

13. We won’t let anyone mess with your data

We have put in place appropriate technical and organisational security measures to prevent your Personal Data from being accidentally lost, falsified, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, contractors and other third-parties who have a business need to know. We have put in place policies, plans and procedures to deal with any suspected or actual personal data breaches (although we hope not to ever be in that position).

 

14. Third party links and social plugins

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy documentation of every website you visit.

 

15. Marketing

We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising. We may use your Identity Data, Contact Data, Technical Data, Usage Data and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.

You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing. We will get your express opt-in Consent before we share your Personal Data with any third-party for marketing purposes. You can ask us or third parties to stop sending you marketing messages at any time by contacting our Legal & Compliance Team and withdrawing your Consent. Where you opt out of receiving these marketing messages, this will not apply to messages that we need to send you a result of performing a contract that we have with you (e.g., as we may be required to contact you about a payment due).

 

16. Contact us

To get in touch with our Legal & Compliance Team, please contact legal@journeyfurther.com.

We also need to let you know that if you have any concerns and/or you’re not happy with our approach, you have the right to make a complaint to the ICO which can be contacted on www.ico.org.uk Data Protection Laws are constantly evolving, and we endeavour to maintain best practice. However, we recognise that we may not always get it right and if you are not satisfied in the way we handle your Personal Data, or you wish to discuss our processes then we would like to hear from you and recommend that you contact us in the first instance.

 

17. Glossary

Consent: refers to when an individual gives agreement which is freely given, specific, informed and is an unambiguous indication of their wishes. It is done by a statement or by a clear positive action in respect of the Processing of any Personal Data relating to them.

Criminal Convictions Data: refers to Personal Data relating to criminal convictions and offences and includes Personal Data relating to criminal allegations and proceedings.

Data Controller: refers to an organisation that determines when, why and how to Process Personal Data. It is responsible for establishing practices and policies in line with Data Protection Laws. There are certain circumstances where we act as a Data Controller.

Data Protection Laws: refers to the European Union’s General Data Protection Regulation 2016/679 and the UK GDPR. The UK GDPR is the UK’s version of the EU GDPR and comprises of the Data Protection Act 2018 and the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 (SI 2019/419)).

Data Processor: refers to an organisation that Processes Personal Data on behalf of a Data Controller. It is also responsible for establishing practices and policies in line with Data Protection Laws and its contractual obligations with Data Controllers. There are certain circumstances where we act as a Data Processor.

European Economic Area (“EEA”): refers to the 27 countries in the European Union, Iceland, Liechtenstein and Norway.

Legitimate Interest: refers to when an organisation’s interests are legitimate (as they need to do something to operate and be successful) and these interests do not override an individual’s interests or fundamental rights and freedoms. We make sure to consider and balance any potential impact on individuals (both positive and negative) and their rights before we Process any Personal Data for our Legitimate Interests.

Personal Data: refers to any information identifying an individual or information relating to an individual that an organisation can identify (directly or indirectly) from that data alone or in combination with other identifiers that it Processes. Personal Data includes Special Category Personal Data, Criminal Convictions Data and pseudonymised Personal Data. Personal Data excludes anonymous data or data that has had the identity of an individual permanently removed.

Processing or Process: refers to any activity that involves the use of Personal Data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transmitting or transferring Personal Data to third parties.

Special Category Personal Data: refers to information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data.