Privacy Policy
Jetty Partners LLC and Jetty Partners UK Ltd
Last updated: August 1, 2026 · Version 1.0
This policy applies to individuals in the United Kingdom, the European Union / EEA, and the United States (including California).
1. About this policy
Jetty Partners LLC and Jetty Partners UK Ltd (“Jetty Partners”, “we”, “us” or “our”) are committed to protecting your privacy and handling your personal information responsibly and transparently. This Privacy Policy explains what personal information we collect about you, how and why we use it, who we share it with, how long we keep it, and the rights and choices you have.
We are the data controller responsible for your personal information. Our registered office is at 15 Stratton Street, London W1J 8LQ and our company registration number is 17092081. This policy covers our website at www.jettypartners.com (the “Website”), as well as personal information we collect when you contact us, enquire about or use our services, or otherwise interact with us.
Because we operate in the United Kingdom, Europe and the United States, this policy is designed to meet the requirements of the UK GDPR and Data Protection Act 2018, the EU General Data Protection Regulation (EU GDPR), the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA), and other applicable US state privacy laws.
Separate notices. If you are a job applicant, employee, worker or contractor, we provide you with a separate privacy notice covering that relationship. This policy is primarily for website visitors, customers, prospective customers, suppliers and other business contacts.
2. The personal information we collect
2.1 Information you provide to us
We collect information you give us directly, for example when you complete a contact or enquiry form, request information about our services, correspond with us by email or phone, or enter into a contract with us. This may include:
- Identity and contact details – your name, email address, telephone number, and postal address.
- Business details – your employer or organisation, job title or role, and other professional information (where you contact us in a business capacity).
- Enquiry and correspondence content – the content of your message, the nature of your enquiry, and any other information you choose to provide.
- Service and transaction information – records of the services we discuss or provide, and related correspondence.
2.2 Information we collect automatically
When you visit our Website, we collect certain information using two analytics tools:
- Google Analytics 4 – which uses cookies and collects information such as your IP address, device and browser type, pages viewed, referring pages, and how you navigate the Website. Google Analytics is only loaded after you consent to analytics cookies.
- Umami – a privacy-friendly, cookieless analytics tool that collects only aggregated, anonymous usage statistics (such as page views and general referrers). It does not use cookies, does not store your IP address, and cannot be used to identify you.
Between them, this may include your device and connection data (IP address, browser, operating system), usage data (pages viewed, links clicked, dates and times), and approximate location inferred from your IP address (not precise GPS location).
2.3 Information we receive from third parties
- Analytics providers – aggregated insights about how visitors use our Website (from Google Analytics).
- Publicly available and business sources – professional or business contact information from public sources, business directories, or referrals, where we contact you in a business capacity.
- Service providers – our IT, hosting and communications platforms.
2.4 Sensitive information
We do not seek to collect any “special category” data (UK/EU) or “sensitive personal information” (California) – such as data revealing racial or ethnic origin, health, religious beliefs, precise geolocation, or government identifiers – through our Website. Please do not include such information in enquiry forms or correspondence unless we specifically request it for a defined purpose.
2.5 Categories of personal information under California law
In the 12 months prior to the “last updated” date above, we have collected the following statutory categories of personal information (as defined by the CCPA/CPRA). We do not sell your personal information, and we do not share it for cross-context behavioural advertising.
| Category | Collected? | Business purpose | Disclosed to |
|---|---|---|---|
| A. Identifiers (name, email, phone, IP, online IDs) | Yes | Respond to enquiries; provide services; site security; analytics | Service providers; analytics provider (Google) |
| B. Customer records (contact details; limited commercial info) | Yes | Manage the customer/prospect relationship and contracts | Service providers |
| C. Protected classification characteristics | No | Not collected | – |
| D. Commercial information (services enquired about / purchased) | Yes | Provide and improve our services | Service providers |
| E. Biometric information | No | Not collected | – |
| F. Internet / network activity (browsing, interactions) | Yes | Analytics; site performance | Analytics provider (Google) |
| G. Geolocation data (approximate, from IP) | Yes | Security; analytics | Service providers; analytics provider |
| H. Sensory data (audio/visual) | No | Not collected via the Website | – |
| I. Professional / employment information | Yes | Manage B2B relationships and enquiries | Service providers |
| J. Education information | No | Not collected | – |
| K. Inferences drawn from the above | Limited | Understand our audience (aggregate) | Service providers |
| L. Sensitive personal information | No | Not collected | – |
3. How and why we use your personal information
We use your personal information for the purposes set out below. Under UK/EU data protection law we must have a “lawful basis” for each use; the table shows the basis we rely on.
| Purpose | Information used | Lawful basis (UK/EU GDPR) |
|---|---|---|
| Respond to your enquiries and correspondence | Identity, contact, business details, enquiry content | Legitimate interests (to respond to and manage enquiries); or steps prior to entering a contract |
| Provide, manage and perform our services and contracts | Identity, contact, business, service and transaction data | Performance of a contract; legitimate interests |
| Operate, secure and improve our Website | Device/connection data, essential cookies | Legitimate interests (to run a safe, functional website) |
| Measure Website usage with Google Analytics | Usage data, analytics cookie identifiers | Consent (via cookie banner) |
| Measure Website usage with Umami (cookieless, aggregate) | Aggregated, anonymous usage data | Legitimate interests (low-risk, first-party statistics) |
| Send business-to-business or requested marketing | Identity and contact details | Consent, or legitimate interests / “soft opt-in” where permitted (see Section 5) |
| Comply with legal, tax and regulatory obligations | Contact, transaction and correspondence records | Legal obligation |
| Establish, exercise or defend legal claims | Any relevant information | Legitimate interests (to protect our rights) |
Change of purpose. We will only use your personal information for the purposes for which we collected it, unless we reasonably consider we need to use it for a compatible reason. If we need to use it for an unrelated purpose, we will notify you and explain the lawful basis.
4. Cookies and similar technologies
Our Website uses a small number of essential cookies, plus Google Analytics cookies that are only set with your consent. Our Umami analytics is cookieless and does not require consent. You can change or withdraw your consent at any time. For full details and controls, please see our Cookie Policy.
5. Marketing communications
Where we send you marketing communications, we do so in accordance with applicable law. In practice this means:
- Where required (including electronic marketing to individuals), we rely on your consent, which you can withdraw at any time.
- Where permitted, we may contact business contacts about services similar to those you have enquired about or received (the “soft opt-in”), always giving you a simple way to opt out.
- Every marketing email contains an unsubscribe link, and you can opt out at any time by contacting us (Section 14). We honour opt-out requests promptly and keep a suppression record so we do not contact you again.
6. How we share your personal information
We do not sell your personal information. We may share your personal information with:
- Service providers and processors – including website hosting, IT, email and CRM providers, who process personal information on our behalf under written contracts and only on our instructions.
- Analytics providers – Google (Google Analytics), where you have consented to analytics cookies. Google acts as our service provider/processor for this purpose.
- Professional advisers and authorities – lawyers, accountants, auditors, insurers, and regulators or law enforcement where required by law.
- Business transfers – a buyer or successor in the event of a merger, acquisition, financing or sale of assets, subject to appropriate confidentiality protections.
- Group companies – our subsidiaries and affiliates, where they have a genuine need to access the information and subject to appropriate safeguards.
7. International data transfers
We operate in the UK, Europe and the United States, and some of our service providers (including Google Analytics) are based in or transfer data to the United States. This means your personal information may be transferred to, stored in, or accessed from countries whose data protection laws differ from those where you live.
Where we transfer personal information out of the UK or the EEA to a country that is not covered by an “adequacy” decision, we put in place an appropriate safeguard, which will usually be one of the following:
- the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses, for transfers from the UK;
- the EU Standard Contractual Clauses, for transfers from the EEA;
- reliance on the EU-US Data Privacy Framework and the UK Extension (“UK-US Data Bridge”) where the recipient is certified; or
- your explicit consent or another lawful transfer mechanism permitted under applicable law.
You can ask us for a copy of the relevant safeguards by contacting us at privacy@jettypartners.com.
8. How long we keep your personal information
We keep personal information only for as long as necessary for the purposes for which we collected it, including to satisfy legal, accounting, tax or reporting requirements, and to establish or defend legal claims. Where information falls into more than one category, the longest applicable period applies.
| Type of information | Typical retention period |
|---|---|
| Website enquiry / marketing database records (leads, contact data) | 2 years from your last contact with us |
| Customer relationship records (queries, account history, correspondence) | 6 years from your last contact with us |
| Contracts and related documents | Contract period plus 6 years (12 years if executed as a deed) |
| Evidence of your consent (including cookie and marketing consent) | While consent is valid, and 6 years after it is withdrawn or lapses |
| Opt-out / suppression records | Retained indefinitely so we can honour your opt-out |
| Website analytics data and reports | 2 years (Google Analytics); Umami retained as aggregated statistics |
| Data subject rights requests and privacy complaints | 6 years from closure of the request |
When we no longer need your personal information, we securely delete or anonymise it.
9. How we keep your personal information secure
We use appropriate technical and organisational measures to protect your personal information against accidental or unlawful loss, access, disclosure, alteration or destruction. These measures include access controls, encryption in transit where appropriate, secure hosting, and limiting access to those who need it. We also require our service providers to maintain appropriate security. No transmission over the internet can be guaranteed to be completely secure, so while we protect your information we cannot guarantee absolute security.
10. Your privacy rights and choices
10.1 Your rights under UK and EU data protection law
If you are in the UK or the EEA, you have the following rights in relation to your personal information:
- Access – to be told whether we process your data and to receive a copy of it.
- Rectification – to have inaccurate or incomplete data corrected.
- Erasure – to have your data deleted in certain circumstances (the “right to be forgotten”).
- Restriction – to ask us to limit how we use your data in certain circumstances.
- Objection – to object to processing based on legitimate interests, and to object to direct marketing at any time.
- Portability – to receive certain data in a structured, commonly used, machine-readable format.
- Withdraw consent – to withdraw your consent at any time where we rely on it (this does not affect processing carried out before withdrawal).
- Automated decisions – not to be subject to a decision based solely on automated processing that produces legal or similarly significant effects. We do not make such decisions through our Website.
10.2 How to exercise your rights and complain
To exercise any of these rights, contact us at privacy@jettypartners.com. We will respond within the time limits required by law (usually one month under UK/EU law). It normally costs nothing to make a request. We may need to verify your identity before acting on a request.
If you are in the UK and are unhappy with how we have handled your personal information, you can complain to the Information Commissioner’s Office (ICO) at ico.org.uk/make-a-complaint. If you are in the EEA, you can complain to your local supervisory authority. We would appreciate the chance to address your concerns first.
10.3 Your rights under US state privacy laws
Depending on the US state you live in (for example California, Colorado, Connecticut, Virginia, Texas, Oregon and others), you may have some or all of the following rights: to know and access the personal information we hold about you; to correct inaccurate information; to delete your information; to opt out of “sale”, “sharing” or targeted advertising; to opt out of certain profiling; and to not receive discriminatory treatment for exercising your rights. To exercise any of these rights, contact us using the details in Section 14. You may also appeal a decision we make about your request by contacting us.
10.4 Your California privacy rights (CCPA/CPRA)
If you are a California resident, you have the following rights, subject to certain exceptions: the right to know/access, to delete, to correct, to opt out of the sale or sharing of your personal information, to limit the use of sensitive personal information, and to non-discrimination for exercising your rights.
Do we “sell” or “share” personal information? No. We do not sell your personal information for money, and we do not share it for cross-context behavioural advertising. We use analytics cookies (Google Analytics) that we configure to act as a service provider on our behalf.
Your choices. You can still opt out of analytics cookies at any time using our cookie banner or the “Cookie Settings” link, and by contacting us at privacy@jettypartners.com.
Opt-out preference signals (Global Privacy Control). We recognise and honour opt-out preference signals, including the Global Privacy Control (GPC). If you visit our Website with GPC enabled in your browser, we treat it as a valid opt-out for that browser or device and will not set analytics cookies.
Authorised agents and verification. You may use an authorised agent to submit a request; we may require proof of authorisation and may ask you to verify your identity directly. We will take steps to verify your identity before responding to a request to know, delete or correct.
11. Children’s privacy
Our Website and services are directed to businesses and adults, not to children. We do not knowingly collect personal information from children under 16 (or the age defined by applicable local law). If you believe a child has provided us with personal information, please contact us and we will take steps to delete it.
12. Third-party websites
Our Website may contain links to third-party websites and services. We do not control these sites and are not responsible for their privacy practices. We encourage you to read the privacy policy of every website you visit.
13. Changes to this policy
We keep this policy under regular review and may update it from time to time. When we make material changes, we will update the “Last updated” date above and, where appropriate, notify you. Please check this page periodically for the latest version.
14. How to contact us
If you have any questions about this policy or how we handle your personal information, or if you wish to exercise your rights, please contact us:
- Data controller: Jetty Partners LLC and Jetty Partners UK Ltd
- Privacy contact / Data Protection Officer: privacy@jettypartners.com
- Post: 15 Stratton Street, London W1J 8LQ
- Telephone: +44 20 4654 3000