Jersey Finance Limited (“JFL”)
Registration Number: 78049
Issue Date: 25 May 2018
Version Number: 1.00
Applicable Law: The Data Protection (Jersey) Law 2018 and Regulation (EU) 2016/79 of the European Parliament and of the Council of 27 April 2016, together the General Data Protection Regulation (hereinafter “the GDPR”)
At JFL we regard your privacy as important.
JFL may collect information about you via our website, www.jerseyfinance.je and directly or indirectly by email, phone or other means.
The information we collect about you, if you agree to provide it, will allow us to contact you and send you information about our services.
- In providing us your information you thereby consent to us processing it for this purpose.
- We will not pass your personal information on to any third party without your express permission, except as defined herein for the provision of services that you have requested, other than authorities and the police in the event of any investigation.
- Personal email addresses and phone numbers are not shared with any other user of the site unless you have explicitly chosen to do so.
For the purposes of the GDPR;
- the data controller is Jersey Finance Limited (“JFL”).
- JFL may use third-party processors to deliver specific services that are requested by you from JFL (see Processors below).
Information that we may collect from you
We may collect and/or process the following data about you:
- Information you provide to us – by filling in forms on our website or by entering into a contract with us, or by correspondence with us by email, letter, phone or other methods, which includes data provided by you by registering to use our website, or by subscribing for newsletters or other information services, or by joining our web forum, or by placing a request for services, and when reporting a problem with our site, or otherwise contacting us.
- Personal data – the information you give us may include; your name, address, email address, IP address, and phone number which is subject to the GDPR.
- When do we collect your data: Members?
- register as a Member by completing our ‘create your account’ form;
- update your Member Profile, Settings, Preferences and Registration Details; make bookings, send emails or otherwise communicate with JFL.
- When do we collect your data: Non-Members?
- If you otherwise use the site (as a non-member), we collect data from you:
- when you register as a Guest by completing our create your account form;
- when you update your Profile, Settings, Preferences and Registration Details; make bookings, send emails or otherwise communicate with JFL.
- when you make an enquiry or provide other feedback to us;
- in monitoring your communications sent via the website and/or use of the website to ensure and check compliance with the Terms and Conditions of Use or otherwise as required by law; and
- when you disclose your data to us through the website or otherwise through any other means.
- If you otherwise use the site (as a non-member), we collect data from you:
- Data protection – all Personal data we hold is protected by us in accordance with the Principles of the GDPR.
- Data security – We endeavour to take all reasonable steps to protect your data. All the data collected by us is stored on a secure platform in a secure hosting facility and we take all reasonable steps to ensure all access is pre-authorised and recorded.
- Other information we collect about you – In accordance with our legal obligation to prevent fraudulent or abusive use of our website, some data may be automatically collected and comprises the following:
- Technical information – such as your internet protocol (IP) address, login information, time zone, browser type/version with plug-in types/versions, device information (operating system and platform);
- Information about your visit – such as your Uniform Resource Locators (URL), including the date and time, information viewed/searched, site statistics, interaction (scrolling, clicks, mouse-overs), exit methods away from pages, phone numbers (if used to call our offices), route to/from our site or from search engine links to our site including search engine address and search term used.
- Our website will not store any identifying information of your visit on your computer apart from a small text file called a cookie, which in itself does not contain any identifying information and does not mean that you entered the site. See the cookies policy link at the end of this document for more detail on cookies.
- Depending on the configuration of your browser, pages and images you view on our site may be stored on your computer. This feature, (which you can configure), is called caching.
- All information you exchange with the JFL website is accessible by its administrators and will only be used to prevent abuse, fraud and threats to members’ confidentiality or safety. This information will only be accessed with respect to specific reports of such activity.
- Information we receive from other sources – information about you may be received by us if you use another website or service that we operate or are connected with in our normal course of business.
- Third-parties may also provide information to us about you, specifically from any of the following; our business partners and/or sub-contractors, or advertising and marketing services, or our technical and analytics providers, or our search engine and search information providers.
How your information is used
The information we hold about you is used as follows:
- Information that you provide to us – this information is used to meet our obligations within any contracts between you and us, and/or our legal obligations, and/or;
- to meet your requests for information and services, or
- to notify you of changes to our services, or make suggestions or recommendations that may interest you, or
- to improve content of our site and ensure it is presented effectively for you and your device, or
- deal with investigations by the police or other regulatory bodies.
- Information that we collect about you – we use this information:
- to manage our website as well as for our efficient operations, which includes analysis, research, statistical and survey uses, together with testing and troubleshooting;
- to improve our website and content for users and their devices;
- to allow you to interact with our website and take advantage of our online services, whenever you may elect to do so;
- to ensure our site is safe and secure by monitoring activities within the context of continual process improvement, which is a best practice requirement of the GDPR;
- to monitor advertising and marketing effectiveness for users, and/or to fine-tune advertising by relevance to users;
- to enable targeted suggestions/recommendations to users about services that may be of interest.
- Information we receive from other sources – we may use third-party information, which may be combined with information you provided to us and/or information collected by us, which may be used for the purposes we have defined above.
Know your rights
Under the GDPR all individuals, who are the owners of their Personal data, have specific and clear rights, which are;
|Right to Erasure||Every individual has the right to be forgotten upon request. The data controller must remove your Personal data from its systems and request the same of any third-party systems of that controller, unless other lawful requirements apply.|
|Right to Access||Every individual has the right to access their Personal data held about them upon request.|
|Right to Portability||Every individual has the right to request their Personal data and use it for other parties they wish to engage with.|
|Right to be Informed||Every individual has the right to be informed about how their Personal data is being used, which may be provided upon request of the individual, or before the controller changes any use of that data, giving the individual the right to consent or object.|
|Right to Objection||Every individual has the right to object to the use of their Personal data for any purpose proposed by a controller.|
|Right to Rectification||Every individual has the right to have errors in their Personal data to be corrected.|
|Right to Restrict||Every individual has the right to restrict the uses of their Personal data for any specific type of processing.|
|Rights on automated decisions & profiling||Every individual has the right to restrict or object to automated decision-making processes or profiling based on their Personal data.|
- Revoke your consent – in accordance with the GDPR, to revoke consent for processing of your Personal data send an email with the word “Revoke” in the subject field to firstname.lastname@example.org.
- Data Subject Access Request (DSAR) – in accordance with the GDPR,
- you may request us to send you details about any Personal data that we may hold about you, or
- you may request that we correct any errors, or
- you may request us to delete any/all Personal data about you.
- DSAR Fee – In accordance with the GDPR, any DSAR is provided free of charge within 30 days, unless a particular DSAR is subject to other regulatory requirements as defined within the GDPR, in which case we will inform you as required by those specific regulations.
Do we pass your information on to third-parties?
We may pass your data to other parties as follows:
- Where relevant, we may pass your data to our employees, suppliers and agents to administer the website and the services provided to you by us or them, now or in the future.
- We may disclose your data to the police, regulatory bodies or legal advisers in connection with any alleged criminal offence or suspected breach of the Terms and Conditions of Use and (where appropriate) Membership Terms and Conditions by you or otherwise where required by law.
We use the following third-parties to process your data and deliver services for the purposes shown. All of these processors have access to some of your Personal data as appropriate for the delivery of the purpose specified.
|Website, CRM and document management service providers||Maintenance and support of our Website, CRM and document management systems which allows access to and analysis of data.|
|Email campaign service providers||Delivery of our email newsletters.|
|IT service providers||Maintenance and support of our IT systems.|
|External market researchers||Survey of JFL Members and Gatekeepers.|
|Marketing and Event service providers||Marketing and Event Management services.|
Links to other sites
Please be aware that the JFL site and/or marketing materials may link to other web sites that may be accessed by you through our site. We are not responsible for their data policies, content or the security of these linked web sites. We do not have any control over the use to which third parties may have of your data, where you choose to purchase products or services or otherwise to contact them via our site.
Marketing to contacts without their consent
We may hold business contact data about you if you are a professionally relevant contact for our services. Your data will only be used to inform you of a service or product which might be relevant to you in your professional capacity. Our main channel of communication is through email and we conduct this marketing in adherence with the Privacy and Electronic Communications Regulation (PECR). This allows for business-to-business marketing on an opt-out basis in so long as a lawful means of processing under GDPR has been established. Our lawful basis for processing in this instance is Legitimate Interests for international parties, or Contract for local members. We may also contact you by telephone from time to time to follow up on interest you have expressed or to verify contact information.
We will respect your wishes and how and if you want to be contacted. If you no longer wish to be contacted for marketing purposes you can:
- Click the unsubscribe link in any email you are sent
- Call us on 01534 836000
- Email email@example.com
In accordance with the GDPR (or similar/related regulations), we may require you to verify your identity prior to acting on any instruction. This measure is to protect you/your organisation from any potential abuse and we will advise you accordingly, in compliance with the law and/or recognised best practice standards.
Transfer outside the EU/EEA
This site is accessible via the internet and therefore may potentially be accessed by anyone around the world. Other visitors may also access the site from outside Jersey and/or the European Economic Area.
- This means that, where you post your data on the site, this could be accessed from anywhere around the world and therefore a transfer of your data outside of Jersey and/or the European Economic Area may be deemed to have occurred.
- Data protection laws in countries outside of Jersey and/or the European Economic Area are generally not as protective.
By completing and publishing your member profile you consent to such transfer of your data for and by way of the purpose stated here.
Data Retention Policy
User data is retained indefinitely to meet the legal obligations of JFL. However, we reserve the right to delete inactive user data older than 10 years.
- E&OE: If you notice any errors (spelling, grammar or other) in this policy document please feel free to notify us via our contact details below.
For any questions relating to your Personal data, or to submit a DSAR, please contact us:
Jersey Finance Limited
4th Floor, Sir Walter Raleigh House,
Jersey JE2 3QB
Phone: +44 (0)1534 836000