Privacy Policy

Introduction

Switch respects your privacy and is committed to safeguarding your personal data.

This privacy notice outlines how we protect and safeguard your personal data when you visit our website, contact the team or when you appoint and start working with Switch as a provider and data processor.

The information we collect about you, if you agree to provide it, will allow us to contact you and send information to you about products and/or services where you have registered an interest.

• In providing us your information you hereby consent to us processing it for this purpose.
• We will not pass your information on to any third party without your express permission, except as defined herein for the provision of services that you have requested, other than authorities and the police in the event of any investigation.
• Email addresses and contact details are not shared with any third-party unless written consent has been explicitly granted.

By visiting our website, or by appointing Switch to fulfil a contract, you are consenting to the data collection and processing terms outlined in this policy. This policy supplements our standard terms of service. 

For the purposes of the General Data Protection Regulation (GDPR);

• the data controller is Switch.
• Switch is the data processor when acting on behalf of clients when appointed to fulfil or support a service.
• Switch may use third-party processors to deliver specific services (see Processors below).
   

Important information

Purpose of this notice

This privacy notice aims to give you information on how Switch collects and processes your personal data through your use of our website, including any data you may provide through the website or when you purchase a product or service.

This privacy notice supplements the other notices and is not intended to override them. Switch may provide on specific occasions when we are collecting or processing personal data about you as to ensure we are transparent and that you are aware of how and why we are using your data. Under no circumstances, will Switch process personal data for a purpose where no prior consent has not been granted.

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

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

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. Where personal contact details have been obtained, Switch will inform you of changes to this policy.
 

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 anonymised (removed).

We may collect, use, store and transfer different kinds of personal data about you as a user of our website, a subscriber of our electronic marketing communications, or as a prospect and client of Switch. The types of data we may collect about you have been 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 a 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 this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products, and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.
   

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract 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 goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
 

How your personal data is 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;
  • 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 some feedback.
     
• Automated technologies or interactions. As you interact with our website, we may 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.
   
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
  • Technical Data from the following parties:
    • analytics providers such as Google based outside the EU;
    • advertising networks based inside and outside the EU; and
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
  • Identity and Contact Data from data brokers or aggregators based inside and outside the EU.
     

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:


Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third-party direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.
 

Purpose and legal basis for processing your personal data

We have outlined 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.
 

Purpose	Type of Data	Lawful basis for processing
To register you as a new customer	Identity, Contact	Performance of a contract with you
To process and deliver your order inc. managing payments, fees and charges, collecting and recovering money owed to us	Identity, Contact, Financial, Transaction, Marketing and Communications	Performance of a contract with you, Necessary for our legitimate interests
To manage our relationship with you which will include: Notifying you about changes to our terms or privacy policy, or asking you to leave a review or take part in a survey or competition	Identity, Contact, Profile, Usage, Marketing and Communications	Performance of a contract with you, necessary to comply with a legal obligation, Necessary for our legitimate interests
To administer and protect our business and this/your website (inc. troubleshooting, data analysis, testing, maintenance, support, reporting and hosting of our/your data)	All data types	Necessary for our legitimate interest, Necessary to comply with a legal obligation
To deliver relevant website content and advertisements, measure or understand the effectiveness of the advertising served	Identity, Contact, Profile, Usage, Marketing and Communications, Technical, Aggregated	Necessary for our legitimate interest
To utilise data analytics to maximise the performance of our website, products/services, marketing, customer relationship and experiences	Technical, Usage, Aggregated	Necessary for our legitimate interest
To make suggestions and recommendations to you about goods or services that may be of interest to you	Identity, Contact, Technical, Usage, Profile, Aggregated	Necessary for our legitimate interest

Change of purpose

We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

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

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
 

Cookies

You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become not function properly.

For more information on which cookies we use and for what purpose, please refer to our cookie policy.
 

International transfers (transfer of personal data outside of the EU)

This site is accessible via the internet and therefore may potentially be accessed by anyone around the world. Other visitors may also access the site from outside Jersey and/or the European Union (EU)/European Economic Area (EEA).

Whenever we transfer your personal data out of the EEA, we ensure that an adequate level of protection to the GDPR and the Data Protection (Jersey) Law 2018 is enforced.

Many of our external third party processors, and indeed, many of the world’s leading technology and Software as a Service (SaaS) providers, are often based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. In such instances, we ensure the following criteria are met:

If you would like more information on our international transfer practices or mechanisms, please contact us via email at [email protected]
 

Data safeguards and security

We have adopted appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. On such safeguard that we have employed is that we limit access to your personal data to those employees, contractors and other third parties who require access to your personal; data to fulfil a contract with you. 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 identify, act and notify you (the data subject) and the regulator of any personal data breach where there is a legal obligation to do so.
 

Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying 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 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 requirements e.g. aggregated statistical data collected via our website is retained for 50 months.

If you would like more information on our data retention policies, please contact us via email at [email protected]
 

Your legal rights

Under the JERSEY-GDPR all individuals, who are the owners of their Personal Data, have specific and clear rights, which are;

 

Jersey-GDPR: Individual Rights	Description
Right to Erasure	Every individual has the right to be forgotten upon request. The data controller must remove your Personal Data from its systems and request the same of any third-party systems of that controller.
Right to Access	Every individual has the right to access their Personal Data held about them upon request.
Right to Portability	Every individual has the right to request their Personal Data and use it for other parties they wish to engage with.
Right to be Informed	Every individual has the right to be informed about how their Personal Data is being used, which may be provided upon request of the individual, or before the controller changes any use of that data, giving the individual the right to consent or object.
Right to Objection	Every individual has the right to object to the use of their Personal Data for any purpose proposed by a controller.
Right to Rectification	Every individual has the right to have errors in their Personal Data to be corrected.
Right to Restrict	Every individual has the right to restrict the uses of their Personal Data for any specific type of processing.
Rights on automated decisions and profiling	Every individual has the right to restrict or object to automated decision-making processes or profiling based on their Personal Data.

If you wish to exercise any of the rights set out above, please contact us.
 

Revoking your consent

In accordance with the JERSEY-GDPR, to revoke consent for the processing of your Personal Data send an email with the word "Revoke" in the subject field to [email protected]
 

Data Subject Access Request (DSAR)

In accordance with the JERSEY-GDPR, any DSAR is provided free of charge within 30 days, unless a particular DSAR is subject to other regulatory requirements as defined within the JERSEY-GDPR, in which case we will inform you as required by those specific regulations.
 

What we may need from you

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.
 

Data protection contact details

Our full details are:

• 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 or regulatory obligation.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
  • Full name of legal entity: Switch Digital (VisualEye Limited)
  • Name or title of data protection contact: Nathan Nicholls (Agency Director)
  • Email address: [email protected]
  • Postal address: Hillgrove House, 10 Hillgrove Street, St. Helier, Jersey. JE2 4SL.
  • Telephone number: +44 (0) 1534 866638

 

The current version of our privacy policy is v01.00 dated 25th May 2018.