Privacy Policy

Benest & Syvret respects your privacy and is committed to protecting your personal data. This document sets out the Benest & Syvret’s privacy policy which we are required under data protection legislation to notify you of.   Please use the Glossary to understand the meaning of some of the terms used in this privacy policy.

BEAUTIFULLY SOLVED

1. PURPOSE OF THIS POLICY AND WHO WE ARE

Privacy Policy

This privacy policy aims to give you information on how Benest & Syvret collects and processes your personal data, including any data you may provide through our website or when you purchase a product or services from us.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions where we are collecting or processing personal data about you. This privacy policy supplements other notices and privacy policies and is not intended to override them.

2. The data We Collect About You

2. 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 first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

- Contact Data includes billing address, delivery address, email address and telephone numbers.

- Financial Data includes bank account and payment card details.

- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

- Technical Data includes 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 our website.

- Profile Data includes, your interests, preferences, feedback and survey responses.

- Usage Data includes information about how you use our website and services.

- Marketing Data includes your preferences in receiving marketing from us.

- Communications includes your preferences in receiving communication from us.

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 privacy policy.

Nor do we collect any information about criminal convictions and offences.

There may be circumstances where we need to collect Special Categories of Personal Data (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) and in such circumstance we will carry out a data privacy impact assessment.

3. How is Your Personal Data Collected?

3. 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 our client take on forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

- apply for our services;

- 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 and other similar technologies.

Third parties or publicly available sources. We will receive personal data about you from analytics providers such as Google or publicly available information such as information available from the Jersey Financial Services Commission or the Jersey Electoral Registers.

4. How We Use Your Personal Data

4. 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:-

- Where we need to perform the contract we are about to enter into or have entered into with you.
- 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 obligation.

Please refer to the Glossary, Lawful Basis, to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending 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.

5. DISCLOSURES OF YOUR PERSONAL DATA

5. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes set out in the table PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA above.

- External Third Parties as set out in the Glossary.

- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

6. INTERNATIONAL TRANSFERS

As part of the transfer of information with Third Parties, your personal data may be transferred to or accessed from countries who may not be the subject of an adequacy decision under Article 45 of the General Data Protection Regulation (GDPR) and therefore may not have the same level or type of statutory (or other legal) protection as countries within the European Economic Area (EEA). We will seek to ensure that transfers of data outside of the EEA comply with all applicable laws and regulations by ensuring that:

  • you have expressly consented to the cross border transfer;
  • the recipient is in a country which has been deemed to have an adequate level of protection under GDPR or equivalent legislation or if the recipient is in the United States of America, that they are part of the Privacy Shield; or
  • the recipient is contractually bound to protect the information to the same or higher standards as those within the EEA.

7. DATA SECURITY

7. 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.

8. DATA RETENTION

8. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Your physical files or an electronic copy of the same will be retained by us for a period of 20 years after we have completed the matter. This period allows for any relevant prescription period for contract or tortious liability to pass. If we are required to retain files to comply with longer prescription periods, protect essential documentation including wills, or to assist clients with providing copy documentation or providing details such as those required pursuant to the Rehabilitation of Offenders (Jersey) Law 2001, such files will be kept beyond the aforementioned 20 year period.

After that time we reserve the right to destroy your files whether held in hard copy or electronically which destruction you agree to unless we are specifically instructed by you not to. We reserve the right also to scan and store documents electronically, including your original signed documents, destroying the originals.

If your file contains any documents that may we may need to refer to in order to verify the accuracy of the Public Registry the file may be retained indefinitely.

Please note we are not obliged to maintain the hardware of the computer system upon which the files or records may be stored.

If instructed by you to retain the files for longer than 20 years we reserve the right to charge for such storage at a commercial rate. Where matters are completed and in storage we reserve the right to charge a retrieval fee where deemed appropriate should you wish to review documentation or should we be asked to review documentation.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data, which are as follows:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

- If you want us to establish the data’s accuracy.

- Where our use of the data is unlawful but you do not want us to erase it.

- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Should you wish to exercise any of the rights set out above, please contact our Data Protection Committee as set out above.

10. GLOSSARY

10. GLOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Consent in relation to direct marketing.

THIRD PARTIES

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© Benest & Syvret 2019 Privacy Policy

We Care About Your Privacy

The following website has been provided for information pertaining to Benest & Syvret and their services. The below information sets out how Benest & Syvret uses and protects the data collected via our website. When using this site, you are legally bound to the following privacy policy, so please read carefully. Privacy protection is something that Benest & Syvret are fully committed towards.

The Information We Collect

Many of our services may require the supply of personal information. When contacting us, we may ask for details such as your name, email address and telephone number. If you choose to register for our newsletter, we will require personal information including your name and email address.

What We Do With The Information

All of the information collected from the website is solely used for the purposes outlined in this document. We do not divulge any information to anyone outside of Benest & Syvret without prior consent from the website visitor – unless it is necessary to provide a requested service.

How We Make Your Information Secure

iPOP take every necessary step to ensure that your personal information is secure. We follow strict policies and follow best practice standards of security when collecting personal information. The website uses HTTPS (This is an adaptation of the Hypertext Transfer Protocol (HTTP) for secure communication over a computer network) to help protect against your personal information being stolen, destroyed or divulged to third parties. Your personal details are stored at our restricted offices which have no unauthorised access.

What We Collect

Through the use of contact forms, call back requests and newsletter sign-ups, we may collect, but are not limited to, the following information:

What We Do With The Information We Collect

We try our best to understand your needs and provide you a high level of service. We may use the information collected for the following reasons: Internal record keeping Improve our products using your email addresses, we will from time to time send you promotional emails with things that may be of interest to you, such as news, offers and industry related articles to customise the website according to your interests

How We Use Cookies

Cookies are files which can be placed onto your computer’s hard drive, with your prior consent. There are numerous benefits to having cookies placed on your hard drive. If you have accepted, cookies are used to identify when you visit a particular site, as well as analyse web traffic. Cookies also facilitate a more personal web experience, allowing web applications to gather information about your preferences, and respond to you as an individual.

Please visit: http://www.aboutcookies.org for more information on cookies.

At Benest & Syvret, traffic log cookies are used to identify the pages that are being used. From the data provided by these cookies, we can analyse the traffic to our website and tailor it to our customer’s needs. This information is only used for the purpose of statistical analysis and the betterment of your user experience. You can choose whether to accept cookies, or not. Many web browsers accept cookies. You can decline cookies in your browser settings if you wish. However, our website and many others may no longer function correctly.

If you accept cookies, we can see which pages our visitors find useful and which are not. This provides us information to be used for a better user experience. Cookies do not allow us to do anything untoward like gain access to your computer.

Cookies

This website uses the following cookies:

Google Analytics: This cookie allows us to see information on user website activities including, but not limited to page views, source and time spent on website. The information is anonymised and is displayed as numbers, meaning it cannot be tracked back to individuals. This will help to protect your privacy. Using Google Analytics we can see what content is popular on our website, and strive to give you more of the things you enjoy reading and watching.

Google AdWords: We use the Google Advertising platform to promote our services. The cookies from Adwords allow us to provide a better advertising experience

Facebook Advertising: We use Facebook advertising conversion tracking and retargeting pixels, which allows us to collect or receive information from your website and elsewhere on the internet and use that information to provide measurement services and target advertising.

DoubleClick: We use remarketing codes to log when users view specific pages, allowing us to provide targeted advertising in the future.

Email Marketing We Send May Contain Tracking Codes

If you have opted in to receive our newsletters, then this may include tracking codes that help us understand who, as well as how many people have opened or clicked on each email. This data helps us to create better emails in the future, and provide you with a better service. This data is stored on the servers of our email partners and covered under their security measures.

Third Party Links

This website may contain links to other websites. However, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting these sites and as such are not governed by this privacy statement.

Links

Hyperlinks on this site may be shortened to hide long links for functionality and tracking.

Controlling Your Personal Information

You may choose to restrict the collection or use of your personal information in the following ways: if you have previously agreed to us using your personal information for direct marketing purposes, you may opt-out at any time by emailing us which you can do via the website.

You may request details of personal information which we hold about you under the Data Protection Act 1998. A small fee will be payable. If you would like a copy of the information held then please contact us. If you notice or know that any information we are holding about you is incorrect, please write to or email us as at the address detailed on the website. We will correct any information you indicate to be incorrect as soon as possible.

How To Opt Out OF Cookies

To opt out of a third-party vendor’s use of cookies, visit the Network Advertising Initiative opt out page. If you want to opt out of our emails, fill in the contact form on our website. Please note that deciding to opt out of cookies for your browser may prevent webpages from functioning correctly. If you wish to disable cookies, please select the below image for your particular browser.

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Variations To The Policy

We reserve the right to alter and change information provided in this document at our own discretion and therefore this document should be regularly referred to for updates and variations. If you have any questions regarding this policy, our contact details are as follows:

16 Hill Street,
St Helier,
Jersey,
JE1 1BS

T: 01534 875 875
F: 01534 875 885

info@benestsyvret.com