Jersey Development Company (JDC) values your privacy and is committed to ensuring that your privacy is protected.
This privacy notice sets out how JDC processes 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 in regard to:
- Visitors to our website.
- Persons that subscribe to our communications, i.e. online feedback forms, newsletters and event notifications
‘We’, ‘our’ or ‘us’ means Jersey Development Company.
‘You or ‘your’ means any person using the services of Jersey Development Company.
‘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.
This 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. 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 email@example.com 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 Data Protection Officer, Dialogue House, First Floor,2, 6 Anley Street, St Helier, JE2 3QE
If we are unable to satisfy your query you may make a complaint to the Jersey Office of the Information Commissioner:
2nd Floor, 5 Castle Street, St. Helier, Jersey JE2 3BT
+44 (0) 1534 716530
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 this website 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 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;
- progress any property reservation and conveyance that may result from enquiries or contact;
- provide customer support services including property maintenance and remedial works post legal completion;
- comply with our regulatory and legal obligations, including our ‘know your customer’ (KYC) and due diligence requirements;
- reporting of crime or suspected crime, including money laundering or fraud.
- When you use our services or through your interactions with us;
- When you complete a reservation form on our website;
- When you interact with our officers and employees and advisors;
- 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 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 marketing office 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 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 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 managing 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; 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; 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,
4) What we use your personal data for
Jersey Development Company 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 (where subscribed to / consent provided), including photos and videos;
- To provide you with requested products or 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) We may disclose your personal data to
- Any JDC entity;
- Any third-party data processors who process your personal data on our behalf;
- Any third parties service providers which are themselves data controllers such as professional advisors, banks and other service providers;
- 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.
6) Data security
We take the security of your personal information seriously and do not share this unless it is essential 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.
7) International transfers or other jurisdictions
We operate in Jersey in the Channel Islands and our data substantially resides in Jersey.
We do use technology that may transfer data to another jurisdiction, for example use of Microsoft and cloud-based software and back-up of data. We will ensure that your data is appropriately protected (for example by reference to IT Policy), where such transfers do not offer the same level of protection of personal data.
8) 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.
If the settings on your internet browser that you are using to view this website are adjusted to accept cookies, we take this, and your continued use of our website, to mean that you are fine with this.
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.
10) Your right
Under the Data Protectstion Law, data subjects have the following rights with regards to their personal information. The right to
- access personal data and supplementary information
- automated decision making and profiling
- be informed about the collection and the use of their personal data
- complain to the Information Commissioner (https://oicjersey.org/)
- 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.
11) 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.