JourneyLab Privacy Policy

Last Updated: 02 July 2025

About this Document

This privacy notice (Notice) explains how Agent 3 Limited, Twogether Creative Limited, Publitek Limited and Velocity Partners Ltd trading as Pretzel collect, use and share ("process") your personal data in relation to the use of JourneyLab, our AI powered B2B marketing engine.

This Notice applies alongside any other information that Pretzel may provide about a particular use of personal data. If you are in receipt of any other products or services, then please read the privacy notice that governs that activity in conjunction with this Notice.

If you are an employee of a client organisation and are using JourneyLab as part of your internal solution set, please read this notice in combination with any transparency information provided to you by your employer.

How We Collect Your Information

We collect your personal data in a number of ways, including:

When you register, or are registered by your company for an account with us in order to use JourneyLab.
When you sign in and use JourneyLab within an internet browser.
If you choose to enter any personally identifiable information about yourself or others.
If you upload any documents that contain personal information about yourself or others.
If JourneyLab is granted access to a company knowledge base that may contain personal information about yourself or others.

The Type of Information We Collect

To provide this service to you, Pretzl will process the following categories of personal data:

Account Information: When you create an account with us, we will collect information associated with your account, including your name and email.
User Content: When you use JourneyLab we process the personal information that is included in the input, file uploads or feedback that you provide.
Other Information you provide: We collect other information that you may provide to us, such as when you participate in any surveys or when providing feedback on JourneyLab so that we may improve it for your use.
Log Data: Information that your browser or device automatically sends when you use JourneyLab. Log data includes your Internet Protocol address, browser type and settings, the date and time of your request, and how you interact with JourneyLab.
Usage Data: We may automatically collect information about your use of JourneyLab, such as the types of content that you view or engage with, the features you use and the actions you take, as well as your time zone, country, the dates and times of access, user agent and version, type of computer or mobile device, and your computer connection.
Device Information: Includes name of the device, operating system, device identifiers, and browser you are using. Information collected may depend on the type of device you use and its settings.
Personal information in the public domain: When we refer to "information in the public domain", we are talking about websites that can be accessed without any special login or subscription or sites that require free login. We collect this, as some search results carried out via our third party knowledgebase may include your personal information. For example, your personal information may have been included in a news article, or your social media post may have included a key word which is picked up by the searches on the online platform.

How We Use Your Personal Data

Subject to applicable law, your personal data may be processed by us for the following purposes:

To provide, administer and maintain the services as set out within our contract, including support.
To provide services to our clients.
To store session data and allow users to save and return to conversations in future.
To improve the functionality of JourneyLab and conduct research.
To prevent fraud, criminal activity, or misuse of JourneyLab, and to protect the security of our IT systems, architecture, and networks, and
To comply with legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties.

We may aggregate or de-identify Personal Information so that it may no longer be used to identify you and use such information to analyse the effectiveness of JourneyLab, to improve and add features, to conduct research for other similar purposes. In addition, from time to time, we may analyse the general behaviour and characteristics of users and analyse aggregated information like general user statistics. We may collect aggregated information through JourneyLab, through cookies, and through other means described in this Privacy Notice. We will maintain and use de-identified information in anonymous or de-identified form and we will not attempt to reidentify the information unless required by law.

Legal Basis for Processing Your Data

Every time we process personal data, we must have a legal basis upon which to rely.

We will only collect, use and share your personal information where we are satisfied that one or more of the following legal bases apply:

Contract

Where the processing of data is necessary in order to fulfil our obligations to you under the contract for you to use JourneyLab.

Legitimate Interest

The processing is necessary for the legitimate interests pursued by Pretzl or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require the protection of personal information. When we use legitimate interest as our legal basis for processing your information, we conduct an assessment in order to risk assess our activities. Our legitimate interests include our interests in running Pretzl in a professional, sustainable manner, in accordance with all relevant legal and regulatory requirements and in line with industry best practice.

Consent

If you enter personal information into JourneyLab you are giving Pretzl your consent to process that information. If you are entering information of a third party, you must obtain their consent before entering such information into JourneyLab.

Data Sharing and Third-Party Websites

For the purposes set out in this notice, we will not share your personal information with any person or entity other than Pretzl. The only exception to this is when your data is transferred to Amazon Web Services (our hosting provider), or to a technology service provider in order to enable JourneyLab to function. In particular, we may use SSO portal, such as Auth0 or Okta in order to provide you with secure access to your account. The usage of these tools to contain your information will be covered by their respective privacy policies. For further information in relation to how they process your personal data please see their Privacy Notices.

Automated Decision-Making and Profiling

Your data will not be subject to any automated decision-making or profiling beyond the activities that are set out within this notice. For the avoidance of doubt, we do not carry out in-application tracking.

International Data Transfers

As set about above, we may share your personal data within our Group. This may involve transferring your data outside of the UK and the European Economic Area (EEA). We have therefore entered into a specific intra-group contract utilising the International Data Transfer Addendum to the European Commission's Standard Contractual clauses for International data transfers.

Although we attempt to process data in country some of our external third-party service providers and some of our customers may be based outside the UK or EEA.

Whenever we transfer your personal data out of the UK or the EEA to these third parties, 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 European Commission or the UK Government.
Where we use certain service providers, we may use specific contracts approved by the European Commission or the Security of State for the United Kingdom as affected by the Information Commissioners Office which give personal data the same protection it has in Europe and the UK

Please contact the Data Protection and Privacy Office if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or the EEA.

Data Retention

We will retain your Personal Data for as long as is reasonably necessary for the purposes explained in this Notice. In some circumstances, we may retain your Personal Data for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax or accounting requirements or so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your relationship with us. Where your Personal Data is no longer required, we will ensure it is either securely deleted or stored in a way that no longer identifies you.

If you would like further details regarding our records retention, please contact the Data Protection and Privacy Office set out below.

Pretzl and CCPA/CPRA Compliance

The California Consumer Privacy Act (CCPA) as amended by the California Consumer Privacy Act of (CPRA) gives consumers more control over the personal information that businesses collect about them. The following table provides additional information about the categories of Personal Information we collect and how we disclose that information.

Category of Personal Information	Disclosure of Personal Information	Sold or Shared
Identifiers, such as your session ID/User ID, IP address, and other device identifiers	We may disclose this information to our affiliates, vendors and service providers to process in accordance with our instructions; to law enforcement and other third parties for the legal reasons described above; to parties involved in Transactions; to corporate administrators of enterprise or team accounts; and to other users and third parties you choose to share it with.	We will not sell or share your data.
Commercial Information, such as your transaction history	We may disclose this information to our affiliates, vendors and service providers to process in accordance with our instructions; to law enforcement and other third parties for the legal reasons described above; to parties involved in Transactions; and to corporate administrators of enterprise or team accounts.	We will not sell or share your data.
Network Activity Information, such as Content and how you interact with our Services	We may disclose this information to our affiliates, vendors and service providers to process in accordance with our instructions; to law enforcement and other third parties for the legal reasons described above; to parties involved in Transactions; and to other users and third parties you choose to share it with.	We will not sell or share your data.
Your account login credentials and payment card information (Sensitive Personal Information)	We disclose this information to our affiliates, vendors and service providers, law enforcement, and parties involved in Transactions.	We will not sell or share your data.
Publicly available personal information	We may disclose this information to our customers as part of our services.	We will sell or share your data.

Your Rights

To the extent provided by applicable local data protection legislation, you have the following rights:

to obtain access to, and copies of, the personal data we hold about you;
to require that we cease processing your personal data if the processing is causing you damage or distress;
to require us not to send you marketing communications;
to request that we erase your personal data;
to request that we restrict our data processing activities in relation to your personal data;
to receive from us the personal data we hold about you, which you have provided to us, in a reasonable format specified by you, including for the purpose of transmitting that personal data to another data controller; and
to require us to correct the personal data we hold about you if it is incorrect.
if you are a California resident, you have the right to opt-out of the sale or sharing of your personal information. To do so, please contact us using the details below.

Please note that the above rights are not absolute, and requests may be refused where exceptions apply.

If you have any questions about these rights or how your personal data is used by us, you should contact the Data Protection and Privacy Office, whose details are set out below.

Contact and Complaints

We recommend that you seek to resolve any issues with us before any referral is made to the relevant regulatory authority. If you have any queries about this privacy notice or how we process your personal data, or if you wish to exercise any of your rights, please contact:

Data Protection and Privacy Office
60 Great Portland Street
London
W1W 7RT

dpo-hub@next15.com

If following such referral, you are still not satisfied with how your personal data is used by Pretzl you can make a complaint to the data protection authority that governs your jurisdiction.

Changes To This Notice

Pretzl will update this Privacy Notice from time to time. Any substantial changes that affect your rights will be provided to you directly as far as is reasonably practicable.