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Privacy Policy

This Privacy Policy explains how COVENANT ADVISORY CIC (“we,” “us,” or “our”), the company that owns and operates DiscoverTMJ.com, TheMannaJourney.com, and the TMJ mobile application (together, the “Service”), collects, uses, shares, and protects your personal information. DiscoverTMJ.com is also known as The Manna Journey.

By accessing or using the Service, you agree to this Privacy Policy and our Terms of Use. If you do not agree, please do not use the Service.

 

1. Who We Are

COVENANT ADVISORY CIC
20 Broadfields Avenue
Edgware, HA8 8PG
United Kingdom
D-U-N-S® Number: 225846532
Email: support@themannajourney.com

We are the data controller of your personal data and are responsible for how it is processed under the UK General Data Protection Regulation (UK GDPR) and other applicable laws.

 

2. Purpose of this Privacy Policy

This Policy provides transparency on how we collect, use, and protect your personal data, and outlines your rights and how to exercise them.

This Policy applies to:

  • Visitors to our websites and apps
     

  • Clients, subscribers, and service users
     

  • Suppliers and operational partners
     

It supplements other notices and is not intended to override them.

 

3. What Personal Data We Collect

“Personal data” means information that can identify you. We may collect, use, store, and transfer the following types:

a. Identity Data – Name, title
b. Contact Data – Email, phone number, address
c. Preferences – Language, content preferences, time zone
d. Communications – Feedback, survey responses, support messages
e. Third-Party Information – Social media profile data (if linked)
f. Location Data – Device/browser-based geolocation
g. Transaction Data – Purchases, payment details, order history
h. Technical Data – IP address, browser, OS, device type
i. Profile & Usage Data – Logins, viewed content, interactions
j. Marketing & Communications Data – Preferences for updates
k. Aggregated Data – Non-personal statistics and trends

We do not collect special category data (e.g., health, ethnicity, political beliefs) or criminal offence data.

 

4. How We Collect Data

  • Directly from you: Forms, feedback, subscriptions, purchases
     

  • Automatically: Cookies, analytics, system logs
     

  • From third parties: Analytics tools, advertising partners, payment providers
     

 

5. Google Click Identifier (GCLID)

We use GCLID to track conversions from Google Ads.

  • GCLIDs are stored for 90 days
     

  • They are not shared with third parties for marketing
     

  • GCLIDs do not directly identify you
     

 

6. Cookies and Similar Technologies

We use cookies to:

  • Ensure site functionality
     

  • Analyse usage patterns
     

  • Improve marketing performance
     

You can manage cookie preferences in your browser. See our Cookies Policy for details.

 

7. Legal Basis for Processing (UK GDPR)

We rely on the following lawful bases:

  • Consent – For tracking and marketing activities
     

  • Contract – To provide services you request
     

  • Legitimate interest – For security, analytics, and service improvement
     

  • Legal obligation – To comply with law
     

 

8. How We Use Your Data

We use your personal data to:

  • Provide and operate the Service
     

  • Improve functionality and content relevance
     

  • Process payments and deliver services
     

  • Respond to enquiries and support requests
     

  • Send updates, legal notices, and marketing (where permitted)
     

  • Comply with legal obligations
     

We do not sell your personal data. We may use it for internal analytics and service personalisation, with your consent if required.

 

9. Marketing Preferences

You may receive marketing communications if:

  • You opted in; or
     

  • You used our services and have not opted out
     

You may opt out at any time by emailing support@themannajourney.com or following unsubscribe links.

We do not share your data with third parties for marketing unless we have your explicit consent.

 

10. Data Sharing

We may share your personal data with:

a. Internal Third Parties

  • Business units and departments for service delivery
     

b. External Third Parties

  • IT and hosting providers (e.g., WPEngine, Mailchimp)
     

  • Analytics tools (e.g., Google Analytics, Hotjar, Woopra)
     

  • Advertising platforms (e.g., Facebook Ads, Google Ads, where consented)
     

  • Regulators (e.g., HMRC, ICO) where legally required
     

  • Professional advisors (e.g., accountants, lawyers)
     

All external parties must adhere to strict confidentiality and data protection agreements.

 

11. International Transfers

Some third-party tools (e.g., Google, Facebook, Mailchimp) are based outside the UK/EEA. We ensure lawful data transfers by:

  • Using countries with UK adequacy decisions
     

  • Implementing Standard Contractual Clauses (SCCs)
     

  • Requiring contractual safeguards
     

Contact us for more on our data transfer arrangements.

 

12. Data Security

We use technical and organisational safeguards, including:

  • Encryption and secure storage
     

  • Role-based access controls
     

  • Monitoring, audits, and incident response plans
     

  • Anonymisation or pseudonymisation where possible
     

 

13. Data Retention

We retain personal data only as long as necessary for:

  • Service delivery and contractual obligations
     

  • Legal and tax compliance (typically 7 years)
     

  • Analytical and development purposes (anonymised if possible)
     

Inactive user accounts may be deleted after 24 months. You may request deletion earlier.

 

14. Your Legal Rights

Under the UK GDPR, you have the right to:

  • Access your data
     

  • Correct inaccurate data
     

  • Request deletion
     

  • Object to processing (e.g. for marketing)
     

  • Restrict data use in specific cases
     

  • Request data portability
     

  • Withdraw consent at any time
     

To exercise your rights, email support@themannajourney.com. We may need to verify your identity.

 

15. Fees and Response Time

We do not charge for data requests unless they are manifestly unfounded or excessive. We aim to respond within one month. Complex cases may take longer; we will notify you if so.

 

16. Children’s Privacy

Our Service is not intended for users under 18. Children must only use the Service under parental or guardian supervision.

 

17. Changes to This Policy

We may update this Privacy Policy periodically. Material changes will be communicated via email or site notice.

Check this page regularly for the latest version.

 

18. Contact Us

To ask questions or exercise your rights, contact:

COVENANT ADVISORY CIC
20 Broadfields Avenue
Edgware, HA8 8PG
United Kingdom
Email: support@themannajourney.com
D-U-N-S® Number: 225846532

 

19. Complaints

You have the right to file a complaint with the Information Commissioner’s Office (ICO): www.ico.org.uk.
We encourage you to contact us first so we can try to resolve any issue directly.

 

20. Glossary

  • Data Controller – Entity that determines how personal data is processed
     

  • Data Processor – Third party that processes data on behalf of the controller
     

  • EEA – European Economic Area
     

  • GCLID – Google Click Identifier used in ad tracking
     

  • UK GDPR – UK’s version of the General Data Protection Regulation
     

 Last updated: 20 May 2025

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