Privacy Policy

Introduction

Welcome to the John Good Group’s privacy notice. 

John Good Group respects your privacy and is committed to protecting your personal data and the confidentiality of any information we collect about you. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. Additionally, whenever you submit your information to us, whether it be by using our website, by email, over the telephone, in person or by any other means, we will collect and use such information in accordance with the terms of this privacy notice.

Our website is not intended for children and we do not knowingly collect data relating to children.

If we change any of the terms of our Privacy Notice we will post the revised policy on our website at the bottom of each page.

1. Important information and who we are
2. The data we collect about you
3. How is your personal data collected
4. How we use your personal data
5. Disclosures of your personal data
6. International transfers
7. Data Security
8. Data Retention
9. Your legal rights
10. Glossary
11. Our entities

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how John Good Group collects and processes your personal data when you use our services.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

We are committed to ensuring that all personal data we hold is treated properly and in accordance with applicable data protection legislation, which currently in the UK is the Data Protection Act 2028 and the UK GDPR.  In accordance with this data protection legislation, we are required to explain to you how we will treat any personal data which we collect from or about you. We make sure that we comply with Article 5 of the UK GDPR which requires personal data shall be:

“(a) processed lawfully, fairly and in a transparent manner in relation to individuals (‘lawfulness, fairness and transparency’);

(b) collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes (‘purpose limitation’);

(c) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’);

(d) accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (‘accuracy’);

(e) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals (‘storage limitation’);

(f) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’).”  And that “ the data controller shall be responsible for, and be able to demonstrate compliance [“accountability’]

Controller

John Good & Sons Limited is made up of different legal entities. This privacy notice is issued on behalf of the John Good Group so when we mention John Good Group, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the John Good Group responsible for processing your data. John Good & Sons Limited is the controller with Joint Controllers being:

Good Travel Management Ltd
Dan Shipping & Chartering Ltd
Bay Shipping Ltd
Trans-European Port Services (G.B.) Ltd (TEPS)
Arthur Smith (Grimsby) Ltd
Mathew Good Foundation

For more details on these entities please refer to section 11 at the end of this Privacy Notice.
We have appointed a Data Privacy Manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

Company name: John Good & Sons Limited
Address: Quarry House, Hesslewood Country Office Park, Ferriby Road, Hessle, East Yorkshire, HU13 0LH
Email: dataprivacy@johngoodgroup.co.uk
Telephone: 01482 230491

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

a) [“Identity Data”] includes first name, last name, username or similar identifier, marital status, title, date of birth, gender and passport details.
b) [“Contact Data”] includes billing address, delivery address, email address and telephone numbers.
c) [“Financial Data”] includes bank account and payment card details.
d) [“Transaction Data”] includes details about payments to and from you and other details of products and services you have purchased from us.
e) [“Traveller Data”] includes information about your preferences and any assistance required.
f) [“Technical Data’] includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
g) [“Profile Data’] includes your username and password, purchases or orders made by you, feedback and survey responses.
h) [“Usage Data”] includes information about how you use our website, products and services.
i) [“Marketing and Communications Data”] includes your preferences in receiving marketing from us and our third parties and your communication preferences. This is line with PECR, Privacy and Electronic Communication Regulations.

We also collect, use and share [“Aggregated Data”] such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We may collect [“Special Categories of Personal Data”] about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data), if you have provided us with explicit consent in order for us to provide you with our services or if necessary to protect your vital interests. Nor do we collect any information about criminal convictions and offences.

Our business is not intended for children and we do not knowingly collect data relating to children, however we cannot be held responsible if a child interacts with our website and submits their details.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

You have the right to withdraw your consent at any time however in some circumstances the above paragraph may apply.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• apply for our products or services;
• create an account on our website;
• subscribe to our service or publications;
• request marketing to be sent to you;
• come to an event;
• enter a competition, promotion or survey; or
• give us some feedback.

• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Where this happens, we operate within the AI Ethics & Governance frameworks.

• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below :

• Technical Data from the following parties:

• • website analytics providers
  • advertising networks; and
  • search information providers.
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
• Identity and Contact Data from data brokers or aggregators.
• Identity and Contact Data from publicly availably sources.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract, we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
• Where you consent to such use; and
• Where it is necessary to protect your vital interests.

See section 10 to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

We may also disclose your personal data to third parties in the event that we sell or buy any business or assets (in which case we may disclose your personal data to the prospective seller or buyer of such business or assets) or if we, or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers and subscribers will be one of the transferred assets.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. 

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). 

You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the John Good Group of companies for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time or by clicking the unsubscribe link. 

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions. You will continue to receive ‘service and information’ emails informing you of changes to our company, our services and privacy notice. These will not be marketing emails.

Cookies

Our website uses “cookies” to ensure you receive the best possible visitor experience.  Cookies are small files which are sent by a web server to an individual’s computer which are then stored on that computer’s hard drive.  A cookie contains text, and is like an identification card which can only be translated by the server it originated from.

Cookies cannot tell us information such as your email address, which we can only collect where you tell us, for example if you submit an enquiry to us.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. 

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. 

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the lawful basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

We share your personal data within the John Good Group which is based in the UK. On occasion this may involve transferring your data outside the United Kingdom or the European Economic Area (EEA).

We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. These rules are called “IDTA” International Data Transfer Agreement or “BCC” binding corporate rules. For further details, see European Commission: IDTA / Binding corporate rules.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the United Kingdom and or European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• You have explicitly consented to the proposed transfer.
• Where we use certain service providers, we may use specific contracts approved by The Information Commissioner Office which give personal data the same protection it has in Europe.
• Where we use providers based in the US we may transfer data to them if they are part of the “UK/US Data Bridge” which requires them to provide similar protection to personal data shared between the Europe and the US.

Please contact us if you want further information on the specific mechanism we use when transferring your personal data out of the UK / EEA.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see Request erasure below for further information and in most cases we will comply except to comply with the above purpose.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

• Request access to your personal data. (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us

• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact the data privacy manager.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is  manifestly unfounded, excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We will respond to all legitimate requests within 30 days. Occasionally it may take us longer than that timeframe if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated and will comply in a further two months.

10. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

Other companies in the John Good Group acting as joint controllers or processors who provide IT & system administration services.

External Third Parties

• Service providers acting as processors who provide IT and system administration services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
• Travel services and providers who may require details of your travel. These third parties may be based outside of the UK/EEA. These companies will have their own responsibilities to comply with data protection laws.
• Where Good Travel Management relies on third parties to assist with our Data Processing activities, Good Travel Management will select a Data Processor who provides the required security measures and takes reasonable steps to ensure adherence to those measures.
• If you are using Good Travel Management to book employment related travel which is paid for by your employer, we may share information about the travel booked with your employer. They will use this information as a “Data Controller”. This means that how they process your travel data should be set out in their own privacy policy and they will have responsibilities to comply with data protection laws.

11. Our Entities

 John Good & Sons Limited

• Registered Company number: 00096398
• ICO number: ZB631426

Good Travel Management Limited                                            

• Registered Company number: 00994164
• ICO number: ZA413507

Dan Shipping & Chartering Limited                                            

• Registered Company number: 02092360
• ICO number: ZB631433

Bay Shipping Limited                                                                    

• Registered Company number: 02756227
• ICO number: ZB631431

TEPS                                                                                            

• Registered Company number: 00628928
• ICO number: Z6776042

Arthur Smith (Grimsby) Limited          

• Registered Company number: 03112339
• ICO number: ZA828772

Mathew Good Foundation

• Registered Company number: 07682465

Changes to the privacy notice and your duty to inform us of changes.

This version was last updated in April 2024. Historic versions can be obtained by contacting us.

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