Privacy Policy

Jersey War Tunnels Limited

Data Protection Privacy Notice for Visitors

What is the purpose of this document?

Jersey War Tunnels Limited is committed to protecting the privacy and security of your personal information.

This privacy notice describes how we collect and use any personal information that we hold on you, as a visitor to Jersey War Tunnels or its website at www.jerseywartunnels.com, in accordance with the Data Protection (Jersey) Law 2018.

It applies to all personal visitors to the Jersey War Tunnels and its website users, also to any tenants, donors and volunteers.

Jersey War Tunnels Limited is a "data controller". This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

This notice does not form part of any contract to provide services. We may update this notice at any time.

It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

Data protection principles

We will comply with data protection law. This says 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 that is 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 we have told you about.

6. Kept securely.

The kind of information we hold about you

Your “personal data” means any information which identifies you, or which can be identified as relating to you personally for example, name, address, phone number and email address.  We will only collect the personal data that we need. There are "special categories" of more sensitive personal data which require a higher level of protection.

We will collect, store, and use the following categories of personal information about you:

Personal data provided by you: 

  • Personal details (name, date of birth, email, address, telephone, and so on) when you purchase tickets.
  • Financial information (payment information such as credit or debit card or direct debit details).
  • Your opinions and attitudes about the Jersey War Tunnels, activities and interests, and your experiences of the Jersey War Tunnels.

We may automatically collect the following information: 

  • Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform and if you access our website via your mobile device we will collect your unique phone identifier.
  • Information about your visit, including, but not limited to the full Uniform Resource Locators (URL) and query string, clickstream to, through and from our website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as but not limited to scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.
  • Information about your purchases including but not limited to revenue figures and the types of products purchased.
  • The terms that you use to search our website.
How we will 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. Where we need to perform the contract we have entered into with you.

2. Where we need to comply with a legal obligation.

3. 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. 

We may also use your personal information in the following situations, which are likely to be rare:

1. Where we need to protect your interests (or someone else's interests).

2. Where it is needed in the public interest or for official purposes.

Situations in which we will use your personal information

We need all the categories of information in the list above primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests of our own, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below. We have indicated below the purpose or purposes for which we are processing or will process your personal information, as well as indicating which categories of data are involved.  

Below are the main uses of your data which depend on the nature of our relationship with you and how you interact with our various services, websites and activities:

  • Your personal data may be collected and used to help us complete your order, for example for the purchase of tickets.
  • If asked by the police, or any other regulatory or government authority investigating suspected illegal activities, we may need to provide your personal data.
  • We would like to send you marketing communications. If you choose to hear from us we may send you information based on what is most relevant to you or things you’ve told us you like. We may also show you relevant content online. This might be about visiting our visitor attraction or volunteering with us.  We’ll only send these to you if you agree to receive them and we will never share your information with companies outside the Jersey War Tunnels. We may however share cookie data with third parties to help with our own advertising targeting. If you agree to receive marketing information from us you can change your mind at a later date. However, if you tell us you don’t want to receive marketing communications, then you may not hear about events or other work we do that may be of interest to you.
  • CCTV is used to provide security and protect both our staff and visitors, as well as Jersey War Tunnels.  CCTV will be only be viewed when necessary (e.g. to detect or prevent crime) and footage is stored for set period of time after which it is recorded over.  
  • Personal data provided to us may also be profiled to help us with advertising targeting. For example we may use your personal data to find online users with a similar profile to yourself who may be interested in our products or services.
  • We may sometimes use third parties to capture some of our data on our behalf, but only where we are confident that the third party will treat your data securely, in accordance with our terms and inline with the requirements set out in the General Data Protection Regulations.
  • We sometimes carry out research with our supporters, customers, staff and volunteers to get feedback on their experience with us. We use this feedback to improve the experiences that we offer and ensure we know what is relevant and interesting to you. If you choose to take part in research, we’ll tell you when you start what data we will collect, why and how we’ll use it. All the research we conduct is optional and you can choose not to take part. For some of our research we may ask you to provide sensitive personal data (e.g. ethnicity). You don’t have to provide this data and we also provide a ‘prefer not to say’ option. We only use it at an aggregate level for reporting (e.g. equal opportunities monitoring). We may give some of your personal data (e.g. contact information) to a research agency who will carry out research on our behalf.  
  • We consider it important to use our resources in a responsible and cost-effective way. We therefore use automated profiling and targeting to help us understand our supporters and make sure that:
    • our communications (e.g. emails) and services (e.g. our website) are relevant, personalised and interesting to you;
    • our services meet the needs of our supporters; and
    • we use our resources responsibly and keep our costs down.
  • We use specific tools to profile how you interact with us online, for example, Google Analytics and Double Click for Advertisers. Much of the information we collect is aggregated, however we may also collect some personal data for the use of personalising your experience, optimising our marketing campaigns, and to ensure the site is functioning as intended.
  • This analysis may be carried out by us or by third party organisations working for us.  We may also host encrypted personal data on third party websites (e.g. social media platforms) to ensure that you only see relevant, personalised and interesting content from those organisations. 
If you fail to provide personal information

If you fail to provide certain information when requested or to keep us up to date with changes to your information, we may not be able to perform the contract requested by you for example the sale of a ticket to our visitor attraction. 

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 we will explain the legal basis which allows us to do so. 

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

How we use particularly sensitive personal information 

"Special categories" of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. We may process special categories of personal information in the following circumstances:

1. In limited circumstances, with your explicit written consent.

2. Where it is needed in the public interest, such as for equal opportunities monitoring.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public. 

At times we’ll collect sensitive personal data for equal opportunities monitoring, as well as researching whether we deliver great experiences for everyone, but this is only ever analysed at an aggregate level.

Do we need your consent?

We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.

Your consent will be required to provide you with marketing information. 

Automated decision-making

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:

1. Where we have notified you of the decision and given you 21 days to request a reconsideration.

2. Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.

3. In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.

If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.

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.

Data sharing

We may have to share your data with third parties, including third-party service providers and other entities in the group.

We require third parties to respect the security of your data and to treat it in accordance with the law.

We may transfer your personal information outside Jersey.

If we do, you can expect a similar degree of protection in respect of your personal information.

Why might you share my personal information with third parties?

We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so. 

Which third-party service providers process my personal information?

"Third parties" includes third-party service providers (including contractors and designated agents) and other entities within our group. In relation to visitors the only such relevant third parties are IT service business.  

How secure is my information with third-party service providers and other entities in our group?

All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

When might you share my personal information with other entities in the group?

We may share your personal information with other entities in our group as part of our regular reporting activities related to company performance, in the context of a business reorganisation or group restructuring exercise, or for system maintenance support and hosting of data.

What about other third parties?

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.

Transferring information outside the EU

We will not transfer the personal information we collect about you outside the European Union, Guernsey or Jersey. There is an adequacy decision by the European Commission in respect of these countries. This means that the countries to which we transfer your data are deemed to provide an adequate level of protection for your personal information. These jurisdictions may not have similar levels of protection in relation to personal data and where this happens we will not transfer personal information without putting safeguards in place which are similar to those in place in Jersey or with your explicit consent.      

Data security

We have put in place measures to protect the security of your information. Details of these measures are available upon request.

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

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

Data retention

How long will you use my information for?

We will only retain your personal information 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. Details of retention periods for different aspects of your personal information are available in our retention policy which is available from the Manager. 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.

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. 

Rights of access, correction, erasure, and restriction 

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us. 

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

  • 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 we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • 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 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).
  • Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party. 

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the Company Secretary of Jersey War Tunnels Limited in writing.

No fee usually required

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 your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

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 the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

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, please contact the Company Secretary. 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.

Data protection reporting officer

We have appointed a data protection reporting officer to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the Company Secretary. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), Jersey’s supervisory authority for data protection issues.

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information. 

If you have any questions about this privacy notice, please contact Company Secretary by email on haley.blampied@jerseywartunnels.com.