Privacy Policy
This privacy notice covers our main activities including our website jam-pan.com.We describe here the data we collect from you when you engage with us.
These are our reasons for collecting it, what we do with it and what your rights are.
Who are we?
We are Jam-Pan Learning Ltd. Our registered address is 3 Hardman street, Spinningfields, Manchester, M3 3HF. (company registration number 08883684).
You can call us on +44(0) 161 397 4974 and email us at hello@jam-pan.com.
We are the data controller for this processing and are registered with the Information Commissioner’s Office (ICO). Our registration number is ZA589628.
Purpose of processing
We process your personal data for a variety of purposes as set out in the table below, which also shows our lawful basis under UK data protection legislation (UK GDPR) for doing so.
| Purpose | Lawful Basis under UK GDPR |
| Managing your enquiries | Our legitimate interests in responding to and managing your enquiry |
| Managing our commercial relationship with you as a client | Our legitimate interests in managing our commercial relationships and any associated contracts between our respective organisations |
| Managing our commercial relationship with you as a supplier | Our legitimate interests in managing our commercial relationships and any associated contracts between our respective organisations. If you are a sole trader or partnership then our lawful basis will be that processing is necessary to manage the contract with you |
| Direct marketing | Our legitimate interests in ensuring we appropriately manage, deliver or suppress direct marketing activity |
| Recruitment enquiries | Taking the steps necessary to enter into a contract with you. We will provide further privacy information to you as the recruitment process progresses. |
| Deployment of non-essential cookies | Your consent |
Where we are relying on our legitimate interests you are free to object to that at any time. In the case of direct marketing activities we will ensure that we cease to market our services to you should you object to our legitimate interests.
Where we are relying on your consent you are free to change your mind and withdraw your consent at any time.
Data we collect
The table below gives information on the categories of personal data we process for each of the purposes shown above.
| Purpose | Categories of Data Processed |
| Managing your enquiries | Name, contact details, company name, contact history and message content |
| Managing our commercial relationship with you as a client | Name, contact details, organisation & role, contact history, languages spoken |
| Managing our commercial relationship with you as a supplier | Name, contact details, organisation & role, contact details, languages spoken If you are a sole trader or partnership then financial records (payments, invoices, VAT details, banking details etc) will also be part of your personal data. |
| Direct marketing | Name, contact details, marketing preferences |
| Recruitment enquiries | Name, contact details, employment history, salary and benefit requirements, details of roles applied for |
| Deployment of non-essential cookies | Your record of consent |
Special category data
There are additional rules we must follow if we collect certain types of more sensitive data, known as Special Category Data. These include details of your ethnicity, beliefs, health and sexuality and in each case we must let you know what our additional lawful basis is for processing such data.
We do not routinely process any such special category data, however we may occasionally do so, for example if you are attending an event and we ask for dietary preferences which may infer a belief, and will always ensure we have a lawful basis (normally by asking for your explicit consent) and only retain the information for a very limited period of time.
How long do we keep your data for?
Where we are relying on our legitimate interests to process your data then we will keep your personal data until you object to our legitimate interests and we agree with your objection, or until the following default periods have elapsed after our last contact with you.
We will retain your personal data by default for the following periods:
| Purpose | Maximum Retention Period |
| Managing your enquiries | 7 years |
| Managing our commercial relationship with you as a client | 7 years |
| Managing our commercial relationship with you as a supplier | 7 years |
| Direct marketing | 7 years |
| Recruitment enquiries | 1 years |
| Deployment of non-essential cookies | 7 years (if retained, otherwise data deleted at end of each session) |
Do we ever share personal data?
We will share your data if we receive a legitimate request from a law enforcement agency.
When you submit your personal data online your data is shared with our partners who manage our website.
If we are communicating with you via email or social media channels, we will be sharing your personal data with those email and social media providers.
We also utilise external suppliers to provide several business supports services. We always ensure that we have appropriate contracts in place to protect your rights when personal data are processed on our behalf by these third parties. There is further information regarding these suppliers in the “Where Do We Process Data?” section.
How do we keep your data secure?
We take sensible steps to keep your data secure and ensure we can uphold your rights and meet our obligations under UK GDPR:
- All data sent between your browser and our website is encrypted in transit
- We ensure that appropriate contracts are in place with our suppliers who process your personal data to protect your rights, to ensure that they take appropriate security measures to safeguard your data, and that any international transfers are done correctly under UK GDPR,
- Our employees are all subject to an obligation of confidentiality, and receive training on data protection matters,
- We utilise appropriate technical and organisational measures to optimise the security of your personal data.
Your Rights
You have a number of rights relating to the processing of your data, if you would like to use them or have any questions then please contact us.
We won’t charge you for doing any of the following, however we may make a charge in the case of frequent repeat requests:
- Awareness: You have the right to be fully informed about why and how we process your information. This privacy notice is intended to meet that requirement, but please do contact us if you have any questions. If we obtain your personal data from a third party (e.g. a social media platform or recruitment platform) then we will tell you where we have obtained your information from,
- Access: You have the right to a copy of the data we hold about you,
- Rectification: If you think some of the data we hold is wrong then you have the right to ask us to correct it,
- Erasure: You have the right to ask us to delete the data we hold about you. Where we are holding the data to fulfil a contract with you or your organisation then we will need to retain the data in accordance with the data retention requirements shown above,
- Restriction: You have the right to ask us to restrict the processing of personal data whilst we check its accuracy, if you think the processing is unlawful, if you believe we no longer need to process the data but you need us to store it due to pending legal claims, or when you object to our processing based upon our legitimate interests and we are assessing the validity of that,
- Object: Where we are processing your personal data based upon our legitimate interests you have the right to object to that. If your objection is valid (for instance in the case of any direct marketing activity) then we will stop processing your personal data for that purpose,
- Data portability: You can request a copy of your data in a digital format which you can then supply to another provider when we ae processing your personal data under the lawful basis of performing a contract with you or because we have your consent.
- Automated decisions and profiling: You have the right, in certain circumstances, not to be subject to decisions based on automated processing (including profiling) if it has a significant or legal impact on you. This doesn’t apply if the processing is necessary to fulfil a contract with you, or if you have given us your consent to do so. We do not currently use any technology to make automated decisions about you
Cookies – How do we use cookies on our website?
We utilise cookies on our website. Some are required for our site to work, these are known as essential cookies, and we also use others for analytics and marketing purposes.
We will ask for your consent to use any cookies which aren’t essential, and we won’t deploy any non-essential cookies without your consent. You should be aware that whilst we use non-essential cookies to help us understand how our website is performing, the author of the cookies (e.g. Google) uses the data obtained for their own purposes.
These are cookies we use:
| Name of Cookie | Set By | Type |
| Google Tag Manager | Marketing and Analytics | |
| Google Analytics | Analytics | |
| Doubleclick.net | Marketing |
What happens when I follow links to other sites?
If you follow a link from our site to another site then you should read the privacy notice on the other site prior to providing your data to them.
Where do we process data?
We primarily process data in the UK however we use partners to help us deliver our services, some of these services will mean that your personal data are transferred outside of the UK.
Where we are using additional, specific partners to deliver services to you as a client and those partners are processing personal data then we will always ensure that we have appropriate Data Processing Agreements in place and, if necessary, an appropriate international transfer mechanism.
The following table shows the main systems providers we use, who act as our Processors.
| Partner | Where do they process data? | What additional protections are in place to safeguard your rights if processing is based overseas |
| Microsoft | USA | Standard Contractual Clauses in place |
| Zoho | USA | Standard Contractual Clauses in place |
| Mailchimp | USA | Standard Contractual Clauses in place |
| Xero | New Zealand | N/A – New Zealand hold adequacy status from UK |
Making a complaint
Please contact us at the above address. You can also contact the Information Commissioner’s Office (ICO) on their helpline 0303 123 1113 or online at www.ico.org.uk. If you should contact the ICO they will normally ask you to contact us first.