JT (IOT) Limited – Privacy Notice
JT IOT as the parent of the JT IOT Group is a ‘data controller’. This means that we are responsible for deciding how we hold and also use personal information about you. We are required under the Data Protection (Jersey) Law 2018, the Data Protection (Bailiwick of Guernsey) Law 2017, the General Data Protection Regulation 2016/679 (“GDPR”), the UK GDPR (the GDPR as implemented into UK domestic law) and the UK Data Protection Act 2018 (as applicable, the “Data Protection Laws“) to notify you of the information contained in this Policy.
For the avoidance of doubt, This Policy is issued on behalf of the JT IOT Group so when we mention JT IOT, “we”, “us” or “our” in this Policy, we are referring to the relevant company in the JT IOT Group responsible for processing your data. We will let you know which entity will be the controller for your data when you purchase a product or service with us. JT IOT is the controller and responsible for this website.
We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this Policy. If you have any questions about this Policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
If you have any questions about this Policy or our privacy practices, please contact our DPO in the following ways:
Full name of legal entity: JT (IOT) Limited/JT IOT Group
Email address: firstname.lastname@example.org
Postal address: JT (IOT) Limited, No 1 The Forum, Grenville Street, St Helier, Jersey, JE4 8PB
You have the right to make a complaint at any time to the relevant regulator. For example, the Jersey regulator for data protection issues is the Jersey Office of the Information Commissioner (jerseyoic.org) and the UK regulator for data protection issues is the Information Commissioner’s Office (ICO) (www.ico.org.uk). Please see the section below on your legal rights within this Policy for more information. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
We keep our Policy under regular review. This version was last updated on 20 July 2021.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes (where applicable) first name, maiden name, last name, username or similar identifier, title and date of birth;
- Contact Data includes (where applicable) billing address, delivery address, email address and telephone numbers;
- Financial Data includes (where applicable) bank account and payment card details;
- Transaction Data includes (where applicable) details about payments to and from you and other details of products and services you have purchased from us;
- Technical Data includes (where applicable) internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website;
- Profile Data includes (where applicable) your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses;
- Usage Data includes (where applicable) information about how you use our website, products and services; and
- Marketing and Communications Data includes (where applicable) your preferences in receiving marketing from us and our third parties and your communication preferences, as well as any third parties we have a sponsorship agreement with, where you have opted-in through a third party and we subsequently contact you for marketing purposes.
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy.
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a Contract/Conditions we have with you, and you fail to provide that data when requested, we may not be able to perform the Contract we have or are trying to enter into with you (for example, to provide you with Services). In such circumstances, JT may suspend the Service and/or terminate the Contract.
How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your identity, contact and financial data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services (including the limited personal data received through the JT IOT Group number portability services- please see below);
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
- Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources (such as the examples set out below):
- Google Analytics
- Technical data from the following parties:
- analytics providers (such as Google based outside the Channel Islands/UK);
- advertising networks (such as Google or LinkedIn based outside the Channel Islands/ UK); and
- search information providers (such as Google based outside the Channel Islands/UK).
- Contact, financial and transaction data from providers of technical, payment and delivery services.
- Identity and contact data from data brokers or aggregators.
- Identity and contact data from publicly available sources such as Companies House, and the Electoral Register based inside the UK, and the JFSC based in Jersey.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Performing the Contract and providing the Service (our legal basis for processing will be performance of a contract where the data subject is a party to the Contract, or potentially sometimes legitimate interests, so long as a legitimate interests assessment (LIA) has been carried out and it shows no negative impact on the rights and freedoms of the data subject);
- Dealing with complaints or enquiries in relation to the use of the Service (Performance of a contract or legitimate interests with LIA completed);
- Assisting the emergency services in an emergency (legitimate interests with LIA completed and, in some circumstances, vital interests);
- Debt collection, credit referencing and preventing fraud, theft and other unlawful activity (legitimate interests with LIA completed); and
- Compliance with applicable law or orders of a court or other body of competent jurisdiction (legal obligation).
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your “opt-in” and recorded consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer||(a) Identity|
|Performance of a contract with you|
|To process and deliver your order including:|
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
|(a) Performance of a contract with you|
(b) Necessary for our legitimate interests (to recover debts due to us)
|To manage our relationship with you which will include:|
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
|(a) Performance of a contract with you|
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To enable you to partake in a prize draw, competition or complete a survey||(a) Identity|
(e) Marketing and Communications
|(a) Performance of a contract with you|
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity|
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)|
(b) Necessary to comply with a legal obligation
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity|
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical|
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity|
(f) Marketing and Communications
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
Processing for Number Portability Customers
We may process personal data for certain number portability customers from time to time, which could include storing sets of numbers on their own, with no other identifying data. While we identify that it is very unlikely we could identify a data subject from a database containing large sets of numbers only, the relevant Data Protection Legislation does list telephone numbers as personal data. Therefore, where JT IOT or any subsidiary within the JT IOT Group processes personal data in this way for number portability customers, JT IOT/the entity within the JT IOT Group will comply with the processing obligations contained within the Addendum attached to this Policy.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your identity, contact, technical, usage and profile data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by a) logging into your website portal (if applicable to you) and checking or unchecking relevant boxes to adjust your marketing preferences; b) following the opt-out links on any marketing message sent to you; or c) by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
Third Party Disclosure
JT IOT may disclose your personal information to members of the JT Group, more specifically the JT IOT Group. JT IOT may also disclose it to external third parties, to include: partners, suppliers, sub-contractors or agents engaged by JT IOT for the purpose of performing the Contract and providing the Service. Other parties engaged to perform services for, or on behalf of JT IOT; persons making a complaint or an enquiry in relation to the use of the Service; the emergency services (if you make an emergency call), including your approximate location; other communications service providers and network operators; credit reference and debt collection agencies; appropriate authorities for the purpose of preventing fraud, theft and other unlawful activity; and commercial partners for joint promotions with that third party. JT IOT may also be required to share your personal information with a third party or body in circumstances where such disclosure is required to satisfy any applicable law or regulatory requirements. Disclosures to law enforcement agencies, regulatory organisations, government bodies or agencies, courts or other public authorities may occur if JT IOT is authorised. Or if it is required, by law to do so. If there is a change (or expected change) in who owns JT IOT or any of JT IOT’s assets, JT IOT might also share personal information to the new (or prospective) owner. If JT IOT does, that party will have to keep the shared information confidential.
JT IOT may need to transfer your personal information to a jurisdiction that is outside of Jersey, Guernsey and the European Economic Area (“EEA”). The EEA consists of countries in the European Union, Switzerland, Iceland, Liechtenstein and Norway. They are considered to have equivalent laws when it comes to data protection and privacy. The laws of the Bailiwicks of Jersey and Guernsey have been deemed “adequate” for the purposes of EU data protection standards. This kind of data transfer may happen if, for example, a member of the JT IOT Group, a JT IOT supplier or a service provider is based outside Jersey, Guernsey and the EEA. Or, if you use JT IOT’s services and products while visiting countries outside these jurisdictions. If JT IOT sends your information to a jurisdiction that is not in the EEA or the Channel Islands, JT IOT will make sure that your information is properly protected. JT IOT will also ensure that there is a legal agreement that covers the data transfer. In addition, if the country is not considered to have laws that are equivalent to EU data protection standards then we will ask the third party to enter into a legal agreement that reflects those standards.
JT IOT 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:
- 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.
- Request correction of your personal information. This enables you to have any incomplete or inaccurate information held about you corrected.
- 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).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party). And, if 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.
- 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
- Request the transfer of your personal information to another party.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
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.
Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, you should contact JT IOT in writing. JT IOT has appointed a data protection officer who may be contacted at email@example.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 may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
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. These are the Island’s respective supervisory authorities for data protection issues.
Addendum – Data Processing Provisions for Number Portability
JT IOT and any subsidiary under the JT IOT Group shall ensure, at all times during the term of any number portability contract, that where they process personal data (as the data processor) on behalf of the number portability customer (as the data controller) they, and any relevant sub-contractor who is responsible for the processing, storage or management of the personal data shall:
- process any personal data only at locations either a) within the EEA; b) within the Bailiwick of Jersey/Guernsey or any other country that has “adequacy” status from the European Commission under Article 45 of the General Data Protection Regulation (EU) 2016/679 (“GDPR”); c) any location approved by the number portability customer; or d) where the number portability customer has given its consent to a transfer of the personal data to outside of the European Union where there is either i) an adequacy decision granted; or (ii) there are appropriate safeguards in place that meet the requirements of Article 67 of the Data Protection (Jersey) Act 2018 (“DP18”); or (iii) the transfer falls within the exceptions set out in Schedule 3 DP18.;.
- comply with any registration requirements under the DP18, the GDPR, and all other applicable laws and regulations relating to processing of personal data and privacy (together with GDPR and DP18, collectively the “Data Protection Legislation”) and will only process personal data as necessary to fulfil the terms under any relevant number portability contract agreed between the parties;
- process all personal data in accordance with the documented instructions provided by the relevant number portability customer and ensure to the best of their knowledge the processing of personal data is compliant with Data Protection Legislation;
- immediately inform the number portability customer if in JT IOT/relevant entity of JT IOT Group’s opinion any instruction given by the number portability customer to JT IOT/the relevant entity within the JT IOT Group infringes privacy and Data Protection Legislation requirements;
- notify the number portability customer without undue delay of any requests received from a data subject exercising their rights under privacy and Data Protection Legislation requirements and assist the number portability customer fulfil its obligations in respect of data subject rights under the privacy and Data Protection Legislation requirements, but excluding responding to any subject access requests or requests from data subjects pursuant to Part 6 of DP18, unless so requested by the number portability customer and agreed by JT IOT/the relevant entity within the JT IOT Group;
- take all security measures required in accordance with the privacy and Data Protection Legislation requirements (including where relevant, Article 21 and 22 DP18 as well as Article 32 of the GDPR), and at the request of the number portability customer provide a written description of, and rationale for, the technical and organisational measures implemented, or to be implemented;
- taking into account the nature of the processing and the information available to JT IOT/the relevant entity within the JT IOT Group, use all measures to assist the number portability customer in ensuring compliance with the number portability customer’s obligations to: i) keep personal data secure (Article 21 DP18); ii) notify personal data breaches to the relevant supervisory authority (Article 20 DP18); iii) advise data subjects when there has been a personal data breach (Article 20(6) DP18); iv) carry out data protection impact assessments (Article 16 DP18); v) consult with the number portability customer where a data protection impact assessment indicates that there is an unmitigated high risk to the processing (Article 17 DP18); v) without undue delay, inform the number portability customer of becoming aware of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, the personal data transmitted, stored or otherwise processed; vi) make available to the number portability customer all information, including (but not limited to) any documentation or record (which may be redacted to remove confidential commercial information not relevant to the requirements of the services and/or goods provided), necessary to demonstrate compliance with the obligations laid down in the relevant number portability agreement and allow for and contribute to audits, including inspections, conducted by the number portability customer or another auditor mandated by the number portability customer; vii) ensure that persons authorised to process personal data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality; and viii) JT IOT/the relevant entity within the JT IOT Group will only engage a sub-processor with the prior consent of the number portability customer in writing (where this is applicable or reasonable to expect, depending on the location and nature of the sub-processor) and the number portability customer shall not unreasonably withhold their consent;
- when the relevant number portability agreement terminates JT IOT/the relevant entity within the JT IOT Group shall immediately cease to use personal data and shall arrange for its safe return or destruction as shall be required by the number portability customer (unless prescribed by law); and
the subject matter of the processing of personal data is the provision of the services agreed between the parties under the relevant number portability agreement only.