The JLT Group Privacy Policy

Last Updated: 15 December 2025

1. Introduction

This Privacy Policy explains how The JLT Group (“we”, “us”, or “our”) collects, uses, and protects your personal data. We are committed to protecting your privacy and complying with our obligations under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

This policy applies to: - Travel Agent Partners (“Agents”) who join our host agency. - Clients of our Agents for whom travel services are booked. - Visitors to our websites, including janinelovestravel.co.uk, hub.thejltgroup.co.uk, thejltgroup.co.uk, and go.thejltgroup.co.uk.

2. Who We Are and How to Contact Us

Data Controller: The JLT Group is the data controller for the personal data we process.

•          Company Name: The JLT Group

•          Registered Office: 20-22 Wenlock Road, London, UK

•          Company Number: 12178075

Contact for Data Protection Enquiries: For any questions about this privacy policy or our data protection practices, please contact us at: - Email: support@thejltgroup.co.uk

We do not have a statutory Data Protection Officer (DPO), but our team is trained to handle all data protection enquiries.

3. What Personal Data We Collect

We collect different types of personal data depending on your relationship with us.

•          Contact Data: Email address, phone number.

•          Financial Data: Bank account details for commission payments.

•          Profile Data: Information provided on your learning platform profile (LearnWorlds).

•          Technical Data: IP address, login data.

•          Usage Data: Information about how you use our systems and services. | | Clients | - Identity Data: Full name, address, date of birth, passport details.

•          Contact Data: Email address, phone number, emergency contact details.

•          Financial Data: Payment details are processed by Stripe; we do not store full card numbers.

•          Special Category Data: Health information, dietary requirements, or other sensitive data necessary for your booking.

•          Booking Data: Travel dates, destinations, preferences, and booking history. | | Website Visitors | - Contact Data: Name and email address from contact forms.

•          Technical Data: IP address, browser type, operating system.

•          Usage Data: Information about how you use our websites, collected via cookies and Google Analytics. |

Recorded Meetings: We record virtual meetings (e.g., on Zoom, Google Meet, Teams) for training and marketing purposes. We will always inform you at the start of a meeting if it is being recorded and obtain your consent.

Future CCTV: We do not currently operate CCTV. When we open physical premises, we will install CCTV for security purposes. Signage will be displayed, and this policy will be updated with full details.

4. How We Use Your Personal Data and Our Lawful Basis

We only use your personal data when the law allows us to. Our lawful bases for processing are Contract, Legal Obligation, Consent, and Legitimate Interests.

5. Who We Share Your Personal Data With

We do not sell your personal data. We only share it with trusted third parties who are essential for providing our services.

•          Travel Suppliers: Airlines, hotels, tour operators, and other suppliers to fulfil your bookings.

•          Payment Processors: Stripe processes all payments. We do not store your full payment card details.

•          Marketing & CRM Platforms: GoHighLevel and Mailerlite for sending marketing emails and managing client relationships.

•          Training Platform: LearnWorlds hosts our agent training and profiles.

•          Booking System: Topdog Travel Systems is our core booking management platform.

•          Communication Tools: WhatsApp, Zoom, Google Meet, and Microsoft Teams for communication.

•          Cloud & Email Providers: Google Workspace for internal operations and email.

•          Website Hosting: SiteGround and WordPress for our websites.

•          Analytics Providers: Google Analytics to analyse website traffic.

•          Regulatory Bodies: The Civil Aviation Authority (CAA), Information Commissioner’s Office (ICO), and law enforcement where required by law.

6. International Data Transfers

We do not transfer your personal data outside the United Kingdom (UK). All our third-party service providers are either based in the UK or have confirmed they process UK data within the UK.

7. Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for.

•          Booking and Financial Records: We retain all booking and financial data for 6 years after the completion of travel to comply with legal and tax obligations.

•          Agent Data: We retain agent data for 6 years after the termination of their membership.

•          Marketing Consent: We retain your data for marketing purposes for as long as you remain subscribed. You can unsubscribe at any time, and your data will be removed from our marketing lists.

8. Your Data Protection Rights

Under UK GDPR, you have the following rights:

•          Right of Access: You can request a copy of the personal data we hold about you.

•          Right to Rectification: You can ask us to correct any inaccurate or incomplete data.

•          Right to Erasure: You can ask us to delete your personal data where there is no good reason for us to continue processing it.

•          Right to Restrict Processing: You can ask us to suspend the processing of your personal data.

•          Right to Data Portability: You can request the transfer of your personal data to you or to a third party.

•          Right to Object: You can object to our processing of your data where we are relying on legitimate interests.

•          Right to Withdraw Consent: Where we rely on consent, you can withdraw it at any time.

To exercise any of these rights, please contact us at support@thejltgroup.co.uk.

9. Cookies and Tracking Technologies

We use cookies on our websites to improve your experience and analyse traffic. Cookies are small text files placed on your device.

•          Essential Cookies: These are necessary for the website to function and cannot be switched off.

•          Analytics Cookies: We use Google Analytics to collect information about how visitors use our site. This helps us improve our website. These cookies are only used with your consent.

You can manage your cookie preferences at any time through the cookie banner on our websites.

10. Security of Your Data

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way. We limit access to your personal data to those employees, agents, and third parties who have a business need to know.

11. Children’s Data

Our services are not aimed at children, and our agents must be 18 years or older. We do not knowingly collect personal data from children under the age of 16 without parental consent.

In the course of booking travel, we may process data for children (e.g., as part of a family holiday or for an unaccompanied minor). In such cases, we will only process this data with the explicit consent of a parent or guardian.

12. Changes to This Privacy Policy

We may update this privacy policy from time to time. The latest version will always be available on our websites. We will notify you of any significant changes.

13. How to Complain

If you have any concerns about our use of your personal data, you can make a complaint to us at support@thejltgroup.co.uk.

You also have the right to complain to the Information Commissioner’s Office (ICO), the UK’s supervisory authority for data protection issues.

•          ICO Website: www.ico.org.uk

•          ICO Helpline: 0303 123 1113