Jersey Development Company (JDC) and its associated entities value your privacy and are committed to ensuring that your privacy is protected.
JDC is a data controller for the purposes of the Data Protection Jersey (2018) Law (DPJL), the Data Protection Authority (Jersey) Law 2018 and any other applicable data privacy legislation in force from time to time. JDC has issued this privacy notice on its behalf and on behalf of all of its associated entities from time to time including (but not limited to) any of its underlying subsidiaries and certain joint venture entities in which it participates. A list of such entities is attached at Schedule 1.
This privacy notice sets out how JDC and its associated entities process personal data, whether it be in respect of individuals who are customers or other third parties collectively being data subjects and further sets out the rights of data subjects in respect of their personal data.
This privacy notice explains what information we collect, how we collect it and how that information is then used. This information is referred to as your ‘personal data’ and is managed in accordance with the Data Protection Jersey (2018) Law and any related Regulations and guidance.
This policy applies to information we collect with regard to:
- Visitors to our website;
- Persons that subscribe to our communications, i.e. online feedback forms, newsletters and event notifications;
- Customers or potential customers;
- Members of the public responding to our marketing campaigns or any promotional activity or public consultations;
- Persons that we deal with in the course of our business – for instance:
- persons who may contract with us to purchase or transact with us on their own behalf or on behalf of someone else;
- persons who will deal with us in the course of obtaining services from us; and
- persons employed or engaged by those who we deal with in the course of our business
‘We’, ‘our’ or ‘us’ means Jersey Development Company and its associated entities.
‘You or ‘your’ means any person using the services of Jersey Development Company or its associated entities.
‘Information’ or ‘data’ means all the different forms of information you provide us and which we collect in carrying out our duties and in providing services to you.
Terms such as personal data, data controller and others pertinent to this Privacy Notice have the meanings as set out in the Data Protection (Jersey) Law 2018 (DPJL).
This privacy notice provides you with the necessary information regarding your rights and obligations, and explains how, why and when we collect and process your personal data and your rights to deletion.
The Company’s website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements/websites/data collection and processing. When you leave our website, we encourage you to read the privacy notice of every website you visit.
1. NAME AND ADDRESS OF THE CONTROLLER
We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to any data protection questions.
Email firstname.lastname@example.org if you have any questions relating to:
- Data protection
- How we use your information
- Information security
- A wish to have your information modified, deleted or to gain access to the information held about you.
Alternatively, write to the Data Protection Officer, Dialogue House, First Floor, 2- 6 Anley Street, St Helier, JE2 3QE
We would ask you to bring any complaints to our attention in the first instance. However, if we are unable to satisfy your query you may make a complaint to:
The Jersey Office of the Information Commissioner
5 Castle Street
2. WHERE AND WHEN WE COLLECT YOUR DATA
We may collect and process your personal data from a variety of sources including:
- Your use of the Company’s websites or when you contact us by telephone, post, e-mail or through any other means (including for the avoidance of doubt via social media services);
- When you register with us and set up an account to receive our services;
- When you complete surveys that we use for research or feedback purposes (although you are not obliged to respond to them);
- When you enter a competition or promotion;
- When you make payments to us;
- When you accept cookies when accessing our website;
- When you set your preferences for receiving communications (i.e online feedback form, newsletters and event notifications) from us;
- Where you have consented to be contacted for purposes which we feel may interest you or provide you with information regarding our products or services that you request from us;
- When we progress any property reservation and conveyance that may result from enquiries or contact;
- When we provide customer support services including property maintenance and remedial works post legal completion;
- When we comply with our regulatory and legal obligations, including our ‘know your customer’ (KYC) and due diligence requirements;
- In the reporting of crime or suspected crime, including money laundering or fraud.
- When you use our services or through your interactions with us;
- When you report any issues with a property which we have sold;
- When you complete a reservation form on our website;
- When you interact with our officers and employees and advisors or otherwise provide information to us;
- Through the information you provide us when you are applying to invest (or considering such an investment) in a property;
- When you interact with us on behalf of your own employer or institution;
- When we receive your personal data from third parties, for example estate agents, legal advisors, service providers, credit reference agencies or fraud prevention organisations or through third party advisors acting on your behalf;
- When we collect publicly available information about you (for example, when we are conducting Client Due Diligence for Anti Money Laundering purposes);
- When you register on our website, contact us by phone or text, or when you visit our offices or developments.
3. WHAT DATA WE MAY COLLECT
We may collect and process the following types of personal data especially when you register on our website, contact us by phone or text, or when you visit our offices (including the marketing suite for all our developments):
- Your full name, address, country of residence, email address, telephone number, date of birth and other contact information;
- Your personal identification documentation, such as original/photocopy of utility bills, your passport, marriage certificate, driving licence, ID card or other documentation required by local law;
- Details about your requirements – particularly if you are looking to transact with us, details of the type of property you are interested in purchasing ie. number of rooms, price range etc;
- Details of payments that you make to us;
- Information about your billing and payment history, and information we learn from the way you manage your account;
- CCTV footage and other information obtained through electronic means such as debit or credit card records;
- Details of your interactions with us, including any which occur electronically or in person for our lawful business purposes including, but not limited to: establish the existence of facts relevant to the business; to ascertain compliance with regulatory and self-regulatory practices and procedures that are relevant to the business; to ascertain or demonstrate standards that employees achieve or ought to achieve when using our communication systems; to ensure compliance with policies and procedures; to prevent or detect crime; to investigate or detect unauthorised use of the communication systems; to ensure the effective operation of the communications systems; and to determine whether received communications are relevant to the business;
- Information about your use of our services, including information about your car park usage which we collect from the software which manages the car park. Some of the information we collect about you may include sensitive personal data (or special category data) as defined in the applicable Data Protection Law in Jersey (presently the Data Protection (Jersey) Law 2018);
- Information that you submit in response to a survey(s) or poll or competition; and
- If purchasing, or potentially purchasing, a property from us:
- We may also ask for details of your mortgage arrangements or other financial arrangements to purchase your property;
- We may ask for details of your current property status – ie. whether it has been sold or you are in a chain; and
- We reserve the right to conduct credit checks with third party credit and financial institutions to confirm any information that you have provided to us.
In some circumstances, we may not be able to communicate with you and/or take certain actions that you request if you do not provide this information. For example, because this personal information is required to respond to your enquiries or provide you with services. Where this is the case we will let you know.
In some circumstances you may provide us with information relating to other data subjects – most notably family members or associated persons. Where you provide us with information of other data subjects, you confirm that that person has consented to you providing us with that information and you will draw to their attention a copy of our privacy notice.
4. WHAT WE USE YOUR PERSONAL DATA FOR
Jersey Development Company, our associated entities and/or persons acting on our behalf may process your personal data for any of the following purposes, depending on the capacity in which you deal with us. Most commonly, we will use your personal data in the following circumstances:
- Where we need to prepare the contract, we are about to enter into or have entered into with you;
- To service and administer your account and to carry out our obligations arising from any contracts entered into between you and us including the provision of car park related services;
- Where it is necessary for the exercise of any functions conferred on us by, or under any enactment, or the exercise of any other functions of a public nature, with a legal basis in Jersey law, to which we are subject and are exercised in the public;
- In certain circumstances, where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
- Where we need to comply with a legal or regulatory obligation;
- *To manage our business and ensure the protection of our own financial interests and those of other JDC entities;
- *For monitoring and assessing compliance with JDC’s policies and standards;
- For promotional and marketing materials and activities including photos and videos (where subscribed to / consent provided, unless those images or videos are already in the public domain. You have the right to withdraw consent to marketing materials at any time;
- *To provide you with requested products or services;
- To communicate with you and respond to queries you may have;
- *To understand your requirements in order to provide you with services or transact with you;
- *To ensure you are connected to essential services such as services provided by public utility companies and postal services;
- *To provide property maintenance services;
- *To identify persons authorised to deal with us on behalf of our clients;
- *In order to ensure the security and access of our systems, premises, platforms and secured websites and applications; and
- Other purposes reasonably ancillary to the above.
5. WHAT LEGAL GROUNDS DO WE RELY ON FOR PROCESSING YOUR PERSONAL DATA?
Personal data may be processed for the purposes set out at section 4 (the "Purposes"). Depending on the Purposes for which your information is used, we will rely on the following legal grounds:
- The processing is necessary to comply with a legal obligation to which we are subject;
- The processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract;
- The processing is necessary for the purposes of our legitimate interests or those of any third party that receives your personal information, except where these are overridden by your interests or fundamental rights and freedoms.
- In limited circumstances (most notably direct marketing), where we have consent to process your personal data. Consent can be withdrawn at any time;
- On rare occasions, where we need to protect your interests (or someone else's interests) or where it is needed in the public interest.
*The Purposes based on our legitimate interests are indicated by asterisks.
Some of the above grounds for processing described above will overlap and there may be several grounds which justify our use of your personal data.
6. WE MAY DISCLOSE YOUR PERSONAL DATA TO:
- Any JDC entity;
- Any third-party data processors who process your personal data on our behalf such as cloud based service providers (such as hosting services);
- Any third parties service providers which are themselves data controllers such as professional advisors, banks and other service providers – including public utility companies and the postal services, construction and property maintenance professionals and building/property management entities;
- Any other financial institutions or regulatory bodies with which personal data and other information is shared for fraud and crime prevention and credit risk assessment/mitigation;
- Any national and/or international regulatory, enforcement or exchange body or court where we are required to do so by applicable law or regulation or at their request; and
- Any central or local government department and other statutory or public bodies as required.
7. DATA SECURITY
We take the security of your personal information seriously and do not share this unless it is necessary to provide you with a service in performing our statutory duties. There may also be occasions when we need to share your information, in the following ways:
- When we have your permission
- When required by law to disclose it
- While pursuing tasks for which we have a legitimate interest
We use up-to-date data storage and security techniques to protect your personal information from unauthorised access, improper use or disclosure, unauthorised modification or unlawful destruction or accidental loss.
We take care to ensure the security of your personal data in use, storage, and transmission and that it is only accessed by verified persons who have the necessary authority. All our employees and any third parties we engage with to process your personal information are legally and contractually obliged to respect the confidentiality of your information and we deliver training to ensure this is maintained.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. INTERNATIONAL TRANSFERS OR OTHER JURISDICTIONS
We operate in Jersey in the Channel Islands.
We use technology that may transfer data to another jurisdiction, for example use of Microsoft and cloud-based software and back-up of data and in certain circumstances other service providers who may be located outside of Jersey, the UK or the EU or may host data outside of these jurisdictions. We will ensure that your data is appropriately protected (for example by reference to IT Policy and legal requirements), where such transfers do not offer the same level of protection of personal data.
9. HOW LONG WE RETAIN PERSONAL DATA
We will retain your personal data for as long as necessary to fulfil the purpose for which it was collected.
Once those purposes are completed, we then have legal and regulatory obligations in connection with data retention which we will need to fulfil.
Additionally, we may also retain personal data in some circumstances for a period of least ten years to ensure that we are able to answer and deal with any queries, complaints, tax enquiries or investigations or any legal proceedings which may arise.
Necessary cookies help to make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.
The law states that we can store cookies on your device if they are strictly necessary for the operation of our website. For all other types of cookies we need your permission.
If the settings on your internet browser that you are using to view our websites are adjusted to accept cookies, we take this, and your continued use of our website, to mean that you accept this data collection.
a) USE OF THIRD-PARTY COOKIES
We may use external services such as Google Analytics, Facebook, LinkedIn, Instagram, and Twitter to display certain content on our website.
We use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics sets several cookies to evaluate your use of our site and enable us to carry out actions including (but not limited to):
- Tracking the number of visitors to our website.
- Monitoring the number of users on our website at any given time.
- Analysing popular content on our website.
b) ANALYTICS INFORMATION
As mentioned, we may use external services such as Google Analytics, Facebook, LinkedIn, and Twitter to display certain content on our website. We cannot prevent such websites from collecting information about your usage of their services, for example: the number of plays of a video, how many visits to the website and accessing location data, etc.
Google will use this information for the purpose of evaluating your use of our websites, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google.
c) LOCATION DATA
When you access the Service by, or through a mobile device, we may access, collect, monitor and/or remotely store “location data,” which may include GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of your device. Location data may convey to us information about how you browse and use the service. Some features of the service, particularly location-based services, may not function properly if use or availability of location data is impaired or disabled.
11. YOUR RIGHTS
Under the DPJL, data subjects have the following rights with regards to their personal information. The right to:
- Access personal data and supplementary information
- Object to automated decision making and profiling
- Be informed about the collection and the use of their personal data
- Data portability, which allows the data subject to obtain and reuse their personal data for their own purposes across different services
- Erasure (to be forgotten) in certain circumstances
- Have inaccurate personal data rectified, or completed if it is incomplete
- Object to processing in certain circumstances
- Restrict processing in certain circumstances
- Withdraw consent at any time (where relevant)
If you object to processing or withdraw your consent, this may affect our ability to deliver services to you. If this is the case, we will let you know.
You also have the right to make a complaint to us (contact details are provided above) or to the Jersey Office of the Information Commissioner (https://jerseyoic.org/).
12. CHANGES TO THE NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
It is important that the personal data we hold about you is accurate and up to date. Please keep us informed if your personal data changes during your relationship with us.
List of entities
The States of Jersey Development Company Limited
- Waterfront (CP) Limited
- Waterfront (LC) Limited
- JIFC Management Limited
- Westward Developments Limited
- Waterfront Development (6C) Limited
- Horizon (West) Limited
- Horizon (Manco) Limited
- Horizon (Commercial) Limited
The registered address for all the above Companies is at Dialogue House, First Floor, 2- 6 Anley Street, St. Helier, JE2 3QE, Jersey.
Point of contact: refer clause 1 - “Name and Address of the controller” above.