Privacy and data protection policies

JTRS Privacy Policy

Effective date: May 13, 2018

JTRS Ltd ("us", "we", or "our") operates the https://www.jtrs.co.uk website (the "Service").

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from https://www.jtrs.co.uk

Definitions
Service

Service is the https://www.jtrs.co.uk website operated by JTRS Ltd

Personal Data

Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

Usage Data

Usage Data is  data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Cookies

Cookies are small pieces of data stored on your device (computer or mobile device).

Data Controller

Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.

For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.

Data Processors (or Service Providers)

Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.

We may use the services of various Service Providers in order to process your data more effectively.

Data Subject (or User)

Data Subject is any living individual who is using our Service and is the subject of Personal Data.

Information Collection And Use

We collect several different types of information for various purposes to provide and improve our Service to you.


Types of Data Collected
Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data").  Personally  identifiable information may include, but is not limited to:

  • Email address

  • First name and last name

  • Phone number

  • Address, State, Province, ZIP/Postal code, City

  • Cookies and Usage Data

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.

Usage Data

We may also collect  information  how the Service is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Tracking Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.

Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

  • Session Cookies. We use Session Cookies to operate our Service.

  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.

  • Security Cookies. We use Security Cookies for security purposes.


Use of Data

JTRS Ltd uses the collected data for various purposes:

  • To provide and maintain our Service

  • To notify you about changes to our Service

  • To allow you to participate in interactive features of our Service when you choose to do so

  • To provide customer support

  • To gather analysis or valuable information so that we can improve our Service

  • To monitor the usage of our Service

  • To detect, prevent and address technical issues

  • To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information


Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)

JTRS Ltd may process your Personal Data because:

  • We need to perform a contract with you

  • You have given us permission to do so

  • The processing is in our legitimate interests and it's not overridden by your rights

  • To comply with the law


Retention of Data

JTRS Ltd will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

JTRS Ltd will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

Transfer Of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside the United Kingdom and choose to provide information to us, please note that we transfer the data, including Personal Data, to  the United Kingdom and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

JTRS Ltd will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.


Disclosure Of Data
Business Transaction

If JTRS Ltd is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Disclosure for Law Enforcement

Under certain circumstances, JTRS Ltd may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements

JTRS Ltd may disclose your Personal Data in the good faith belief that such action is necessary to:

  • To comply with a legal obligation

  • To protect and defend the rights or property of JTRS Ltd

  • To prevent or investigate possible wrongdoing in connection with the Service

  • To protect the personal safety of users of the Service or the public

  • To protect against legal liability


Security Of Data

The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Your Data Protection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. JTRS Ltd aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.

The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.

The right to object. You have the right to object to our processing of your Personal Data.

The right of restriction. You have the right to request that we restrict the processing of your personal information.

The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.

The right to withdraw consent. You also have the right to withdraw your consent at any time where JTRS Ltd relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).


Service Providers

We may employ third party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/


Behavioral Remarketing

JTRS Ltd uses remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Service.

Google AdWords

Google AdWords remarketing service is provided by Google Inc.

You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads

Google also recommends installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout - for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/

Twitter

Twitter remarketing service is provided by Twitter Inc.

You can opt-out from Twitter's interest-based ads by following their instructions: https://support.twitter.com/articles/20170405

You can learn more about the privacy practices and policies of Twitter by visiting their Privacy Policy page: https://twitter.com/privacy

Facebook

Facebook remarketing service is provided by Facebook Inc.

You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950

To opt-out from Facebook's interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217

Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.

For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation


Links To Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.


Children's Privacy

Our Service does not address anyone under the age of 18 ("Children").

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.


Changes To This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.


Contact Us

If you have any questions about this Privacy Policy, please contact us:

By email: gdpr@jtrs.co.uk

By visiting this page on our website: https://www.jtrs.co.uk/page/contactus

By phone number: 03302230500

By mail: Suite 1 Fulshaw Hall, Alderley Road, Wilmslow, Cheshire SK9 1RL


JTRS data protection Policy


Context and Overview


Key Details

Policy approved by Senior Management Team on: 22nd May 2018

Next review date: July 5th


Introduction

JTRS Ltd needs to gather and use certain information about individuals.

These individuals can include customers, suppliers, business contacts, employees and other people the organisation has a relationship with.

This policy describes how this personal data must be collected, handled and stored to meet the company’s data protection standards and to comply with the general data protection regulation.


Why this policy exists

This data protection policy ensures JTRS Ltd:

  • Complies with data protection law and follows good practices

  • Protects the rights of staff, customers and partners

  • Is open about how it stores and processes individuals data

  • Protects itself from the risks of a data breach


Data protection law

The General Data Protection Regulation describes how organisations including JTRS Ltd must collect, handle and store personal information.

These rules apply regardless of whether data is stored electronically, on paper or on other materials.

To comply with law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.

Data Protection is underpinned by eight important principles. These say that personal data must:

  • Be processed fairly and lawfully

  • Be obtained for specific, lawful purposes

  • Be adequate, relevant and not excessive

  • Be accurate and kept up to date

  • Not be held for any longer than necessary

  • Processed in accordance with the rights of data subjects

  • Be protected in appropriate ways 

  • Not be transferred outside the European Economic Area, unless that country or territory also ensures an adequate level of protection.


People, risks and responsibilities


Policy Scope

This policy applies to:

  • The head office of JTRS Ltd

  • All branches of JTRS Ltd

  • All staff of JTRS Ltd

  • All Contractors, suppliers and other people working on behalf of JTRS Ltd


It applies to all data that the company holds relating to identifiable individuals, this can include:

  • Names of individuals

  • Postal addresses

  • Email addresses

  • Telephone numbers

  • Plus and pther information relating to individuals 


Data protection risks

This policy helps to protect JTRS Ltd from some very real data security risks, including:

  • Breaches of confidentiality. For instance,  information  being given out inappropriately

  • Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.

  • Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.


Responsibilities

Everyone who works for or with JTRS Ltd has some responsibility for ensuring data is collected, stored and handled appropriately.

Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.

However, these people have key areas of responsibility:


The Board of Directors are ultimately responsible for:

  • Ensuring that JTRS Ltd meets its legal obligations

  • Keeping JTRS Ltd up to date regarding data protection responsibilities, risks and issues

  • Reviewing all data protection procedures and related policies, in line with an agreed schedule

  • Arranging data protection training and advice for the people covered in this policy

  • Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data


The Technical Director is responsible for:

  • Ensuring all systems, services and equipment used for storing data meets acceptable security standards

  • Performing regular checks and scans to ensure security hardware and software is functioning properly

  • Evaluating any third party services the company is considering using to store or process data. For instance, cloud computing services.


The Marketing Director is responsible for:

  • Approving any data protection statements attached to communications such as emails and letters

  • Addressing any data protection queries from media outlets

  • Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.


General staff guidelines
  • The only people able to access data covered by this policy should be those who need it for their work

  • Data should not be shared informally. 

  • JTRS Ltd will provide training to all employees to help them understand their responsibilities when handling data.

  • Employees should keep all data secure, by taking sensible precautions and following the guidelines below.

  • In particular, strong passwords must be used and they should never be shared.

  • Personal data should not be disclosed to unauthorised people, either within the company or externally.

  • Data should be reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.

  • Employees should request help from their line manager if they are unsure about any aspect of data protection or our GDPR Manager


Data storage

These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the Technical Director.


When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.

These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:

  • When not required, the paper or files should be kept in a locked drawer or filing cabinet.

  • Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer/desk.

  • Data printouts should be shredded and disposed of securely when no longer required.


When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:

  • Data should be protected by strong passwords that are changed regularly and never shared  between  employees.

  • If data is stored on removable media (like a USB, CD or DVD) these should be kept locked away securely when not being used.

  • Data should only be stored on designated drives/servers and should only be uploaded to approved cloud computing services.

  • Servers containing personal data should be sited in a secure location, away from general office space.

  • Data should be backed up frequently. Those backups should be tested regularly, in line with the company’s standard backup procedures.

  • Data should never be saved directly to laptops or other mobile devices like tablets or smartphones.

  • All servers and computers containing data should be protected by approved security software and a firewall.


Data use

Personal data is of no value to JTRS Ltd unless the business can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:

  • When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.

  • Personal data should not be shared informally. In particular, it should never be sent by email, as this form of communication is not secure.

  • Data must be encrypted before being transferred electronically. The IT manager can explain how to send data to authorized external contacts.

  • Personal data should never be transferred outside of the European Economic Area.

  • Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.

Data  Accuracy

The law requires JTRS Ltd to take reasonable steps to ensure data is kept accurate and up to date.

The more important it is, that the personal data is accurate, the greater the effort JTRS Ltd should put into ensuring its accuracy.

It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.

  • Data will be held in  as  few places as necessary. Staff should not create any unnecessary additional data sets.

  • Staff should take every opportunity to ensure data is updated. For instance, by confirming customers details when they call.

  • JTRS Ltd will make it easy for data subjects to update information JTRS Ltd holds about them. 

  • Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it should be removed from the database.

  • It is the marketing managers responsibility to ensure marketing databases are checked against industry suppressions files every six months.


Subject access requests

All individuals who are the subject of personal data held by JTRS Ltd are entitled to:


  • Ask what information the company holds about them and why.

  • Ask how to gain  access  it.

  • Be informed how to keep it up to date.

  • Be informed how the company is meeting its data protection obligations/


If an individual contacts the company requesting this information, this is called a subject access request.

Subject access requests from individuals should be made by email to gdpr@jtrs.co.uk. JTRS Ltd will supply a standard request form, although individuals do not have to use this.

JTRS Ltd will aim to provide the relevant data within 14 days but may take up to 30.

JTRS Ltd will always verify the identity of anyone making a subject access request before handing over any information.


Disclosing data for other reasons

In certain circumstances, personal data may need to be disclosed to law enforcement agencies without the consent of the data subject.

Under these circumstances, JTRS Ltd will disclose requested data. However, they will ensure the request is legitimate, seeking assistance from the company’s legal advisers where necessary.



Providing information

JTRS Ltd aims to ensure that individuals are aware that their data is being processed, and that they understand:

  • How the data is being used

  • How to exercise their rights


To these ends, the company has a privacy policy inline with GDPR, setting our how data relating to individuals is used by the company.