Jumping Rivers
External Privacy Notice

1. Introduction

We appreciate the trust you place in us when sharing your personal data. The security of that data is very important to us. In this notice, we will explain how we collect, use, and protect your personal data. We will also explain what rights you have with regards to your personal data and how you can exercise those rights.

2. Who We Are

Jumping Rivers has delivered quality data insights from day 1. Based in Newcastle and founded in 2016, the company is bringing a fresh approach to the world of data analytics. Our trainers and consultants come with over 100 years combined experience in R, Python, Stan, Scala and other programming languages. We have worked with some of the largest (and smallest) companies in the world.

Registered office address:

Helix,
Catalyst 3 Science Square,
Newcastle upon Tyne
NE4 5TG

If you have questions about how we process personal data, or would like to exercise your data subject rights, please email us at privacy@jumpingrivers.com

3. Company and Website Within Scope

The following company and websites are within scope of this privacy notice:

Jumping Rivers |www.jumpingrivers.com

We consider this website to be UK-based; see section 6 below for more information on non-UK data processing.
This notice also covers any additional personal data collected by telephone, email forms, or through Live Chat and any related social media applications.

4. Collection of Personal Data

We collect personal data from you for one or more of the following purposes:

To provide you with information that you have requested or that we think may be relevant to a subject in which you have demonstrated an interest.
To initiate and complete commercial transactions with you, or the entity that you represent, for the purchase of our services.
To fulfil contract that we have entered into with you or with the entity that you represent. In these circumstances it may be your entity, rather than yourself, that has provided us with your personal data.
To manage any communication between you and us.
Sending you information via our Newsletter or Mail-shots

The table in section 5 below provides more detail about the data that we collect for each of these purposes, the lawful basis for doing so, and the period for which we will retain each type of data.

Technical information:

In addition, to ensure that each visitor to our website can use and navigate the site effectively, we collect the following:

Technical information, including the IP (Internet Protocol) address used to connect your device to the Internet.
Information about your visit, including the URL (Uniform Resource Locators) click stream to, through, and from our site.

In section 8 below, we identify your rights in respect of the personal data that we collect and describe how you can exercise those rights.

5. Lawful Basis For the Processing of Personal Data

The table below describes the various forms of personal data we collect and the lawful basis for processing this data. We have processes in place to make sure that only those people in our organisation who need to access your data can do so. A number of data elements are collected for multiple purposes, as the table below shows. Some data may be shared with third parties; where this happens, this is also identified below.

When we process on the lawful basis of legitimate interest, we apply the following test to determine whether it is appropriate:

The purpose test - is there a legitimate interest behind the processing?
Necessity test - is the processing necessary for that purpose?
Balancing test - is the legitimate interest overridden, or not, by the individual's interests, rights or freedoms?

Purpose of collection	Information category	Data collected	Purpose for collection	Lawful basis for processing	Data shared with?	Retention period
To provide you with information	Subject matter information	Name, company name, geographic location, email address, business sector	To provide appropriate online or email information about services that you have requested	Contractual fulfilment	Internally only	Maximum eight years from the date the information is collected. Six months if a marketing email is left unopened
			To provide further, related, online or email information and ongoing news updates in relation to the identified area of interest	Legitimate interest	Internally only
		Telephone number.	Follow-up to ensure requested information meets the needs and identify further requirements.	Legitimate interest	Internally only
		Personal contact information as provided through website forms or other means.	General mailing list subscription	Consent	Internally only
Transactional information	Transaction details	Name, physical address, email address, telephone number, bank account details, (for credit accounts)	To process purchase transactions for services with customers, and to ensure any transaction issues can be dealt with.	Contractual performance	Internally only	Maximum eight years from the date of the performance of the contract. Six months from the data subject has input personal information but has not proceeded with a transaction
			For accounting and taxation purposes via XERO accounting platform	Statutory obligation	Internally & professional advisers
			Documentation should any contractual legal claim arise	Legitimate interest	Internally and professional advisors	Eight years from the performance contract
Communications	Contact information	Names, contact details, identification details.	To communicate with you about any issues that you raise with us, or which follows from an interaction between us.	Legitimate interest	Internally & professional advisers	Relevant statutes of limitation
Communications	Contact information	Past email data	To enable the sales team to progress a communication with a company and know the 'back story'	Legitimate interest	Internally & professional advisers	Relevant statutes of limitation
Aftercare	Contact information	Names, contact details, identification details	To offer ongoing support	Contractual fulfilment	Internally only	Eight years from the performance contract
Aftercare	Contact information	Names, contact details, identification details	To offer additional services.	Legitimate interest	Internally & professional advisers	Maximum eight years from the date the information is collected or eight years from the performance contract.Six months if a marketing email is left unopened

6. Storage of Personal Data

Jumping Rivers is a UK-based business with a sole UK office. For non-UK customers, we have appropriate contractual and security measures to protect personal data.

We may transfer your data to countries or organisations outside the European Union (EU) when necessary for the purposes outlined in this privacy policy. In cases where the transfer is not based on an adequacy decision, we will ensure that appropriate safeguards are in place in accordance with Articles 46, 47, or 49 of the UK GDPR. These safeguards may include standard contractual clauses, binding corporate rules, or other legally recognised mechanisms to protect your data during the transfer.

We use Asana, Google, GitLab, and Slack as our primary Cloud service providers (CSP) and as part of our processing environment. Unless we specifically state otherwise, we are, in respect of all CSPs, the data controller.
We operate a data retention policy in respect of all data, whether paper-based or digital, and those aspects of it that relate to personal data are contained in the table at 5, above.

7. Security Measures

We have what we believe are appropriate security controls in place to protect personal data. We do not, however, have any control over what happens between your device and the boundary of our information infrastructure. You should be aware of the many information security risks that exist and take appropriate steps to safeguard your own information. We accept no liability in respect of breaches that occur beyond our sphere of control.

8. Your Rights as a Data Subject

As a data subject whose personal information we hold, you have certain rights. If you wish to exercise any of these rights, please privacy@jumpingrivers.com or use the information supplied in the 'contact us' section below. To process your request, we will ask you to provide two valid forms of identification for verification purposes. Your rights are as follows:

The right to be informed - As a data controller, we are obliged to provide clear and transparent information about our data processing activities. This is provided by this privacy notice and any related communications we may send you.

The right of access - You may request a copy of the personal data we hold about you free of charge. Once we have verified your identity and, if relevant, the authority of any third-party requestor, we will provide access to the personal data we hold about you as well as the following information:
- The purposes of the processing
- The categories of personal data concerned
- The recipients to whom the personal data has been disclosed
- The retention period or envisioned retention period for that personal data
- When personal data has been collected from a third party, the source of the personal data

If there are exceptional circumstances that mean we can refuse to provide the information, we will explain them. If requests are frivolous or vexatious, we reserve the right to refuse them. If answering requests is likely to require additional time or occasions unreasonable expense (which you may have to meet), we will inform you.

The right to rectification - When you believe we hold inaccurate or incomplete personal information about you, you may exercise your right to correct or complete this data. This may be used with the right to restrict processing to make sure that incorrect/incomplete information is not processed until it is corrected.

The right to erasure (the 'right to be forgotten') - Where no overriding legal basis or legitimate reason continues to exist for processing personal data, you may request that we delete the personal data. This includes personal data that may have been unlawfully processed. We will take all reasonable steps to ensure erasure.

The right to restrict processing - You may ask us to stop processing your personal data. We will still hold the data but will not process it any further. This right is an alternative to the right to erasure. If one of the following conditions applies you may exercise the right to restrict processing:
- The accuracy of the personal data is contested.
- Processing of the personal data is unlawful.
- We no longer need the personal data for processing but the personal data is required for part of a legal process.
- The right to object has been exercised and processing is restricted pending a decision on the status of the processing.

The right to data portability - You may request your set of personal data be transferred to another controller or processor, provided in a commonly used and machine-readable format. This right is only available if the original processing was on the basis of consent, the processing is by automated means and if the processing is based on the fulfilment of a contractual obligation.

The right to object - You have the right to object to our processing of your data where
- Processing is based on legitimate interest;
- Processing is for the purpose of direct marketing;
- Processing is for the purposes of historic research; or
- Processing involves automated decision-making and profiling.

9. Contact Us

Any comments, questions or suggestions about this privacy notice or our handling of your personal data should be emailed toprivacy@jumpingrivers.com

Alternatively, you can contact us at our Head Office using the following postal address or telephone numbers:

Jumping Rivers,
Helix,
Catalyst 3 Science Square,
Newcastle upon Tyne
NE4 5TG

Telephone:+ 44(0) 191 432 4340

10. Complaints

Should you wish to discuss a complaint, please feel free to contact us using the details provided above. All complaints will be treated in a confidential manner.

Should you feel unsatisfied with our handling of your data, or about any complaint that you have made to us about our handling of your data, you are entitled to escalate your complaint to a supervisory authority within the European Union. For the UK, this is the ICO (Information Commissioner's Office), which is also our lead supervisory authority. Its contact information can be found at https://ico.org.uk/global/contact-us/.