Privacy Policy

Welcome to Velos IoT Jersey Limited’s privacy policy (the “Policy”). This Policy applies to Velos IoT Jersey Limited, whose current registered office is P.O. Box 536, 13-14 Esplanade, St. Helier, Jersey, JE4 5UR (company number 133078) (“Velos IoT”), an Internet of Things (“IoT”) solution provider, and all its group companies (“we”, “us” and together the “Velos IoT Group”). The current Velos IoT Group is as follows:

1. Important information and who we are

Purpose of this Policy
This is the Policy referred to in the various Velos IoT Terms and Conditions that are applicable to our products and services (the “Conditions”). Terms defined in the relevant Conditions shall have the same meaning in this Policy. Unless this is otherwise defined in this Policy.

This Policy applies to any natural person (a “data subject” or “you”) when you purchase goods or services from Velos IoT or the Velos IoT Group or in relation to whom Velos IoT receives personal information in relation to the purchase of said goods or services.

In addition, this Policy aims to give you information on how the Velos IoT Group collects and processes your personal data through your use of this website, including any data you may provide through this website, when you sign up to our newsletter, log into and use our platforms or take part in a competition or an event.

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

It is important that you read this Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Policy supplements other notices and privacy policies and is not intended to override them. We may update this Policy at any time.

Controller
Velos IoT as the parent of the Velos IoT Group is a ‘data controller’. This means that we are responsible for deciding how we hold and also use personal information about you. We are required under the Data Protection (Jersey) Law 2018, the Data Protection (Bailiwick of Guernsey) Law 2017, the General Data Protection Regulation 2016/679 (“GDPR”), the UK GDPR (the GDPR as implemented into UK domestic law) and the UK Data Protection Act 2018 as applicable, (the “Data Protection Laws”) to notify you of the information contained in this Policy.

For the avoidance of doubt, this Policy is issued on behalf of the Velos IoT Group so when we mention Velos IoT, “we”, “us” or “our” in this Policy, we are referring to the relevant company in the Velos IoT Group responsible for processing your data. We will let you know which entity will be the controller for your data when you purchase a product or service with us. Velos IoT is the controller and responsible for this website.

We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this Policy. If you have any questions about this Policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details
Full name of legal entity: Velos IoT Jersey Limited

If you have any questions about this Policy or our privacy practices, please contact our DPO in the following ways:

Email address: legal@velosiot-production.tempurl.host

Postal address: Velos IoT Jersey Limited, P.O. Box 536, 13-14 Esplanade, St. Helier, Jersey, JE4 5UR

You have the right to make a complaint at any time to the relevant regulator. For example, the Jersey regulator for data protection issues is the Jersey Office of the Information Commissioner (jerseyoic.org) and the UK regulator for data protection issues is the Information Commissioner’s Office (ICO) (www.ico.org.uk). Please see the section below on your legal rights within this Policy for more information. We would, however, appreciate the chance to deal with your concerns before you approach the relevant regulator so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes
We keep our Policy under regular review. This version was last updated on 20 September 2022.

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.

Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements/notices. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. 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 removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes (where applicable) first name, maiden name, last name, username or similar identifier, title and date of birth;
• Contact Data includes (where applicable) billing address, delivery address, email address and telephone numbers;
• Financial Data includes (where applicable) bank account and payment card details;
• Transaction Data includes (where applicable) details about payments to and from you and other details of products and services you have purchased from us;
• Technical Data includes (where applicable) 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 (where applicable) your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses;
• Usage Data includes (where applicable) information about how you use our website, products and services; and
• Marketing and Communications Data includes (where applicable) your preferences in receiving marketing from us and our third parties and your communication preferences, as well as any third parties we have a sponsorship agreement with, where you have opted-in through a third party and we subsequently contact you for marketing purposes.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

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.

If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of an Agreement we have with you, and you fail to provide that data when requested, we may not be able to perform the Agreement we have or are trying to enter into with you (for example, to provide you with services). In such circumstances, we may suspend the service and/or terminate the Agreement.

3. How is your personal data 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 (including the limited personal data received through the Velos IoT Group number portability services- please see below);
  • create an account and become a user of our platforms;
  • 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 feedback or contact us.
• Automated technologies or interactions. As you interact with our website, we will 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. Please see our cookie policy for further details.
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources (such as the examples set out below):
  • Google Analytics
  • HubspotSalesforce
  • Lead Forensics
  • DocuSign
• Technical data from the following parties:
  • analytics providers (such as Google based outside the Channel Islands/UK);
  • advertising networks (such as Google or LinkedIn based outside the Channel Islands/ UK); and
  • search information providers (such as Google based outside the Channel Islands/UK).
• Contact, financial and transaction data from providers of technical, payment and delivery services.
• Identity and contact data from data brokers or aggregators.
• Identity and contact data from publicly available sources such as Companies House, and the Electoral Register based inside the UK, and the JFSC based in Jersey.

4. 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:

• Where we need to perform the Agreement 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 obligation; and
• Where we need to assist the emergency services in an emergency (legitimate interests and, in some circumstances, vital interests);

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your “opt-in” and recorded consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data
We have set out 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. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Processing for Number Portability Customers
Number Portability is a service that allows a customer to change telecom carrier and keep the same phone number. We may process personal data for certain number of portability customers from time to time, which could include storing sets of telephone numbers on their own, with no other identifying data with the purpose of running and developing a shared number database to support number portability in certain locations. While we identify that it is very unlikely, we could identify a data subject from a database containing large sets of numbers only, the relevant Data Protection Legislation does list telephone numbers as personal data. Therefore, where Velos IoT or any company within the Velos IoT Group processes personal data in this way for number portability customers, Velos IoT/the entity within the Velos IoT Group will comply with the processing obligations contained within our policy for data processing for number portability, which you can request from us.

Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us
We may use your identity, contact, technical, usage and profile data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out
You can ask us or third parties to stop sending you marketing messages at any time by a) logging into your website portal (if applicable to you) and checking or unchecking relevant boxes to adjust your marketing preferences; b) following the opt-out links on any marketing message sent to you; or c) by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Cookies
This site uses cookies which are small text files that are placed on your machine to help the site provide a better user experience. In general, cookies are used to retain user preferences, store information for things like shopping carts, and provide anonymised tracking data to third party applications like Google Analytics. As a rule, cookies will make your browsing experience better. However, you may prefer to disable cookies on this site and on others. The most effective way to do this is to disable cookies in your browser. We suggest consulting the help section of your browser. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

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.

5. Disclosure of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table above.

• members of Velos IoT Group;
• external third parties, to include: partners, suppliers, sub-contractors or agents engaged by Velos IoT for the purpose of performing the Agreement for the goods or services or other parties engaged to perform services for, or on behalf of Velos IoT;
• persons making a complaint or an enquiry in relation to the use of the service;
• the emergency services (if you make an emergency call), including your approximate location;
• other communications service providers and network operators;
• credit reference and debt collection agencies;
• appropriate authorities for the purpose of preventing fraud, theft and other unlawful activity;
• commercial partners for joint promotions with that third party: and
• if there is a change (or expected change) in who owns Velos IoT or any of Velos IoT’s assets, Velos IoT might also share personal information to the new (or prospective) owner. If Velos IoT does, that party will have to keep the shared information confidential.

Velos IoT may also be required to share your personal information with a third party or body in circumstances where such disclosure is required to satisfy any applicable law or regulatory requirements. Disclosures to law enforcement agencies, regulatory organisations, government bodies or agencies, courts or other public authorities may occur if Velos IoT is authorised or if it is required, by law to do so.

6. International Transfers
Velos IoT may need to transfer your personal information to a jurisdiction that is outside of Jersey, Guernsey and the European Economic Area (“EEA”). The EEA consists of countries in the European Union, Iceland, Liechtenstein and Norway. They are considered to have equivalent laws when it comes to data protection and privacy. The laws of the Bailiwicks of Jersey and Guernsey have been deemed “adequate” for the purposes of EU data protection standards. This kind of data transfer may happen if, for example, a member of the Velos IoT Group, a Velos IoT supplier or a service provider is based outside Jersey, Guernsey and the EEA. Or, if you use Velos IoT’s services and products while visiting countries outside these jurisdictions. If Velos IoT sends your information to a jurisdiction that is not in the EEA or the Channel Islands, Velos IoT will make sure that your information is properly protected. Velos IoT will also ensure that there is a legal agreement that covers the data transfer. In addition, if the country is not considered to have laws that are equivalent to EU data protection standards, then we will ask the third party to enter into a legal agreement that reflects those standards.

7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. 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 deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your Legal Rights
Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.

If you wish to exercise any of the rights set out above, you should contact Velos IoT in writing. Velos IoT has appointed a data protection officer who may be contacted at legal@velosiot-production.tempurl.host.

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 the 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 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.

Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

YOUR LEGAL RIGHTS
You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data’s accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.