Last updated: 16 August 2022 (previous version 10 January 2021)
What’s new: Updates to section 3.2 and 10.2 regarding Google
This policy covers how your information may be held and used by The Gap Year Edit. Click on the numbered list below to take you straight to the relevant section.
1.1 This website is owned and operated by The Gap Year Edit. Throughout this policy, “We”, “Us” and “Our” means The Gap Year Edit. We are committed to safeguarding the privacy of our website visitors and service users.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
1.5 We may update this policy from time to time by publishing a new version on the Privacy and Cookies policy page of our website. This page will include the date of the most recent update. You should check the page occasionally to ensure you are happy with any changes to this policy.
3.1 In this Section 3 we have set out (a) the general categories (types) of personal data we may process; (b) why we may process it; and (c) the legal bases for processing. For the latter, data protection law means we need to have one more of the following six reasons for using your information: contract performance, legal obligation, legitimate interest, consent, vital interests or public task. You can find more about these legal bases on the Information Commissioner’s Office website.
3.2 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern. The source of the usage data Jetpack and Google Analytics and Affiliate (referral) schemes of which The Gap Year Edit is a member. This usage data may be processed for the purposes of analysing the use of the website and services. The legal bases for this processing are our legitimate interests (monitoring and improving our website and services) and/or consent (through acceptance of website cookies as indicated in section 1.3). See section 10.2 for information on how Google processes your data.
3.3 We may process information that you post for publication on our website, social media channels or through our service (“publication data“). The publication data may be processed for the purposes of enabling such publication, administering our website, and services, and for marketing purposes. The legal basis for this processing is legitimate interest and/or consent.
3.4 We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data“). The enquiry data may be processed for the purposes of researching, offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.
3.5 We may process information relating to our customer relationships, including customer contact information (“customer relationship data“). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is the performance of a contract between you and us and our legitimate interests, namely the proper management of our customer relationships.
3.6 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“accounts data“). The transaction data may include your contact details, your payment details and the transaction details. The source of the accounts data is you or your employer. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.
3.7 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletter(s) (“notification data“). We use Mailchimp as our marketing platform. By subscribing to our email notifications and/or newsletter(s) you acknowledge that your notification data information will be transferred to Mailchimp for processing for the purposes of sending you the relevant notifications and/or newsletter(s) requested. Learn more about Mailchimp’s privacy practices here. Should you wish to unsubscribe, you can click the unsubscribe link in the footer of any email you receive from us, or contact us directly. The legal basis for this processing is consent.
3.8 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
4.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4.2 We may disclose your personal data to our suppliers or subcontractors insofar as reasonably necessary for the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.
4.3 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5.1 You acknowledge that personal data that you submit for publication through our website, social media channels or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3 We will retain your personal data as follows:
(a) Personal data (as set out in Section 3) will be reviewed annually. Contact details will be retained where there is a basis for doing so; otherwise they will be deleted as part of this annual review process.
(b) Personal data in respect of Section 3.7 and our enewsletter database (“notification data”) will also be reviewed annually. Where enewsletter subscribers have not opened a newsletter during the previous 12-month period, and when newsletters have been sent at least four times during this same 12-month period, they will be unsubscribed from the enewsletter service.
6.4 We may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
6.5 We endeavour to take all reasonable steps to protect your personal information. However, we cannot guarantee the security of any data that you disclose and we will not be responsible for any breach of security unless this is due to our negligence or willful default.
7.1 In this Section 7, we have summarised the rights that you have under data protection law. You should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
7.2 Your principal rights under data protection law are (a) the right to access; (b) the right to rectification; (c) the right to erasure; (d) the right to restrict processing; (e) the right to object to processing; (f) the right to data portability; (g) the right to complain to a supervisory authority; and (h) the right to withdraw consent.
7.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies requested within twelve months of the initial request will be charged at £10 or the equivalent value in other currencies.
7.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
7.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
7.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
7.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
7.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
7.9 To the extent that the legal basis for our processing of your personal data is (a) consent; or (b) that the processing is necessary for the performance of a contract to which you are party (or in order to take steps at your request prior to entering into a contract), and such processing is carried out by automated means; you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
7.10 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
7.11 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
7.12 You may exercise any of your rights in relation to your personal data by written notice to us.
8.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
8.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
8.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
10.2 The cookies in use on The Gap Year Edit website are for Google Analytics including Google Analytics Advertising Reporting Features, and for our Affiliate (referral) partners. Google Analytics is a web analytics tool that helps website owners understand how visitors engage with their website. The Gap Year Edit then uses the information to compile reports about how visitors interact with the website so they can make future improvements. Google utilises the data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services. Google may use the data collected to contextualise and personalise the ads of its own advertising network.
11.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. This blog post contains useful information for how to block cookies in different browers.