JT Group Limited – Data Protection Notice

This is the data protection notice referred to in the various JT Terms and Conditions applicable to our products and services (the “Conditions“). Terms defined in the relevant Conditions shall have the same meaning in this notice unless otherwise defined in this notice.

This notice applies to any natural person (a “data subject” or “you“) entering into a Contract with JT (“we” or “us“) or in relation to whom JT receives personal information in relation to a Contract. We may update this notice at any time.

JT is a ‘data controller’. This means that we are responsible for deciding how we hold and use personal information about you. We are required under the Data Protection (Jersey) Law 2018 and the Data Protection (Bailiwick of Guernsey) Law 2017 (as applicable, the “Data Protection Laws“) to notify you of the information contained in this notice.

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

JT will process your personal information on the following legal bases:

1. it is necessary for the performance of a contract to which you are a party (the “contractual necessity” basis);
2. it is necessary for compliance with a legal obligation (other than a contract) to which JT is subject (the “legal obligation” basis);
3. it is necessary for the purpose of legitimate interests (the “legitimate interests” basis) pursued by JT or a third party provided your interests and fundamental rights do not override those interests;
4. if it is necessary to protect vital interests (life and limb) of the data subject or another person (the “vital interests” basis); or
5. if it is necessary for any legal proceedings, obtaining legal advice or establishing, exercising or defending legal rights (the “legal proceedings” basis).

The purposes for which (and, in parentheses, the relevant legal bases on which) JT shall process your personal information in relation to the Contract are as follows:

1. performing the Contract and providing the Service (legitimate interests and, where the data subject is a party to the Contract, contractual necessity);
2. dealing with complaints or enquiries in relation to the use of the Service (legitimate interests);
3. assisting the emergency services in an emergency (legitimate interests and, in some circumstances, vital interests);
4. debt collection, credit referencing and preventing fraud, theft and other unlawful activity (legitimate interests); and
5. compliance with applicable law or orders of a court or other body of competent jurisdiction (legal obligation).

Some of the above bases for processing will overlap and there may be several bases which justify the use of your personal information. We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason, for example for the prevention of crime, or that reason is compatible with the original purpose, or is in your interest. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

If you fail to provide certain information when requested, we may not be able to perform our obligations under the Contract and we may be prevented from complying with our legal obligations. In such circumstances, JT may suspend the Service and/or terminate the Contract.

JT may disclose your personal information to members of the JT Group and to third party sub-contractors or agents engaged by JT for the purpose of performing the Contract and providing the Service. JT may also disclose your personal information to persons making a complaint or an enquiry in relation to the use of the Service and, in an emergency, to the emergency services. Your personal information may be shared with other communications service providers and network operators, credit reference and debt collection agencies and the appropriate authorities for the purpose of preventing fraud, theft and other unlawful activity. JT may also be legally required to share your personal information with judicial, law enforcement, regulatory and governmental bodies or agencies.

JT will not transfer your personal information outside of Jersey or the European Economic Area or to an international organisation.

JT will store your personal information for no more than 6 years after your Contract has ended.

Under the Data Protection Laws, you will have the right in certain circumstances to:

1. request access to your personal information (commonly known as a ‘data subject access request’). This enables you to receive a copy of the personal information held about you and to check that it is being lawfully processed;
2. request correction of your personal information. This enables you to have any incomplete or inaccurate information held about you corrected;
3. request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You will also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below);
4. object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes;
5. request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information, for example if you want us to establish its accuracy or the reason for processing it; and
6. request the transfer of your personal information to another party.

If you wish to review, verify, correct or request erasure of your personal information, object to the processing of your personal information, or request the transfer of your personal information to another party, you should contact JT in writing. JT has appointed a data protection officer who may be contacted at dpo@jtglobal.com. You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if the request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

Under the Data Protection Laws, you will have the right to make a complaint at any time to either the Jersey or Guernsey Data Protection Authority, the Island’s respective supervisory authorities for data protection issues.

Your Right to Object

It is important that you understand that you have a right to object to us processing your personal information where we do so exclusively on the basis of legitimate interests. As set out above, this applies to where we are processing your data for the purposes of:

• performing a Contract to which you are not a party
• dealing with complaints or enquiries in relation to the use of the Service
• assisting the emergency services where there is no risk to life or limb
• debt collection, credit referencing and preventing fraud, theft and other unlawful activity

Cookies

So, what is a cookie?

A cookie is usually a small piece of data sent from a website and stored in your web browser while you are browsing a website. When you browse the same website in the future, the data stored in the cookie can be retrieved to notify the website of your previous activity.

What are cookies used for?

Cookies are used on more than 90 per cent of sites and serve many functions. For example, they can help us to remember your username and preferences, analyse how well our website is performing, or even allow us to recommend content we believe will be most relevant to you. Certain cookies contain personal information. For example, if you click on ‘remember me’ when logging in, a cookie will store your username. Most cookies won’t collect information that identifies you, but will instead collect more general information, such as how users arrive at and use our websites or a user’s general location. These cookies are divided into the following four categories:

1. Necessary Cookies that are essential for the operation of our website.
2. Functional Cookies that allow us to remember your preferences.
3. Performance Cookies that analyse how our visitors use our websites and to monitor website performance.
4. Tracking/Targeting Cookies that allow social media sites and our advertisers to serve you content we believe is relevant to you.

Advertising cookies Advert management system

Our advert management system uses cookies to identify which adverts you have previously seen, and to deliver campaigns effectively over a certain timeframe. These adverts also contain third party cookies, which are detailed below.

Third party adverts

Many of the adverts displayed on jerseyinsight.com are generated by third party companies. Some of these third parties use anonymous cookies to track how many people have seen a particular ad, or to track how many people have seen it more than once. The same cookies are also used to track the amount of clicks that an advert has generated, this is used for statistical reporting. The companies that generate these cookies have their own privacy policies, and jerseyinsight.com has no access to these cookies. Third party advertising cookies may also be used to target users with relevant adverts, based on their user habits on jerseyinsight.com.

Turning cookies off in browsers

Please remember that if you do choose to disable cookies, you may find that certain sections of our website do not work properly.

Google Chrome

1. Click the wrench icon on the browser toolbar and select ‘Settings’.
2. Click ‘Show advanced settings’.
3. In the ‘Privacy’ section, click the ‘Content settings’ button.
4. To enable cookies in the ‘Cookies’ section, pick ‘Allow local data to be set’; this will enable both first-party and third-party cookies. To allow only first-party cookies, pick ‘Block all third-party cookies without exception’.
5. To disable cookies, in the ‘Cookies’ section pick ‘Block sites from setting any data’.
6. Note there are various levels of cookie enablement and disablement in Chrome. For more information on other cookie settings offered in Chrome, refer to the following page from Google: http://support.google.com/chrome/bin/answer.py?hl=en&answer=95647.

Microsoft Internet Explorer 6.0, 7.0, 8.0

1. Click on ‘Tools’ at the top of your browser window and select ‘Internet Options’.
2. In the options window navigate to the ‘Privacy’ tab.
3. To enable cookies, set the slider to ‘Medium’ or below.
4. To disable cookies, move the slider to the top to block all cookies.
5. Note there are various levels of cookie enablement and disablement in Explorer. For more information on other cookie settings offered in Internet Explorer, refer to the following page from Microsoft: http://windows.microsoft.com/en-GB/windows-vista/Block-or-allow-cookies.

Mozilla Firefox

1. Click on ‘Tools’ at the browser menu and select ‘Options’, select the Privacy panel.
2. To enable cookies, check ‘Accept cookies for sites’.
3. To disable cookies, uncheck ‘Accept cookies for sites’.
4. Note there are various levels of cookie enablement and disablement in Firefox. For more information, refer to the following page from Mozilla: http://support.mozilla.org/en-US/kb/Enabling%20and%20disabling%20cookies.

Opera

1. Click on ‘Setting’ at the browser menu and select ‘Settings’, select ‘Quick Preferences’.
2. To enable cookies, check ‘Enable Cookies’.
3. To disable cookies, uncheck ‘Enable Cookies’.
4. Note there are various levels of cookie enablement and disablement in Opera. For more information on other cookie settings offered in Opera, refer to the following page from Opera Software: http://www.opera.com/browser/tutorials/security/privacy/.

Safari on OSX

1. Click on ‘Safari’ at the menu bar and select the ‘Preferences’ option, click on ‘Security’.
2. To enable cookies, in the ‘Accept cookies’ section select ‘Only from site you navigate to’.
3. To disable cookies, in the ‘Accept cookies’ section select ‘Never’.
4. Note there are various levels of cookie enablement and disablement in Safari.