Randalls Limited and Subsidiary Companies

PRIVACY NOTICE

 

This is our Privacy Notice and this sets out the basics.  In some cases you may have additional documents – contract, agreements or terms & conditions with more details specific to you.

 

On the left is the ICO guidance on what a Privacy Notice should contain, plus references to the legislation.  On the right is an explanation of what we do against each criterion.

What We Do

INTRODUCTION

Jersey Law Article 6 General Duties and accountability.

 

The Privacy Notice applies to Randalls Limited and subsidiary companies.

 

The Privacy Notice sets out we deal with your personal data.  We take privacy and security of your information seriously and will only use such personal information as set out in this privacy policy.

 

CONTROLLER

Identify and contact details of the controller and where Applicable, the controllers representative and DPR:

 

Information which is collected will be the responsibility of the Randalls Limited who will act as data controller in relation to your personal data.

 

If you have any questions in relation to this policy or data protection within please contact me:

 

Data Protection Representative (DPR) is

Kerry.Murray@randalls.je or call 01534 836700

What Data We Collect

Categories of Personal Data:

When visiting our website we collect basic contact information about you for the purpose of telling you about Randalls Limited and our subsidiary companies and their related services, for example loyalty card applications or requests for price lists and details of venues.

Jersey Law Article 10 Fair and Transparent processing:

For client/customers we hold confidential information necessary for us to be able to provide services. This includes for example information for contact and delivery.

We provide a full description of that data and our safeguards in our contracts or terms and conditions.

For Customers:

We will keep contract information in relation to the contract or terms and conditions in order for us to process orders or provide goods, services, information and to review and invoice payments.

For Suppliers:

As above, but we would expect us to be receiving the services and invoices rather than providing them.

Bespoke Needs:

If you have special needs, like anonymity, we can arrange that on discussion.

Where necessary we can provide a full description of that data and our safeguards in the client/customer contract.

 

WHAT PURPOSES WE USE YOUR PERSONAL DATA FOR:

 

Purpose of the processing and the legal basis for the processing:

We need to know information about you to be able to provide services and to operate the Randalls Loyalty Card Scheme and only use personal data where there is a legitimate interest in doing so.

 

Statutory Contractual :Requirements

Unless otherwise specified on contract or agreement, information is only for the purposes of provision of Randalls Limited services.

 

Where the provision of Personal data part of a statutory or contractual requirement or obligation and possible consequences of failing to provide the personal data:

We are bound by the Freedom of Information Act and will act in accordance with these for any States of Jersey contracts. However, we never share data unless there is legislation or regulation or express agreement to do so.

 

The existence of automated decision making, including profiling and Information about how decisions are made:

Automated Decisions:

We have no automated decision making or profiling of personal data.

 

Lawful basis: The legitimate interests of the controller or third party, where applicable:

Generally (unless otherwise specified on contract or agreement) this for the legitimate interests of Randalls Limited and subsidiary companies operation.

 

How Long we hold data:

Randalls Limited and subsidiary companies will retain your personal data for as long as necessary to fulfill the purpose for which it was collected.

 

Retention period or criteria used to determine the retention period:

In relation to contracts we are required to hold data for 10 years in accordance with Jersey’s statute of limitations. In relation to loyalty data, the retention term will be for 12 months following the last usage of the loyalty card.

 

Data Security:

Randalls Limited and subsidiary companies uses up-to-date data storage and security techniques to protect your personal information from unauthorized access, improper use or disclosure, unauthorized modification or unlawful destruction or accidental loss.

 

Data Sharing and Disclosure:

Generally (unless otherwise specified on contract or agreement) no data is shared with any other organization, except with explicit agreement. As above with relation to Freedom of Information relating to States of Jersey contracts.

 

Any recipient or categories of recipients of the personal data:

However, we never share data unless there is legislation or regulation or express agreement to do so.

 

Third Country Transfers and Safeguards:

Randalls Limited and subsidiary companies operate in Jersey.

However, we use technology which may transfer data to another jurisdiction, for example use of Microsoft and external back-up of data.

 

Details of transfers to third Country and safeguards:

Where such transfers to not offer the same level of protection of personal data as may be enjoyed within your home country (eg United States) we will ensure that your data is appropriately protected (for example by reference to IT security standards).

GDPR is a key consideration when selecting a service provider and we seek those that demonstrate that they will keep data private, safe and secure by reference to ISO27001, Cyber Essentials or similar standards.

 

YOUR RIGHTS:

The existence of each of data Subject’s rights:
The GDPR provides the following rights for individuals:
The right to be informed:
The right of access:
The right to rectification:
The right to erasure:
The right to restrict processing:
The right to data portability:
The right to object:
Rights in relation to automated decision making and profiling

 

More details can be found:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

 

The right to withdraw Consent at any time, where Relevant

We general hold data on the basis of legitimate interest (we need the data to run our business and provide our services and loyalty card scheme)

We do use contracts and Terms & Conditions to agree the exact terms of business. If you want us to stop, just tell us:

Email to: optout@randalls.je

 

The right to lodge a complaint with a supervisory authority

If you think we have got something wrong, please tell us.

But you can also tell the regulator: https://oicjersey.org/guidance

 

Concerns or Queries

If you have any questions in relation to this policy or data protection within please contact us at contacts@randalls.je

Data Processing Representative:

Kerry.Murray@randalls.je

Privacy Policy of randalls-jersey.co.uk

This website collects some Personal Data from its Users.

 

Owner and Data Controller

Data Processing Representative:

Kerry.Murray@randalls.je

Randalls Jersey
PO Box 43,
Clare House,
Clare Street,
St Helier,
JE4 9NB

Owner contact email: contact@randalls.je

 

Types of Data collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Cookies, Usage Data, first name, last name, date of birth, phone number, address, country, county, email address, ZIP/Postal code and website.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party’s consent to provide the Data to the Owner.

 

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

 

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

  • Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
  • provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
  • processing is necessary for compliance with a legal obligation to which the Owner is subject;
  • processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
  • processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

 

Place

The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.

Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

 

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

  • Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
  • Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

 

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Analytics and Contacting the User.

Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.

 

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

  • Analytics

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

 

Google Analytics (Google Inc.)

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.

 

Google Analytics with anonymized IP (Google Inc.)

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
This integration of Google Analytics anonymizes your IP address. It works by shortening Users’ IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.

  • Contacting the User

 

Contact form (this Application)

By filling in the contact form with their Data, the User authorizes this Application to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

Personal Data collected: address, country, county, date of birth, email address, first name, last name, phone number, website and ZIP/Postal code.

 

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

  • Withdraw their consent at any time.Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
  • Object to processing of their Data.Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
  • Access their Data.Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
  • Verify and seek rectification.Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
  • Restrict the processing of their Data.Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
  • Have their Personal Data deleted or otherwise removed.Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
  • Receive their Data and have it transferred to another controller.Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
  • Lodge a complaint.Users have the right to bring a claim before their competent data protection authority.

 

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

 

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

 

Additional information about Data collection and processing

 

Legal action

The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

 

Additional information about User’s Personal Data

In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

 

System logs and maintenance

For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) use other Personal Data (such as the IP Address) for this purpose.

 

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

 

How “Do Not Track” requests are handled

This Application does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

 

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within this Application and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

 

Definitions and legal references

Latest update: August 08, 2018