In May 2018, Jersey introduced Data Protection Law with equivalent principles to the European General Data Protection Regulations (“GDPR”). The Data Protection (Jersey) Law 2018 brings equivalence to the principles of the GDPR. This means that individuals privacy rights will be strengthened and your information will be safer.
We are registered with the Office of the Information Commissioner (registration number 67889). All Personal Data is held and Processed by us strictly in accordance with the provisions of the Data Protection (Jersey) Law 2018 and the Data Protection Authority (Jersey) Law 2018.
By instructing us to provide you with our Services you warrant and undertake that you have obtained the requisite consent to enable all such Personal Data to be used, disclosed and otherwise Processed by us for the purposes of performing the Services and any compatible supporting functions.
means any applicable law, order, regulation, rule, order of court, code or similar in any jurisdiction, as amended, reenacted or modified from time to time and the law governing these Terms & Conditions, including but not limited to the Data Protection (Jersey) Law 2018 and the Data Protection Authority (Jersey) Law 2018;
means any agreement between Virteffic and the Client to which these Terms & Conditions apply;
(or “you” or “yours”)
means the person, company, firm or organisation to whom Virteffic agrees to provide the Services in accordance with the Agreement and these Terms & Conditions;
means all information that a Party discover because of or through the relationship created between the Parties under the Agreement and which is about or relating to the business of each Party (including information of the business, affairs, customers, products, developments, operations, Processes, pricing, networks, trade secrets, design rights, know-how and financial information, products, Services, service levels, customer satisfaction, proposed Services and products, pricing, and margins) or the people connected to the Party (including the directors or partners, investors, staff, suppliers, customers, clients, prospects and contractors) but excludes information that is openly published by such Party, or information that is publicly available without breach of our confidentiality obligation;
means all fees payable by the Client to Virteffic as set out in the Agreement, or as otherwise agreed in Writing;
shall not imply any limitation on the generality of the concept or thing of which examples are being given;
includes a natural person, corporate or unincorporated body (whether or not having separate legal personality);
has the meaning as defined in Article 2 of the Data Protection (Jersey) Law 2018;
Process or Processing or Processes
when applied to Personal Data, will include (without limitation) the collection, organisation, recording, storage, altering, using and disposal of Personal Data;
Party or Parties
refer to the Parties to the Agreement;
means any service rendered by Virteffic to the Company, pursuant to or in connection with any Agreement and the Services to be provided by Virteffic to the Customer under the Agreement as specified in the Fee Schedule
Terms & Conditions
means these standard terms and conditions;
(or “we” or “our” or “us”)
means Virteffic Limited, trading as Virteffic, a company registered in Jersey with registered number 132020 whose registered office is at Norowsa, La Vallee de St Pierre, St Lawrence, Jersey JE3 1EG; and
shall be construed as written or represented by any means reproducible in writing, including any form of print, email, facsimile or photograph or represented by any other substitute or format for storage or transmission for writing or partly one and partly another.
Words imparting the singular number shall include the plural and vice versa.
References to any gender shall include the other gender and the neuter.
What sort of personal information do we collect?
The type of personal information which we collect will vary significantly depending on numerous factors, including your personal circumstances, the nature of your relationship with us, and the nature of Services we are asked to perform. The personal information we obtain can be grouped into the following categories:
Your contact details such as title, name, job title, postal address, email address and phone number, demographic information such as postcode, preferences and interests and any other information you provide by filing in a form on our site. This includes information provided at the time of registering to use our site, subscribing to our service or requesting further Services. We may also ask you for information when you report a problem with our site.
Information about you which we obtain in order to provide Services to corporate clients. Depending on the circumstances and the nature of your relationship with us, such information may include, without limitation, your assets and liabilities, any directorships / partnerships you hold action we take towards you based on the instruction we received from our corporate clients, and information about your personal circumstances.
Details of your visits to our site
Social media, blogs, reviews
Any social media posts or comments you send to us (for example on the Virteffic Facebook page, Viteffic’s Twitter page etc.) will be shared under the terms of the relevant social media platform on which they are written and could be made public. We have no control over that policy or the terms of such social media platforms, including but not limited to Facebook, Instagram, Twitter, LinkedIn, Pinterest, as other people, not us, control these platforms. We are not responsible for this kind of sharing. We recommend you should review the terms and conditions and privacy policies of the social media platforms you use. That way, you will understand how they will use your information, what information relating to you they will place in the public domain, and how you can stop them from doing so if you are unhappy about it.
Any blog, review or other posts or comments you make about us and our Services on our blog, reviews or user community Services will be shared with all other members of that service and the public at large. Any comments you make on these Services and on social media in general must be not offensive, insulting or defamatory. You are responsible for ensuring that any comments you make comply with any relevant policy on acceptable use of those Services.
How we use your Personal Data and the legal basis for doing so
We require this information to understand your needs and provide you with a better service, and in particular for the following purposes:
Our legitimate business interest to facilitate the provision of our Services to you. Further information about the relevant Services we provide is available at https://virteffic.com/services/.
Internal management, administrative and organisational purposes
We may keep you information for internal record keeping. This includes maintaining internal records and carrying out other business administration tasks, and to facilitate the effective management and administration of our business, including in relation to matters such as business planning, budgeting, and forecasting, as well as enforcement of our Terms & Conditions of service and collection our Fees. We do so in relation to our legitimate business interest to Process your Personal Data in order to manage our business Processes.
Development and Improvements
We may use the information to improve our Services and/or to develop new products and Services.
Marketing about our Services, our news and events
We may periodically send promotional emails about new Services, special offers or other information which we think you may find interesting using the email address which you have provided, including sending you our news emails, information about our Services, related information which may be of interest to you and to invite you to our events. We would do so to promote the Services we offer and in respect of our legitimate business interest to send you marketing and promotional materials from time to time. Where we have obtained your consent to send marketing then we instead rely on consent as the legal basis. You can tell us to stop sending you marketing information at any time by objecting or withdrawing your consent. You can do so by contacting email@example.com or by using the unsubscribe link in any marketing email you receive from us.
Research, statistics and other data analysis
From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone or mail. We may use the information to customise the website according to your interests. We may also create forecasts and business plans, improving our service and developing new Services. We consider this our legitimate business interest to Process your Personal Data to develop and improve our business through aggregated and anonymised reporting analysis.
To manage, maintain, and develop our relationship with our clients.
Carrying out due diligence
Sharing data with other third Parties
Including third Parties who Process Personal Data on our behalf. We refer to our legitimate business interest to share your data with trusted third Parties who provide us with Services relating to our provision of Services to you, including professional advisers, any screening service providers and IT service providers.
How does Virteffic obtain your personal information and collect your data
We endeavor to collect your personal information directly from you wherever possible. However, the nature of the Services we perform and the context in which we handle your personal information can often result in us collecting your personal information indirectly from third Party sources.
Additionally, there may be circumstances where we are required to seek your personal information from independent sources (for example where we need to use your personal information to comply with any legal requirements to validate your identity and background).
We may use the following methods to collect data from and about:
Direct Interactions on our website
For example when you fill our and submit a contact form, sign up to a newsletter, making an enquiry or comment on our website or on our social media accounts. We will ask you to agree that we can hold your personal information for this purpose as part of the sign up Process.
Automated technologies or interactions
Third Parties or publicly available sources
We may receive Personal Data about you from various third Parties and public sources.
On Social Media
We have a number of social media platforms where we interact with individuals who follow our sites or respond to our postings. We will engage with and respond to individuals who also have a presence on these platforms and all these interactions remain on the site on which they are posted. We use the analytics provided by these platforms in order to understand how our posts are engaging users.
Our clients and people who email or phone us
Our business idea is to work on an ongoing basis with a portfolio of businesses based in Jersey. We may receive email and phone enquiries from individuals who ask us for further details in respect of the Services we provide. In these cases, we will meet in person, by telephone or online video messaging or enter into an email correspondence with individuals in order to provide the information they need. During this Process, individuals may share commercially sensitive information with us about their business.
Providing your Personal Data to others
We will not sell or lease your personal information to third Parties unless we have your permission or the law requires us to do so.
We may disclose your personal information to third Parties, only:
● If we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
● We may disclose your Personal Data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
● To our suppliers or sub-contractors insofar as reasonably necessary for proper administration of our website and business and communications.
● In the event that we sell or buy any business or assets, in which case we may disclose your Personal Data to the prospective seller or buyer of such business or assets.
Whenever we share your personal information, whether internally or externally, we will ensure that such sharing is kept to the minimum necessary.
How long do we keep your information for?
We only retain your information for as long as we actually need it for the purposes we acquired it for, to ensure we meet our legal data protection and privacy obligations.
Customarily, this mean that we will hold your information during the period that we provide you with our Services.
Following the termination of our engagement and post the delivery of our Services, we may keep your information and data for a reasonable period of time afterwards for marketing purposes (which shall take into account whether you have had contact with us or otherwise actively engaged with us during that time) from receipt subject to an individual’s right to unsubscribe or be forgotten at any time. Active engagement shall mean if you are actively engaging with our online Services where you communicate with us or click through from our marketing communications.
After that we will delete it other than where we lawfully can keep any data for audit or legal reasons.
Your Rights and Obligations
The Data Protection (Jersey) Law 2018 grants people a range of specific rights they can exercise over their Personal Data, in certain circumstances (exemptions may apply). Your rights under the Data Protection (Jersey) Law 2018 include the rights to:
● be informed about how your data is being used;
● access Personal Data;
● have incorrect data updated;
● have data deleted (in certain circumstances);
● limit or restrict the Processing of your data (in certain circumstances);
● data portability (allowing you to obtain and reuse your data for different Services); and
● object to how your data is Processed (in certain circumstances).
You have the right to ask us not to Process your Personal Data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third Party for such purposes. You can exercise your right to prevent such Processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us.
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
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.
You may request details of personal information which we hold about you under the GDPR Law 2018 & Jersey Data Protection Laws or request that we copy, delete or amend the details of the information held. You can easily do so by:
Write to us at Virteffic Limited, Norowsa, La Vallee de St Pierre, St Lawrence, Jersey JE3 1EG, or by email to firstname.lastname@example.org .
If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.
We will email you if we become aware of a Personal Data breach. We will assist you in your investigations in establishing how this occurred. We will assist you, as you may reasonably require, in meeting your GDPR obligations in relation to the security of Processing, the notification of Personal Data breaches and data protection impact assessments. This may result in additional time-related charges.
If you have instructed us to do something we believe is not within the Applicable Law, we reserve the right to take advice from the Information Commissioner’s help line and to act in accordance with their indications or advice.
It is your responsibility at all times to specify suitably secure platforms and Processes and to share data with us in a secure way.
Security is important to us and we are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and administrative procedures (including this Policy) to safeguard and secure the information we collect online, as follows:
● We will regularly review and enhance our procedures and this Policy to ensure your personal information is kept safe, confidential and protected from unauthorised access, accidental loss, misuse and abuse.
● We use Microsoft 365 Business with protection against advanced cyberthreats to help protect against malware, viruses, phishing attempts, malicious links, and other threats. This is the safest windows ever which features control access to sensitive information using encryption to help keep data from being accidentally shared. The data stored on our Microsoft 365 platform is encrypted but you should be aware that if we are corresponding with you via a platform that you use which is not encrypted then these emails and their attachments may not be protected in transit.
● All access to Virteffic’s website is covered by HTTPS.
● We will notify you and any applicable regulator of a breach, in the event of any suspected Personal Data breach and where we are legally required to do so.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. Please be aware that communications over the Internet, such as emails / webmails, are not secure unless they have been encrypted. Your communications may route through a number of countries before being delivered – this is the nature of the World Wide Web/Internet. Virteffic cannot accept responsibility for any unauthorised access or loss of personal information that is beyond our control.