PRIVACY POLICY
BACKGROUND:
Navigator Media and Advertising Ltd trading as ‘OneTwenty’ understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, https://onetwenty.uk/ (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
Please read this Privacy Policy carefully and ensure that you understand it.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
| “Account” | means an account required to access and/or use certain areas and features of Our Site; |
| “Client” | Means a Client of ours by whom we are instructed to deliver services; |
| “Cookie” | means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and |
| “Cookie Law” | means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003; and |
| “Consumer” | Means an individual who uses our Site, a Client’s website and/ or a social media platform on which we advertise. |
2. Information About Us
Our Site is owned and operated by Navigator Media and Advertising Ltd, a limited company registered in England under company number 12613995.
Registered address: The Fort Business Centre Artillery Business Park, Park Hall, Oswestry, Shropshire, United Kingdom, SY11 4AD.
VAT number: GB VAT 353610616
Data Protection Officer: George Collins
Email address: hello@leadsnavigator.co.uk
Telephone number: 01743 623 613
Postal address: The Fort Business Centre Artillery Business Park, Park Hall, Oswestry, Shropshire, United Kingdom, SY11 4AD.
We are not directly regulated however the following organisations have a view into our activity:
The Advertising Standards Authority;
The Information Commissioners Office (we are registered);
The Gambling Commission; and
The Fundraising Regulator.
3. What Does This Policy Cover?
This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
4. What Is Personal Data?
Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
5. What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
- The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.
- The right to access the personal data we hold about you. Part 13 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 15 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
- The right to data portability. This means that, if you have provided personal data to u directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 15.
6. What Data Do You Collect and How?
6.1 We may collect personal data in the following ways:
6.1.1 as set out in the table below, using the methods also set out in the table;
6.1.2 by way of Consumer survey’s completed via social media platforms; and/ or
6.1.3 as provided to us by our Clients.
6.2 Please also see Part 14 for more information about our use of Cookies and similar technologies. We do not knowingly collect any ‘special category’ or ‘sensitive’ personal data, personal data relating to children or data relating to criminal convictions and/or offences.
| Data Collected | How We Collect the Data |
| Identity Information including name age, and gender.
Contact information including email and telephone number.
Social media profile platform information. |
Collected from:
|
| Payment information including payment card details. | Where collected, it will be collected and stored by our nominated payment processing provider. |
| Business Information for our Clients including username and password. | Collected from a Clients direct input on our platform and held via WordPress. |
| Technical information including I.P. address, browser type and version, and operating system, geographical data and preferences. | Collected either from a Consumers direct input on our Site and/ or via a third party website or social media platform; |
7. How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we will use your personal data, and our lawful bases for doing so:
| What We Do | What Data We Use | Our Lawful Basis |
| Collection of data via Client surveys. | Identity Information including name age, and gender.
Contact information including email and telephone number.
Social media profile platform information. |
Consent |
| Providing and managing your user access login and access to our Site. | Username and password. | Contract |
| Administering Our Site including monitoring how our Site is used so that we are able to provide a personalised browsing experience, to help us improve the Site to make them more user-friendly and help you find compatible organisations that could be of interest. | Device information, IP address, analysis of Site navigation via cookies event trackers, beacons and other technologies. | Legitimate Interests. |
| Supplying our services to you. | Contact details including name, address, and phone number. | Legitimate Interests. |
| Managing payments for our services from Clients. | Payment card details. | Contract |
| Personalising and tailoring our services for you. | Browsing data, IP address, and geographical data, gender and preferences. | Legitimate Interests. |
| Communicating with you. | Contact details including name, address, and phone number. | Legitimate Interests. |
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone, text message and/ or post with information, news, and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.
Third Parties (including but not limited to Facebook) whose content appears on Our Site may use third-party Cookies, as detailed below in Part 14. Their Privacy Policy is available at https://www.facebook.com/privacy/policy/. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.
We use the following automated systems for carrying out certain kinds of profiling. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the Data Protection Legislation gives you the right to do so. Please contact us to find out more using the details in Part 15.
- The following automated profiling may take place:
- We profile Consumer responses to questions on our Site to decide what next communication, if any they should receive in respect of their preferences. This data is collected under the legal basis of legitimate interest for the purpose of matching third party organisations to Consumers.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
8. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
| Type of Data | How Long We Keep It |
| Identity Information. | 90 days or until the relevant campaign has finished. |
| Contact information. | 90 days or until the relevant campaign has finished. |
| Social media profile platform information. | 90 days or until the relevant campaign has finished. |
| Client business information including username and password. | For as long as you are a Client accessing our Site. |
| Technical information including I.P. address, browser type and version, and operating system, geographical data and preferences. | 90 days or until the relevant campaign has finished. |
9. How and Where Do You Store or Transfer My Personal Data?
We will only store your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the EU GDPR and/or to equivalent standards by law. Transfers of personal data to the EEA from the UK are permitted without additional safeguards.
The security of your personal data is essential to us and to protect your data, we take a number of important measures, including the following:
- limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
- procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are] legally required to do so;
10. Do You Share My Personal Data?
Your personal data will also be transmitted to third parties that we use to provide our services; these parties have been rigorously assessed for the way in which they manage personal data and may only use your data for the exact purposes that we specify in the contract with them.
The third parties in question belong to the following categories:
- Companies such as payment service providers that help us to process your subscription payments.
- Professional service providers, such as email delivery suppliers, IT software providers, marketing and research agencies, analytics companies and website hosts who help us to run our business,
- Credit reference agencies, law enforcement and fraud prevention agencies, so we can help tackle fraud.
- Governmental bodies and regulators to comply with our legal obligations.
If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.
If any personal data is transferred outside of the UK, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 9.
If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
11. How Can I Control My Personal Data?
-
- In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and, at the point of providing your details).
- You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
12. Can I Withhold Information?
You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
You may restrict our use of Cookies. For more information, see Part 14.
13. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within one month and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
14. How Do You Use Cookies?
Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve our services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.
By using Our Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on Our Site for analytical purposes. For more details, please refer to the table below. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
All Cookies used by and on Our Site are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended. You will be given the opportunity to allow only first-party Cookies and block third-party Cookies.
Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
The following first-party Cookies may be placed on your computer or device:
| Name of Cookie | Strictly Necessary | Provider | Purpose |
| CookieConsent | Yes | onetwenty.uk | Stores the user’s cookie consent state for the current domain |
| elementor | Yes | onetwenty.uk | Used in context with the website’s WordPress theme. The cookie allows the website owner to implement or change the website’s content in real-time. |
| wpEmojiSettingsSupports | Yes | onetwenty.uk | This cookie is part of a bundle of cookies which serve the purpose of content delivery and presentation. The cookies keep the correct state of font, blog/picture sliders, color themes and other website settings. |
| _hjAbsoluteSessionInProgres | Yes | onetwenty.uk | This cookie is used to count how many times a website has been visited by different visitors – this is done by assigning the visitor an ID, so the visitor does not get registered twice. |
| _hjCookieTest | Yes | onetwenty.uk | Collects data on the user’s navigation and behavior on the website. This is used to compile statistical reports and heatmaps for the website owner. |
| _hjFirstSeen | Yes | onetwenty.uk | This cookie is used to determine if the visitor has visited the website before, or if it is a new visitor on the website. |
| _hjIncludedInSessionSample_# | Yes | onetwenty.uk | Collects statistics on the visitor’s visits to the website, such as the number of visits, average time spent on the website and what pages have been read. |
| _hjRecordingEnabled | Yes | hotjar.com | Collects data on the user’s navigation and behavior on the website. This is used to compile statistical reports and heatmaps for the website owner. |
| _hjSession_# | Yes | onetwenty.uk | Collects statistics on the visitor’s visits to the website, such as the number of visits, average time spent on the website and what pages have been read. |
| _hjSessionUser_# | Yes | onetwenty.uk | Collects statistics on the visitor’s visits to the website, such as the number of visits, average time spent on the website and what pages have been read. |
| hjActiveViewportIds | Yes | hotjar.com | This cookie contains an ID string on the current session. This contains non-personal information on what subpages the visitor enters – this information is used to optimize the visitor’s experience. |
| hjViewportId | Yes | hotjar.com | Saves the user’s screen size in order to adjust the size of images on the website. |
| _fbp | Yes | onetwenty.uk | Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers. |
| lastExternalReferrer | Yes | connect.facebook.net | Detects how the user reached the website by registering their last URL-address. |
| lastExternalReferrerTime | Yes | connect.facebook.net | Detects how the user reached the website by registering their last URL-address. |
and the following third-party Cookies may be placed on your computer or device:
| Name of Cookie | Purpose | Provider |
| gtags.js | Collects data about visitor activity on the Site such as pages visited, links clicks and time spent on the Site. It sends the data to Google Analytics for analysing website traffic and user behaviour. | |
| consent | Stores the user’s consent preferences for tracking purposes. | |
| _ga | Enables anonymous visitor tracking to generate statistical insights on our Site. | |
| _gid | Enables anonymous visitor tracking to generate statistical insights on our Site. | |
| _gat | Used to regulate request rate ensuring proper server resource allocation and preventing excessive data traffic. | |
| _gac | Stores campaign-related data and parameters, including traffic source (e.g. website or ad), the medium through which the user arrived (e.g. search or paid ads), the campaign name, and associated marketing information | |
| ga<property> | Assigns a randomly generated identifier to each user, ensuring anonymity while distinguishing individual visitors for analytical purposes. | |
| _fbp | Used by Facebook for advertising purposes. | |
| AEC | Tracks the user’s participation in Google’s A/B testing and experimentation programs | |
| __utmx | Used to determine a user’s inclusion in an experiment | |
| __utmxx | Used to determine the expiry of experiments a user has been included in | |
| _gaexp | Used to determine a user’s inclusion in an experiment and the expiry of experiments a user has been included in | |
| _opt_awcid | Used for campaigns mapped to Google Ads Customer IDs | |
| _opt_awmid | Used for campaigns mapped to Google Ads Campaign IDs | |
| _opt_awgid | Used for campaigns mapped to Google Ads Ad Group IDs | |
| _opt_awkid | Used for campaigns mapped to Google Ads Criterion IDs | |
| _opt_utmc | Stores the last utm_campaign query parameter | |
| _fbp | Used to deliver advertising products | |
| fr | Provides ad delivery or retargeting | |
| _hjid | Sets a unique ID for the session. Helps track user behaviour on the site for analytics | Hotjar |
| _hjTLDTest | Determines the path for the user tracking | Hotjar |
| bcookie | Used for browser ID and to share content off platform | Hotjar |
| lidc | Used for routing | Hotjar |
| UserMatchHistory | Used to track users on multiple websites | Hotjar |
| tt_webid | Used to track users on multiple websites | TikTok |
| ttcid | Used for user tracking for ad targeting. | TikTok |
| tt_wiewer | Used to store user preferences and other information. | TikTok |
Our Site uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how Our Site is used. This, in turn, enables us to improve Our Site and the services offered through it.
The analytics service(s) used by Our Site use(s) Cookies to gather the required information. You do not have to allow us to use these Cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable us to continually improve Our Site, making it a better and more useful experience for you.
The third party analytics service(s) used by Our Site use(s) the Cookies stated in the table above.
In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve our services. By using Our Site you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on Our Site for analytical purposes, full details of which are found in the tables above. In addition, Our Site uses analytics services provided by Google Analytics, which also use Cookies. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling us to better understand how people use Our Site.
15. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of George Collins:
Email address: hello@leadsnavigator.co.uk
Telephone number: 01743 623 613
Postal Address: The Fort Business Centre Artillery Business Park, Park Hall, Oswestry, Shropshire, United Kingdom, SY11 4AD.
16. Changes to this Privacy Policy
We may change this Privacy Policy from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date. This Privacy Policy was last updated in December 2023.