Privacy Policy

Network Distribution (Jersey) Limited, referred to as 'Webreality', 'we' or 'our', is committed to protecting the privacy and security of your personal information.

This Privacy Notice describes how we collect and use personal information about you during and after your relationship with us under the Data Protection (Jersey) Law 2018 (the “DPJL”.)

Webreality is a "Data Controller", which means we are responsible for deciding how we hold and use personal information. 

We are required under data protection legislation to notify you of the information contained in this Privacy Notice.

Webreality is registered with the Jersey Office of the Information Commissioner – Registration No. 18687.

We will comply with data protection law, the principles of which say that the personal information we hold about you must be:

1. Used lawfully, fairly and in a transparent way
2. Collected only for valid purposes that we have clearly explained to you and not used in any way incompatible with those purposes
3. Relevant to the purposes we have told you about and limited only to those purposes
4. Accurate and kept up to date
5. Kept only as long as necessary for the purposes for which we collected it
6. Kept securely.

Webreality is accountable to you and to the relevant authorities to show compliance with the data protection laws and to demonstrate how we are compliant. 

The Data Protection Officer ("DPO")

We have appointed a DPO to oversee compliance with this Privacy Notice.

If you have any questions about this Privacy Notice or how we handle your personal information, contact the DPO at dataprotection@webreality.co.uk.

You have the right to make a complaint at any time to the Jersey Office of the Information Commissioner, whose contact details are outlined at the bottom of this Privacy Notice.

How is your personal information collected?

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 collect personal information about you when you complete a form on our site, communicate with us by email, letter or other methods, enter into a contract with us or report a problem on our site, or when you provide us with your data for another specific purpose.

What information do we collect about you?

Depending on the nature of the relationship between you and Webreality, we might collect any of the following: 

• Name
• Title
• Address
• Financial data
• Signature
• Email address
• Phone number
• Company
• Bank details

What special category data do we collect about you?

Webreality does not collect special category data as part of its usual data processing activities for its own purposes.

When, as a sub-processor, we collect special category data on behalf of a specific client, that client’s own Privacy Notice will describe on what terms such processing is undertaken.

How will we use information about you?

We will only use your personal information when the law allows us to. 

Most commonly, we will use your personal information in the following circumstances:

1. You have entered into a contract with us to provide you with a service; an example of this would be when you register to use one of our services. 
2. We need to comply with a legal obligation; an example of this would be when we have to comply with lawful authority to disclose information to the Police.
3. Where it is necessary for our legitimate interests (or those of a third party), your interests and fundamental rights do not override those interests. An example of this is when we investigate any suspected breach of our Terms of Use made by you or otherwise relating to you. 

We may also use your personal information in the following situations:

1. Where you have given your consent to contact you for a specific purpose.
2. In an emergency, it is in your vital interest to share your information when we have it recorded.

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. 

If we need to use your personal information for an unrelated purpose, we will notify you and explain the legal basis that allows us to do so.

Data sharing

We may, on occasions, pass your personal information to an organisation outside of Webreality exclusively to process on our behalf; these organisations are called Data Processors.  

We require these parties to agree to process this information based on our instructions and requirements consistent with this Privacy Notice.

We do not pass on information gained from your engagement with us without a clear legal basis for doing so. However, we may disclose your Personal Information to meet legal obligations, regulations, or valid governmental requests such as a Police request for information in evidence. 

The personal data we collect from you may be transferred to and stored at a destination outside the European Economic Area ("EEA"). 

It may also be processed by companies outside the EEA who work for one of our service providers, or for us.

If we do this, we ensure that your privacy rights are respected in line with this Policy and the same protection is given to your personal information as laid down by the DPJL. 

Data security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, altered or disclosed, or accessed in an unauthorised way. In addition, we limit access to your personal information to those Colleagues, Agents, Contractors and other third parties on a need to know basis. 

They will only process your personal information on our strict instructions, and they are subject to a duty of confidentiality. 

Details of these measures may be obtained from our Data Protection Officer (DPO).

We have put in place procedures to deal with any suspected data security breach and notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data retention

We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements. 

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 data, 
• the purposes for which we process your data, and whether we can achieve those purposes through other means, and 
• the applicable legal requirements. 
  
  

You can request our Data Retention Schedule from our DPO if required.

In some circumstances, we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. 

Access to and control of your personal information

You may have certain legal rights in respect of the personal information which is processed by Webreality pursuant to the DPJL, including:

• the right of access
• the right to have your data corrected, updated, rectified or erased
• the right to object to the processing of, or to restrict the processing of, your data 
• the right to withdraw your consent previously given to the processing of your data, and 
• the right to request the transfer of your data to another party.
  
  

Please note that the rights set out above are subject to certain exemptions and conditions. We may decline to comply with any request to access, correct, delete or restrict the use of your information if there is a specific legal ground or exemption.

Where we are processing your information on the basis of contractual necessity, or a legal or regulatory requirement, it is likely that the provision and processing of such information will be mandatory. In addition, where the provision of your personal information is generally a contractual or legal requirement, or is a requirement in order for us to enter into a contract, in the event that you choose not to provide any personal information or to exercise one or more of the rights above to restrict the processing of your information, this may restrict the services which Webreality is able to provide. 

Should you wish to exercise any of your rights, you should send your request to dataprotection@webreality.co.uk. We will respond to your request in accordance with the applicable data protection legislation.

Data Subject Access Requests (DSARs)

You can use the data subject access request form available on our cookie banner, or click here and complete our online form. If you have any questions about this process or any of your rights, contact our DPO at dataprotection@webreality.co.uk. You can also email your request, send us a request in writing by post, or make your request over the telephone orally to a member of our team.

We reserve the right to ask for proof of your identity and address, and we also further reserve the right, in accordance with the DPJL, to request additional information reasonably required to verify the specific information being requested or referred to, or any additional information reasonably required to confirm your identity.

We will respond to your request without undue delay, but certainly within four weeks after satisfactory verification of your identity. In some circumstances we can apply an eight-week extension to this time frame if the request is complex in nature, and it cannot be answered in the four-week time frame. If this were to happen, we would inform you as soon as possible.

Right to withdraw consent 

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. 

To withdraw your consent, contact our DPO at dataprotection@webreality.co.uk.

Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to unless we have another legitimate basis for doing so in law.

Complaints

We want the chance to resolve any complaints you have about how we process your information. Please therefore in the first instance contact our DPO at dataprotection@webreality.co.uk. You have the right to complain to the Jersey Office of the Information Commissioner about how we have used your data.

Contact details

Webreality

Commercial House, Commercial Street, St Helier, Jersey JE2 3RU.

Telephone +44 (0) 1534 488 888 or Email: dataprotection@webreality.co.uk.

Jersey Office of the Information Commissioner

2nd Floor, 5 Castle Street, St Helier, Jersey JE2 3BT. 

Telephone +44 (0) 1534 716530 or Email: enquiries@jerseyoic.org