Privacy Policy

 

 

Privacy Policy

Last updated: 14 July 2026

This Privacy Policy explains how JTC France SAS, trading as Journey Through Culture (“JTC France,” “Journey Through Culture,” “we,” “us,” or “our”) collects, uses, stores and protects personal data.

It applies to visitors to our website, prospective and current customers, students, parents or legal guardians, educational partners, service providers, job applicants and other individuals who communicate or work with us.

We process personal data in accordance with Regulation (EU) 2016/679, the General Data Protection Regulation (“GDPR”), the French Data Protection Act and other applicable data-protection laws.

1. Data Controller

The data controller responsible for the processing of personal data is:

JTC France SAS
Trading as Journey Through Culture

SIREN: 943 466 805
Registered office: 11 Boulevard Étienne Astegiano, B135, 06150 Cannes, France
Email: contact@journeythroughculture.com
Telephone: +33 6 42 97 94 84
Website: journeythroughculture.com

For any question concerning this Privacy Policy or the processing of your personal data, please contact us using the details above.

JTC France has not appointed a Data Protection Officer. Privacy-related requests may be sent directly to the email address stated above.

2. Personal Data We May Collect

Depending on your relationship with us and the services requested, we may collect the following categories of personal data:

  • identity information, including name, surname, title, date of birth, age, gender and nationality;
  • contact information, including postal address, email address and telephone number;
  • identification and travel information, including passport details, identity documents, visa information, residence status, travel details and emergency-contact information;
  • educational information, including school attended, academic records, qualifications, language level, interests, course preferences and educational objectives;
  • application information, including application forms, personal statements, photographs, supporting documents and correspondence;
  • information relating to parents, guardians, sponsors or representatives;
  • information necessary to assess accommodation, accessibility, dietary or other individual requirements;
  • health or medical information where strictly necessary for participation, safety, insurance, accommodation or emergency support;
  • financial and transactional information, including invoices, payments, refunds and banking information;
  • communications exchanged with us by email, telephone, messaging applications, website forms or social media;
  • marketing preferences and records of consent;
  • website and technical information, including IP address, browser type, device information, pages visited, cookie identifiers and approximate location derived from technical data;
  • recruitment information, including CVs, qualifications, employment history, references and right-to-work information.

We seek to collect only the personal data reasonably necessary for the relevant purpose.

3. How We Collect Personal Data

We may collect personal data:

  • directly from you;
  • from a parent, guardian, sponsor or authorized representative;
  • through our website or contact forms;
  • through email, telephone, WhatsApp or other communication channels;
  • during consultations, applications, bookings and enrolment procedures;
  • from educational institutions, accommodation providers, insurers, visa-support providers and other partners involved in a requested service;
  • from publicly available professional sources where appropriate;
  • automatically through cookies and similar technologies when you use our website.

Where another person provides personal data about you, that person should ensure that they are authorized to do so and that you have been informed about the disclosure.

4. Why We Process Personal Data

We may process personal data for the following purposes:

4.1 Responding to enquiries

We use contact and enquiry information to respond to questions, recommend programs, arrange consultations and provide quotations.

The legal basis is taking steps at your request before entering into a contract and, where applicable, our legitimate interest in responding to business enquiries.

4.2 Providing educational and related services

We process personal data to:

  • identify suitable educational programs;
  • prepare and submit applications;
  • communicate with schools and educational institutions;
  • arrange enrolment, accommodation, transportation, insurance or related services;
  • support visa and immigration-related administrative processes;
  • coordinate travel or arrival information;
  • monitor the progress of an application or placement;
  • provide customer support before, during and after a program.

The legal basis is the performance of a contract or taking steps before entering into a contract.

4.3 Processing student applications

We may transmit relevant application information to schools, universities, language centres, exchange-program organizations, accommodation providers and other institutions selected by or for the applicant.

The legal basis is the performance of a contract or taking steps at the applicant’s request before entering into a contract.

4.4 Processing information about minors

Some of our services are intended for children or young people under the age of 18.

Where appropriate, we collect and process their personal data through or with the involvement of a parent or legal guardian. We may require parental or guardian authorization before processing an application, arranging travel, publishing photographs or providing certain services.

We take particular care to limit the collection and disclosure of minors’ personal data to what is necessary for their education, safety and participation.

4.5 Health and special-category data

In limited circumstances, we may need information concerning health, disability, allergies, dietary requirements or other special needs.

We process this information only when necessary and where an appropriate legal basis applies, such as explicit consent, protection of vital interests or another basis permitted by law.

Such information may be shared with relevant schools, accommodation providers, insurers, emergency services or program partners where necessary to protect the individual or provide the requested service.

4.6 Payments, invoicing and accounting

We process billing, payment and transaction information to issue invoices, receive payments, make refunds, maintain accounting records and comply with tax and financial obligations.

The legal bases are performance of a contract and compliance with legal obligations.

4.7 Legal and regulatory compliance

We may process personal data to:

  • comply with accounting, tax and corporate obligations;
  • respond to lawful requests from public authorities;
  • prevent fraud or misuse;
  • establish, exercise or defend legal claims;
  • maintain appropriate records of our activities.

The legal bases are compliance with legal obligations and our legitimate interests in protecting our rights and business.

4.8 Marketing communications

We may send information about programs, events, services and opportunities where:

  • you have given consent;
  • the communication is otherwise permitted by law; or
  • it relates to services similar to those previously requested, where applicable.

You may unsubscribe at any time by using the unsubscribe option in the communication or by contacting us.

Consent must be freely given, specific, informed and unambiguous, and may be withdrawn at any time.

4.9 Website operation and analytics

We may process technical and usage information to:

  • operate and secure the website;
  • prevent abuse and unauthorized access;
  • understand how visitors use the website;
  • measure website performance;
  • improve content and user experience.

The legal basis may be our legitimate interest for strictly necessary functions or your consent where cookies or similar tracking technologies require it.

5. Whether You Must Provide Personal Data

You provide personal data voluntarily. However, certain information is necessary for us to:

  • respond to an enquiry;
  • prepare a quotation;
  • submit an application;
  • arrange enrolment or accommodation;
  • provide visa-related administrative assistance;
  • process a booking or payment;
  • comply with legal obligations.

Where required information is not provided, we may be unable to provide the requested service or complete an application.

We will indicate where information is mandatory whenever reasonably possible.

6. Recipients of Personal Data

Personal data may be accessed or received by:

  • authorized personnel of JTC France;
  • schools, universities, colleges, language centres and educational institutions;
  • exchange-program organizations;
  • accommodation providers and host-family organizations;
  • visa-support and immigration-administration partners;
  • transport, travel and transfer providers where relevant;
  • insurers and assistance providers;
  • payment processors, banks and accounting professionals;
  • website hosting, email, cloud-storage, customer-management and IT service providers;
  • legal, accounting and professional advisers;
  • public authorities, courts, regulators or law-enforcement bodies where disclosure is legally required.

We disclose only the information reasonably necessary for the relevant service or legal purpose.

Our service providers are expected to process personal data only in accordance with our instructions, their contractual obligations and applicable data-protection law.

7. International Transfers

Because JTC France arranges international education programs, personal data may be transferred to educational institutions and service providers located outside France or the European Economic Area, including, depending on the selected program, the United Kingdom, the United States, Canada, Japan and other countries.

Some countries have been recognized by the European Commission as providing an adequate level of protection. Where no adequacy decision applies, we seek to use an appropriate safeguard permitted under the GDPR, such as:

  • European Commission Standard Contractual Clauses;
  • contractual and organizational safeguards;
  • a legally permitted derogation where the transfer is necessary for the performance of a contract requested by the individual;
  • explicit consent where appropriate and legally valid.

Transfers outside the EU or EEA must be subject to an appropriate level of protection under the GDPR.

You may contact us for further information about the safeguards applicable to a particular transfer.

8. Data Retention

We retain personal data only for as long as necessary for the purpose for which it was collected and to satisfy legal, accounting, contractual or evidential requirements.

Indicative retention periods include:

  • general enquiries that do not lead to a contract: up to three years from the last meaningful contact;
  • prospective-customer and marketing information: up to three years from collection or the last contact initiated by the prospect, unless consent is renewed or withdrawn earlier;
  • customer and student files: for the duration of the relationship and generally up to five years afterwards where necessary for contractual, legal or claims-related purposes;
  • application documents: for the duration of the application and program, followed by a limited archival period where required;
  • contracts, invoices and accounting records: generally ten years where required by French accounting law;
  • payment information: only for the period necessary to process the transaction and satisfy legal or dispute-related obligations;
  • unsuccessful job applications: generally up to two years after the last contact, unless the applicant requests earlier deletion;
  • cookie and consent records: for the duration specified in our cookie settings and applicable legal guidance;
  • legal claims and disputes: for the applicable statutory limitation period.

Personal data must not be retained indefinitely, and organizations should define retention periods based on purpose and legal requirements. CNIL guidance commonly uses three years for prospecting data and ten years for records required for accounting purposes.

At the end of the applicable period, data will be deleted, anonymized or securely archived where continued retention is legally required.

9. Cookies and Similar Technologies

Our website may use cookies and similar technologies.

Strictly necessary cookies

These cookies are required for the website to operate, provide security, remember essential settings or enable functions specifically requested by the user. They may generally be used without consent where legally exempt.

Optional cookies

Optional cookies may be used for:

  • audience measurement and analytics;
  • embedded videos or external content;
  • social-media features;
  • advertising or marketing;
  • personalization.

Where consent is required, optional cookies must not be placed before the visitor has made a choice.

Visitors must be able to accept or reject optional cookies with comparable ease and must be able to change or withdraw their choice later. French rules require prior consent for many non-essential cookies and trackers.

The precise cookies used by the website should be listed in the website’s cookie banner or cookie settings panel.

10. Photographs, Videos and Testimonials

We may use photographs, videos, testimonials or other content featuring students, customers, partners or event participants only where we have an appropriate legal basis.

For identifiable individuals, particularly minors, we may request specific permission or a written image-release authorization before using such material for:

  • the website;
  • social media;
  • advertising;
  • brochures;
  • presentations;
  • other promotional communications.

Where consent is the legal basis, it may be withdrawn for future use. Withdrawal does not affect processing that was lawful before withdrawal.

We will not intentionally publish sensitive personal information together with an identifiable photograph unless necessary and appropriately authorized.

11. Security

We use reasonable technical and organizational measures designed to protect personal data against:

  • unauthorized access;
  • accidental loss;
  • misuse;
  • alteration;
  • unlawful disclosure;
  • destruction.

Measures may include restricted access, password protection, secure systems, appropriate contractual safeguards, backups and staff confidentiality obligations.

No method of transmission or storage is completely secure. However, we regularly seek to adapt our safeguards to the nature of the data and the risks involved.

12. Your Data-Protection Rights

Subject to the conditions and limitations established by law, you may have the following rights:

Right of access

You may request confirmation as to whether we process your personal data and obtain a copy of that data.

Right to rectification

You may request correction of inaccurate or incomplete personal data.

Right to erasure

You may request deletion of personal data where, for example:

  • it is no longer necessary for the original purpose;
  • consent has been withdrawn and no other legal basis applies;
  • the processing is unlawful;
  • deletion is required by law.

The right to erasure does not apply where continued retention is necessary to comply with a legal obligation or establish, exercise or defend legal claims.

Right to restriction

You may request that processing be temporarily restricted in certain circumstances, including while the accuracy of data or an objection is being considered.

Right to object

You may object to processing based on our legitimate interests for reasons relating to your particular situation.

You may object at any time to the use of your personal data for direct marketing.

Right to data portability

Where processing is based on consent or a contract and carried out by automated means, you may request personal data you provided in a structured, commonly used and machine-readable format.

Right to withdraw consent

Where processing is based on consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

Rights concerning automated decisions

You have the right not to be subject to a decision based solely on automated processing that produces legal or similarly significant effects, subject to the exceptions provided by law.

JTC France does not currently intend to make significant decisions about applicants or customers based solely on automated processing.

Instructions after death

Where permitted under French law, you may provide instructions concerning the retention, deletion or communication of your personal data after your death.

CNIL confirms that individuals have rights to information, access, rectification, erasure, restriction, objection and, where applicable, portability.

13. Exercising Your Rights

To exercise a data-protection right, contact:

Email: contact@journeythroughculture.com

Postal address:
JTC France SAS
11 Boulevard Étienne Astegiano, B135
06150 Cannes, France

Please state clearly which right you wish to exercise and provide enough information for us to identify the relevant records.

We may request reasonable evidence of identity where necessary to prevent unauthorized disclosure. We will not request more information than is reasonably required to verify identity.

We will respond within the period required by applicable law, normally within one month. This period may be extended where a request is particularly complex or numerous, in which case we will inform you.

Rights are not absolute. In certain circumstances, we may lawfully refuse or limit a request, but we will explain the reason where required.

14. Complaints

Please contact us first if you have a concern about how your personal data has been handled. We will use the information provided in the complaint only to investigate, respond and improve our procedures.

You also have the right to lodge a complaint with the French data-protection authority:

Commission Nationale de l’Informatique et des Libertés — CNIL
3 Place de Fontenoy
TSA 80715
75334 Paris Cedex 07
France

You may also complain to the competent supervisory authority in the EU or EEA country where you normally reside, work or believe an infringement occurred.

15. Third-Party Websites

Our website may contain links to educational institutions, partners, social-media platforms or other third-party websites.

We are not responsible for the privacy practices or content of those third parties. You should review their privacy information before submitting personal data through their websites.

16. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in:

  • our services;
  • our partners;
  • the technologies used on our website;
  • legal or regulatory requirements;
  • our data-processing practices.

The latest version will be published on this page with the date of the most recent update.

Material changes may also be communicated by another appropriate method where required.