Privacy Notice
Revised: 8th February 2024
Introduction
At Join Branch Ltd (“Branch”, “we,” “us,” or “our”), we are strongly committed to transparency, and we want you (“you” or “your”) to understand how we collect, use, share and protect your information. This Privacy Notice (“Privacy Notice“) describes how Branch handles information in connection with Branch’s websites, programmes, communication channels (collectively, the “Services”), and when you otherwise interact with us. Please also read our Terms and Conditions which sets out the terms governing the Services.
We may change this privacy policy from time to time. In the event of material changes we will i) inform you about these changes in advance and ii) inform you of your right to object to these changes.
All questions and complaints about our use and handling of personal information should be addressed to hello@joinbranch.co
You also have the right of complaint to the UK’s Supervisory Authority for Data – the Information Commissioners Office (the “ICO”). See ico.org.uk/make-a-complaint
What personal information do we process?
We collect or receive information in different ways. The types of information we collect or receive depends on how you use and interact with our Services. In many cases, you can choose the information you provide to us, although certain information (such as Account Information) is required for us to provide the Services and if it is not provided, we will not be able to provide the Services. We use and disclose this information for the purposes described further below. Branch primarily processes and stores data using Google Workspace and Squarespace, with additional third-parties detailed below. The types of information we collect include:
Account Information such as your name, email address, telephone number, company, job title. We collect this information via various forms on our website (e.g. our ‘register interest’ form and ‘reserve a place’ form), and on forms that we send via other channels (e.g. forms sent via email). We may also collect this information from our interactions with you via communication channels (e.g. email, LinkedIn, Instagram, etc).
Payment information. When you purchase a Branch product, we provide you with an invoice or a link to pay by credit card. We keep internal records of financial transactions to comply with our legal obligations. Processing of credit card and payment data is handled by trusted third parties. Branch uses Monzo bank for all financial transactions, and an integration with Stripe to process credit card information.
We may collect and process information about you and your return to work when you enrol in one of our group programmes (or your employer enrols you). Specifically:
The date of your return to work so that we can create groups of people returning at a similar time.
Your email address so that we can invite you to Branch group sessions and community meetups
Your phone number so that we add you to your group’s WhatsApp group.
Your home address so that we can send you a materials related to Branch services (e.g. content booklet)
Your job title and company so that we can ensure that we assign people to relevant Branch groups, and can identify those that have had their space ‘pre-paid’ by their company as part of a corporate contract.
Information about how your space on the Branch programme will be funded so that we can process your payment using the appropriate channel, and at an appropriate price point.
Additional information about your return to work so that we can be sure that our Services can meet your individual needs. This data includes:
Information on parental leave (length taken, whether this is the first time you have taken parental leave)
Your subjective feelings about your return to work
Your hopes and expectations for the programme
Your consent for marketing communications so that we can ensure that our future communication is appropriate
Feedback data. When you use our Services, we may ask you to provide feedback. This information is used to improve our Services, and is typically collected via an optional form. Data collected includes your name, your subjective feedback, and quantitative ratings (e.g. NPS score). You can optionally provide a testimonial, which we may use publicly (e.g. on our website). When we use a testimonial publicly, we will refer to you by your first name. If you would like us to remove a testimonial that you have provided, please contact us at hello@joinbranch.co.
Web analytics data. Our website is build with Squarespace, who provide site analytics. This uses information collected by cookies (please see our Cookies and internet advertising policy below)
Do we process any sensitive personal information?
We do not process sensitive personal information (defined in Article 9 of UK GDPR as ‘special categories of personal data’)
Do we receive any information from third parties?
If you are joining a Branch programme via your employer, they may provide us with information that helps us get in touch with you. That information may include: name, email address and return to work date.
How do we process your information?
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
To deliver and facilitate delivery of our services. We may process your information to provide you with the requested service.
To respond to customer inquiries/offer support to customers. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user. For example, if you join one of Branch’s group programmes we may add you to a WhatsApp group with your coach and other members of your group.
To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.
What legal bases do we rely on to process personal information?
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
Performance of a Contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
When and with whom do we share your personal information?
We may share information in specific situations described below:
Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (‘third parties‘) who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organisation apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The third parties we may share personal information with are as follows:
Web and Mobile Analytics
Squarespace and Google Analytics
Website Hosting
Squarespace
Invoice and Billing
Monzo and Stripe
Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Do we use cookies and other tracking technologies?
We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information.
How long do we keep your information?
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
How do we keep your information safe?
We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
8. Do we collect information from minors?
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at hello@joinbranch.co
9. What are your privacy rights?
In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section “How can you contact us about this notice?” below.
We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html
Withdrawing your consent:
If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section “How can you contact us about this notice?” below.
However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications:
You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section ‘‘How can you contact us about this notice?’‘ below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
Cookies and similar technologies:
Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.
If you have questions or comments about your privacy rights, you may email us at hello@joinbranch.co
10. Controls for do-not-track features
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (‘DNT’) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
11. Do California residents have specific privacy rights?
California Civil Code Section 1798.83, also known as the ‘Shine The Light’ law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc).
12. Do we make updates to this notice?
We may update this privacy notice from time to time. The updated version will be indicated by an updated ‘Revised’ date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
13. How can you contact us about this notice?
If you have questions or comments about this notice, you may email us at hello@joinbranch.co
Branch is a company registered in England & Wales whose registered number is 14948252 with a registered office address at 27 Old Gloucester Street, London, United Kingdom, WC1N 3AX.
14. How can you review, update, or delete the data we collect from you?
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please contact us.