JT Group Limited Privacy Notice

Welcome to JT Group Limited’s privacy policy (the “Policy”). This Policy applies to JT Group Limited, whose current registered office is  No.1 The Forum, Grenville Street, St Helier, Jersey, JE4 8PB (company number 84230) (“JT”), a telecommunications provider, and all its subsidiaries (“we”, “us” and together the “JT Group”). JT’s current subsidiaries (minus the “Internet of Things”/IOT subsidiaries; for more information on those companies please visit www.jtiot.com) are:

ekit.com Pty Limited
Level 18
530 Collins Street
Melbourne VIC 3000 Australia
Australian company no: 082 138 574

Jersey Telecom (UK) Limited
Forum 4 Solent Business Park
Whiteley, Farnham
Hampshire, England PO15 7AD
E&W company no: 3874568

ekit.com, Inc.
2 Mill Road
Suite 108 Wilmington New Castle Delaware 19806 USA
US (Delaware) company no: 3010998

JT (Global) Limited
Forum 4 Solent Business Park
Whiteley
Fareham, Hampshire, England PO15 7AD
E&W company no: 7476338

JT (Australasia) Pty Limited
Level 18
530 Collins Street
Melbourne VIC 3000 Australia
Australian company no: 625 345 977

JT (Guernsey) Limited
PO Box 286
Floor 2 Trafalgar Court
Les Banques
St Peter Port
Guernsey GY1 4LY
Guernsey company no: 39971

JT (Jersey) Limited
No 1 The Forum Grenville Street St Helier
Jersey JE4 8PB
Jersey company no: 83487

JT (International) Limited
No 1 The Forum Grenville Street St Helier
Jersey JE4 8PB
Jersey company no: 84169

JT Group respects your privacy and is committed to protecting your personal data. This Policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from), how we look after and process your personal data when you are a customer of JT or the JT Group (and are subject to the relevant Contract/Conditions), and will also tell you about your privacy rights and how the law protects you.

Important information and who we are

Purpose of this Policy

This is the Policy referred to in the various JT Terms and Conditions. It is applicable to our products and services (the “Conditions“). Terms defined in the relevant Conditions shall have the same meaning in this Policy. Unless, this is otherwise defined in this Policy.

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

In addition, this Policy aims to give you information on how the JT Group collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase a product or service or take part in a competition.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Policy supplements other notices and privacy policies and is not intended to override them.

Controller

JT as the parent of the JT Group is a ‘data controller’, with each subsidiary capable of being the ‘data controller’, depending on what entity you have the relationship with. 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 Group so when we mention JT, “we”, “us” or “our” in this Policy, we are referring to the relevant company in the JT 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 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.

Contact details

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 Group Limited/JT Group

Email address: dpo@jtglobal.com

Postal address: JT Group 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.

Changes to the privacy policy and your duty to inform us of changes

We keep our Policy under regular review. This version was last updated on 20^th 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.

Third-party links

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/notices. When you leave our website, we encourage you to read the privacy policy of every website you visit.

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 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.
• Automated technologies or interactions. As you interact with our website, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
• 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
  • Hubspot
  • Dotdigital

• 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:

1. 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);
2. Dealing with complaints or enquiries in relation to the use of the Service (Performance of a contract or legitimate interests with LIA completed);
3. Assisting the emergency services in an emergency (legitimate interests with LIA completed and, in some circumstances, vital interests);
4. Debt collection, credit referencing and preventing fraud, theft and other unlawful activity (legitimate interests with LIA completed); and
5. 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.

Marketing

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.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

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 may disclose your personal information to members of the JT Group. JT may also disclose it to external third parties, to include: partners, suppliers, sub-contractors or agents engaged by JT for the purpose of performing the Contract and providing the Service. Other parties engaged to perform services for, or on behalf of JT; 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; potential third party buyers in relation to M&A processes within the JT Group; and commercial partners for joint promotions with that third party. JT 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 is authorised. Or if it is required, by law to do so. If there is a change (or expected change) in who owns JT or any of JT’s assets, JT might also share personal information to the new (or prospective) owner. If JT does, that party will have to keep the shared information confidential

International Transfers

JT 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 Group, a JT supplier or a service provider is based outside Jersey, Guernsey and the EEA. Or, if you use JT’s services and products while visiting countries outside these jurisdictions. If JT sends your information to a jurisdiction that is not in the EEA or the Channel Islands, JT will make sure that your information is properly protected. JT 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 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, 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.
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.
6. Request the transfer of your personal information to another party.

Data security

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 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 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.

Cookies

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