Privacy Policy

Digital Jersey Limited (trading as Digital Jersey, known as “DJ”) is the data controller responsible for
your personal data. We are committed to protecting your privacy and complying with the Data
Protection (Jersey) Law 2018. This privacy notice explains how we collect, use, and protect your
personal information. JOIC Registration No. 110892.

The Data Protection Manager (“DPM”)

We have appointed a Data Protection Manager to oversee our data protection compliance. If you
have any questions about how we use your personal data, or if you wish to exercise your data
protection rights, you can contact our DPM at dpm@digital.je.

The Kind of Information We Hold About You

DJ collects and processes personal data to manage memberships, event bookings, and
communications with members, clients, and website visitors. We hold information such as your
name, contact details, business information, event preferences, and feedback. In some
circumstances, for example following an accident or incident at our facilities or events, we may also
hold health information.

How Is Your Personal Information Collected?

We collect your personal data in a number of ways:

• Directly from you, when you register as a member, book an event, fill in a contact form on
  our website, or communicate with us by email, telephone, or post
• When you visit our website, through cookies and similar tracking technologies
• From third parties, such as event organisers, sponsors, or partner organisations
• Automatically, when you interact with us online or use our facilities

What Information Do We Collect About You?

Special Category Data

Special category data is personal information about your health, ethnicity, religion, or other sensitive
matters. DJ processes health information in limited circumstances only. If you are involved in an
accident or incident at our facilities or events, we may record health-related information to fulfil our
duty of care and for safeguarding purposes. We only collect and use such information where it is
necessary, and we protect it with appropriate security measures. You have enhanced rights in
relation to special category data, including the right to object to its processing.

How We Will Use Information About You

We process your personal data on the basis of one or more of the following lawful bases, as set out
in the Data Protection (Jersey) Law 2018:

Contract

We use your personal data to perform our membership agreement with you, or to fulfil your event
booking. For example, we use your name, address, and email address to send you membership
confirmation, event tickets, and to manage your account. This processing is necessary to perform
the contract between us and you.

Legal Obligation

We may process your personal data to comply with a legal obligation, for example in response to a
court order, a regulatory investigation, or other legal requirement. We may also retain certain
records for archival or public interest purposes in accordance with our statutory obligations.

Legitimate Interests

We process personal data where it is in our legitimate interests to do so, and where those interests
are not overridden by your rights and freedoms. For example, we use your contact details to send
you news, updates, and information about membership benefits, events, and facilities; we may
analyse your engagement with our communications to understand which events and services are of
most interest to you; we may process your feedback and reviews to improve our services; and we
may use your business information to identify relevant sponsorship or partnership opportunities.
Where we send you marketing communications, we do so only where you have not objected to
receiving them or where we have your consent.

Consent

In some cases, we will ask for your explicit consent to process your personal data. For example, we
may ask your permission before taking photographs or video at an event, or before adding your
details to a specific mailing list. You have the right to withdraw your consent at any time by
contacting us

Change of Purpose

We will only use your personal data for the purpose for which it was collected, or for a purpose that
is compatible with the original purpose. If we wish to use your data for a new and different purpose,
we will notify you in advance and, where necessary, ask for your consent. Where the new purpose is
incompatible with the original purpose, we will not process your data for that new purpose unless
you agree.

Data Sharing

We share your personal data with the following processors to enable us to provide our services.
These organisations process data on our behalf and are contractually bound to protect your
information in accordance with data protection law.

We also share your personal data where required by law, or where it is necessary to protect our interests, the interests of our members, or the public.

International Transfers

Your personal data may be transferred outside Jersey in the course of our processing activities. We ensure that appropriate safeguards are in place to protect your data when it is transferred internationally, in accordance with the Data Protection (Jersey) Law 2018.

Data Security

We take the security of your personal data seriously. We have implemented appropriate technical and organisational measures to protect your data against unauthorised access, alteration, disclosure, or destruction. These measures include encryption, access controls, secure authentication, and regular security reviews.

However, no system of data protection can be completely secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee absolute security. Any transmission of data is at your own risk, and you are responsible for maintaining the confidentiality of any passwords or login credentials you use to access our services.

If you believe your personal data has been compromised or if you have a concern about our security practices, please contact us immediately using the details provided in the “How to Request Your Information” section below.

Data Retention

We retain your personal data only for as long as is necessary to fulfil the purposes for which it was
collected. The retention period depends on the reason for collection, any legal or regulatory
obligations we must meet, historical or public interest archiving needs, and whether the data is
needed for protection purposes.

Once the retention period has expired, your personal data will be securely deleted or anonymised,
unless we are required by law to retain it for a longer period. A detailed retention schedule is
available on request via a Data Subject Access Request. Please contact our Data Protection Manager
at dpm@digital.je for further information about how long your specific data is retained.

Rights of Access, Correction, Erasure and Restriction

Under the Data Protection (Jersey) Law 2018, you have a number of rights in relation to your
personal data. These are set out below.

Right of Access

You have the right to request a copy of the personal data we hold about you. This right is commonly
known as a Data Subject Access Request (DSAR). We will provide you with the information in a clear
and understandable format, usually within four weeks of receipt of your request.

Right to Rectification

You have the right to request that we correct any inaccurate or incomplete personal data we hold
about you. If we have shared your data with others, we will inform them of the correction where
possible.

Right to Erasure

In certain circumstances, you have the right to request that we delete your personal data. This right
is not absolute and applies only where we no longer need the data for the purpose it was collected,
where you withdraw consent (if consent was the lawful basis), or where the data has been
processed unlawfully. We may refuse to delete data where we are required to retain it by law or
where deletion would compromise our legal obligations or legitimate interests.

Right to Restrict Processing

You have the right to request that we restrict or suspend our processing of your personal data in
certain circumstances, such as where you have challenged the accuracy of the data or where you
have objected to processing on legitimate interest grounds. Where processing is restricted, we will
continue to store your data but will not actively process it further.

Right to Data Portability

Where we process your data on the basis of your consent or in order to fulfil a contract, you have
the right to request a copy of your data in a structured, commonly used and machine-readable
format, and to have that data transmitted directly to another organisation of your choice.

Right to Object

You have the right to object to the processing of your personal data in certain circumstances,
particularly where we are processing your data on the basis of legitimate interests. We must then
demonstrate that our reasons for processing outweigh your privacy interests, or that the processing
is necessary for the establishment, exercise or defence of legal claims.

Rights Related to Automated Decision-Making

You have rights in relation to automated decision-making and profiling. However, please see the
section titled “Automated Decision-Making” below.
Some of these rights may not apply in all circumstances, and we may decline a request where we
have a lawful reason to do so. If we refuse your request, we will explain our reasons.

How to Request Your Information

To exercise any of your data protection rights, please contact our Data Protection Manager:

Data Protection Manager
Digital Jersey
Ground Floor, Forum 4 Block 3
Grenville Street
St Helier
Jersey JE2 4UF
Email: dpm@digital.je
Telephone: 01534 488235

When you submit a request, please include as much detail as possible about the data you are
requesting or the action you wish us to take. Please also provide proof of your identity and address
so that we can verify that the request is coming from you or an authorised representative.

We will respond to your request as soon as possible, and in any event within four weeks of receipt of
your request. If your request is complex or if you have made multiple requests, we may extend this
period by a further eight weeks. If we decide to extend the response time, we will inform you of the
extension within the original four-week period and will explain the reasons for the delay.

If we are unable to fully comply with your request, we will explain the reasons and inform you of
your right to lodge a complaint with the Jersey Office of the Information Commissioner.

Right to Withdraw Consent

Where we process your personal data on the basis of your consent, you have the right to withdraw
that consent at any time. Withdrawal of consent will not affect the lawfulness of any processing we
have already carried out before you withdrew your consent.

To withdraw your consent, please contact our Data Protection Manager at dpm@digital.je or using
the contact details provided in the “How to Request Your Information” section above. We will
confirm receipt of your withdrawal and will cease processing your data for that purpose, unless we
have another lawful basis for continuing to process it.

Automated Decision-Making

We do not use automated decision-making or profiling in relation to your personal information. Any
decisions about you will be made by our staff following human review and consideration of all
relevant circumstances.

Changes to this Privacy Notice

We may update this privacy notice from time to time to reflect changes in our data processing
activities, legal obligations, or other relevant factors. When we make material changes, we will
inform you by updating the date of this notice and, where appropriate, by sending you a notification
email or displaying a prominent notice on our website or at our premises.

Your continued use of our services or engagement with us following publication of changes to this
notice will constitute your acceptance of those changes. We encourage you to review this notice
regularly to stay informed about how we handle your personal data.

The date of the current version of this notice is shown at the top of this document.

Complaints

If you are unhappy with how we have handled your personal data, or if you believe that we have
breached your data protection rights, you have the right to lodge a complaint with us and with the
relevant supervisory authority.

Complaint to DJ

In the first instance, we encourage you to contact our Data Protection Manager so that we can try to
resolve your concern:

Data Protection Manager
Digital Jersey
Ground Floor, Forum 4 Block 3
Grenville Street
St Helier
Jersey JE2 4UF
Email: dpm@digital.je
Telephone: 01534 488235
Registration number with JOIC: 110892

Complaint to the Supervisory Authority

If you are not satisfied with our response, or if you wish to lodge a complaint directly with the
supervisory authority, you may contact the Jersey Office of the Information Commissioner:

Jersey Office of the Information Commissioner
2nd Floor
5 Castle Street
St Helier
Jersey JE2 3BT
Telephone: +44 (0) 1534 716530
Email: enquiries@jerseyoic.je
Website: jerseyoic.org

You have the right to lodge a complaint with the Jersey Office of the Information Commissioner at
any time. You do not need to exhaust our internal complaints procedure first, although we would
appreciate the opportunity to resolve your concern directly with you.