Data Protection Policy

WEBSITE DISCLAIMER

The information contained on the Headway Jersey website (the "Website") is for general information purposes only. Headway Jersey Ltd. assumes no responsibility for errors or omissions in the contents on the Website. To the extent permitted by law, in no event shall Headway Jersey Ltd. be liable for any special, direct, indirect, consequential, or incidental damages or any damages whatsoever, whether in an action of contract, negligence or other tort, arising out of or in connection with the use of or in connection with the use of the Website or the contents of the Website. Headway Jersey Ltd. reserves the right to make additions, deletions, or modification to the contents on the Website at any time without prior notice. Headway Jersey Ltd. does not warrant that the Website is free of viruses or other harmful components. 

Medical advice disclaimer: Any Medical information is merely information - not advice. If you need medical advice, you should consult a doctor or other appropriate medical professional.

External links disclaimer: the Website may contain links to external websites that are not provided or maintained by or in any way affiliated with Headway Jersey Ltd. Please note that Headway Jersey Ltd. does not guarantee the accuracy, relevance, timeliness, or completeness of any information on these external websites.

PRIVACY & DATA POLICY

COLLECTING INFORMATION

This Website requests and collects certain personally identifiable information  (PII) such as your name, address, phone number,  e-mail address and credit card information through various means, including Website registration, surveys, questions, comments and communications to the Website, postings to chat,  subscribing to newsletters, placing an order for products or services, reporting a problem with the Website or otherwise contacting Health Alchemy Ltd. All PII data held by Headway Jersey Ltd. is protected in accordance with Principles of the GDPR.

 

Headway Jersey Ltd. may collect your IP (Internet Protocol) address to help diagnose problems with its server and to administer the Website. An IP address is a number that is assigned to your computer when you use the Internet. This information does not contain any personally identifiable information about you.

 

COOKIES

"Cookies" are pieces of information that are placed on an individual's computer hard drive to enable the individual to more easily communicate and interact with the Website. Headway Jersey Ltd. may use cookies to customise your experience on the Website. Headway Jersey Ltd. may also use cookies to record how many times you have visited the Website and what pages you have accessed. You may, however, disallow receiving cookies at any time through your web browser. It is not Headway Jersey Ltd. intention to use cookies to retrieve information that is unrelated to the Website or your interaction with the Website.

RETARGETING COOKIE STATEMENT 

Headway Jersey Ltd. uses cookies, pixels, and other technologies (collectively, "cookies") to recognise your browser or device, learn more about your interests, and provide you with essential features and services and for additional purposes, including:

Recognising you when you visit the Website and use the services. This allows Headway Jersey Ltd. to provide you with product recommendations, display personalised content, recognise you as an ideal customer, to provide other customised features and services on the Website.

Keeping track of your specified preferences. This allows Headway Jersey Ltd. to honour your likes and dislikes, such as whether or not you would like to see interest-based ads. Conducting research and diagnostics to improve the Website content, products, and services.

Improving security.

Delivering content, including ads, relevant to your interests on the Website and third-party sites. (DATA INVENTORY STATEMENT: Facebook, Instagram, Google)

Reporting. This allows Headway Jersey Ltd. to measure and analyse the performance of its services.

The Website retargeting cookies allow you to take advantage of some of the Website's essential features.

Approved third parties may also set cookies when you interact with the Website. Third parties include search engines, providers of measurement and analytics services, social media networks, and advertising companies. Third parties use cookies in the process of delivering content, including ads relevant to your interests, to measure the effectiveness of their ads, and to perform services on our behalf of us. 

You can manage browser cookies through your browser settings. The 'Help' feature on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, how to disable cookies, and when cookies will expire. If you disable all cookies on your browser, neither Headway Jersey Ltd. nor third parties will transfer cookies to your browser. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some features and services may not work.

GENERAL DATA PROTECTION REGULATION (GDPR)

Headway Jersey Ltd. will treat all information received from clients and third parties in accordance with the GDPR.

For the purposes of the GDPR:

The data controller is Headway Jersey Ltd.

The data processor is Headway Jersey Ltd.

DATA PROCESSING DEFINITION

Processing means any operation or set of operations which is performed upon personal data or sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.’ In other words, anything we do in relation to holding or using customer information.

THE PURPOSE FOR COLLECTING DATA

The purpose of data collected by Headway Jersey Ltd. is its use for carrying out Headway Jersey Ltd.’s business and in order to:

  • enter into an agreement with you regarding the provision of services or sale of products;

  • respond in Headway Jersey Ltd.’s legitimate interest to your enquiries about its products and /or services and/or other requests;

  • send promotional emails about new services, products, special offers or other information which Headway Jersey Ltd thinks you may find relevant using the email address which you have provided;

  • manage Headway JerseyLtd.’s infrastructure and business operations and to comply with policies and procedures that may be required by law or where necessary for Headway Jersey Ltd.’s legitimate interest to satisfy other applicable industry regulations or guidelines that may have been put in place by Headway Jersey Ltd., including those relating to finance and accounting, billing and collections, IT systems, data and website hosting, training, testing and business continuity;

  • correspond with you concerning Headway Jersey Ltd.’s present and future services and relevant news and service/products updates with your consent where required by law or otherwise in Headway Jersey Ltd.’s legitimate interests provided these interests do not override your right to object such communication; and/or

  • other purposes which Headway Jersey Ltd. may notify you of from time to time and obtaining your consent where necessary.

CONSENT TO HOLD DATA

By visiting the Website and completing any of the consent processes you accept and consent to the practices defined in this Privacy and Data Policy. On completion of any of the consent processes, the data will be forwarded from your browser and processed in accordance with this Privacy and Data Policy. If you do not agree to this policy, please do not use the Website. Headway Jersey Ltd. reserves the right, at its discretion, to change, modify, add, or remove portions from this Policy at any time so you are encouraged to review this Policy from time to time. Your continued use of this Website following the posting of changes to these terms means you accept these changes.

YOUR RIGHTS UNDER THE GDPR

You have a number of rights under the GDPR in relation to your PII. You have the right under certain circumstances to:

  • ACCESS

You have the right to access all the PII stored on you. There will be no fee for the first copy of the information. A fee may be charged if you ask for a copy to be sent to another interested party.

  • RECTIFICATION

If you find inaccuracies in your personal data you can ask to rectify it.

  • ERASURE

You have the right to request your PII to be erased without undue delay.

Instance where erasure of data would be appropriate:


- If the PII is no longer necessary in relation to the purposes for which they were collected.

An instance where erasure of data would not be appropriate:


- where the erasure of the data may be in breach of regulatory or legal obligations of the controller.

  • RESTRICTION OF PROCESSING

You have the right to have the processing of your PII restricted (while Health Alchemy Ltd. verifies or investigates your concerns with this information for example)

  • PREVENT DIRECT MARKETING

Headway Jersey Ltd. uses information such as your interactions with the Website content, or services to display interest-based ads for features, products, and services and/or products that might be of interest to you. Headway Jersey Ltd. does not use information that personally identifies you to display interest-based ads.

You may choose to have your name taken off Headway Jersey Ltd. e-mail marketing list by sending an e-mail on the Contact me page with the subject line "Unsubscribe" or by following instructions provided in any e-mail message from [www.headway.org.je].

  • DATA PORTABILITY

You have the right to PII concerning you which you have provided to a controller be transmitted to another controller.

  • AUTOMATED DECISIONS & PROFILING

You have the right not to have your personal data automatically processed.

CONTROLLING YOUR PERSONAL INFORMATION

You may choose to restrict the collection or use of your personal information in the following ways:

Headway Jersey Ltd. will only collect your data on the Website contact form where you specifically agree.

Headway Jersey Ltd. utilises email and SMS marketing for the purposes of client communications, and where used, it always includes an ability to unsubscribe your email address from any ongoing marketing communications.

If you believe Headway Jersey Ltd. holds any personal data about you, you are welcome to send us a written "Subject Access Request" to request details of this data. Headway Jersey Ltd. will require you to provide comprehensive proof of your identity before releasing any information.

If you require this personal data to be deleted / anonymised / archived / updated or altered in any other way, you should include this in your written request. Headway Jersey Ltd. will be happy to comply where its regulatory, statutory and commercial rights and responsibilities will not be compromised.

Headway Jersey Ltd. is only able to respond to "Subject Access Requests" where these are received in writing and sent to the following address:

The Data Protection Officer

Headway Jersey / Karen De Gouveia karen.degouveia@headway.org.je

You should also contact the Data Protection Officer if you have any complaints about the way in which PII is processed or if you require any further information about this Privacy and Data Policy or its contents.

If your request or concern is not satisfactorily resolved by Headway Jersey Ltd. you may approach the Office of the Information Commissioner. The contact details are as follows:

Headway Centre, Le Coie, Springfield Road, St Saviours, Je2 7DN

Tel. 01534 505937 or 505936

website:  jerseyoic.org

 

Headway Jersey Ltd. will not distribute personal information to third parties unless it is explicitly required to do so to fulfil a commercial request, under IT hosting arrangements, by law, or for accounting or regulatory purposes.

Transfers out of the European Economic Area. Whenever Headway Jersey Ltd. transfers personal information to countries outside of the European Economic Area in the course of sharing information as set out above, it will ensure that the information is transferred in accordance with this Privacy Notice and as permitted by the applicable laws on data protection.

DATA RETENTION PERIODS

Personal data shall be kept in a form that permits the identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.

At the completion of the retention period, all data will be purged.

SENSITIVE PERSONAL DATA

Personal data consisting of the following information is deemed to be of a sensitive nature and Headway Jersey Ltd. will not enquire or retain information relating to these:

(a) the racial or ethnic origin of the data subject;

(b) his/her political opinions;

(c) his/her religious beliefs or other beliefs of a similar nature;

(d) whether he/she is a member of a trade union;

(e) his/her sexual life;

 

SECURITY

Headway Jersey Ltd. is committed to using its best endeavours to ensure that your information is secure. All information transferred between your browser and the Website or third party applications are encrypted using HTTPS protocol, using Digital Certificates with secure TLS Cyphers. This can be verified by looking for the secure padlock symbol in the browser address bar.

In order to prevent un-authorised access or disclosure, Headway Jersey Ltd. has put in place further physical, electronic and managerial procedures to safeguard and secure the information it collects. These policies and procedures are company confidential, to avoid exposure of this data security, so can only be made available to relevant parties legally bound by a non-disclosure agreement.

REGISTRATION

It is the responsibility of Headway Jersey Ltd. to ensure that registration is maintained with the Data Protection/Information Commissioner, declaring the purposes for which the information is being held or processed, to whom it will be disclosed and the security to be applied.

It is the responsibility of all staff members to ensure that any use of personal data in the course of their work is treated in accordance with the GDPR.

LINKS

This Website may contain links or references to other websites outside of Headway Jersey Ltd.’s control. Please be aware that Headway Jersey Ltd. has no control over these sites and this Privacy and Data Policy does not apply to these sites.

Charity Status Statement

  • Registered charity name: Headway Jersey Ltd.

  • Your charity number: 56

  • Your registered address:
    Headway Jersey Ltd. is a registered charity in Jersey (Charity No. _56_). Our registered address is Headway Centre, Le Coie, Springfield Road, St Saviour, Jersey JE2 7DN.

Donations & Fundraising Disclaimer

Donations Disclaimer Example:
All donations made through this Website support the charitable work of Headway Jersey Ltd. Unless specifically stated, donations are unrestricted and may be used wherever the need is greatest. Headway Jersey Ltd. reserves the right to allocate funds according to operational priorities.

Fundraising Compliance:
All fundraising activity conducted in the name of Headway Jersey Ltd. must be authorised in writing by the charity. Unauthorised fundraising is not permitted.

Financial Transaction & Refund Statement


Headway Jersey Ltd. does not issue refunds for voluntary donations. If you believe a donation has been made in error, please contact us within 48 hours so we can review the request. 

Vulnerable Person Protection (Highly recommended for brain-injury charities)


Headway Jersey Ltd. is committed to safeguarding vulnerable individuals. We will never intentionally seek donations from anyone we believe lacks the capacity to make an informed decision.

Complaints Procedure

If you wish to provide feedback or make a complaint, please contact us at [email]. We aim to acknowledge all complaints within 5 working days and resolve them as quickly as possible.

Gift Aid / Lump Sum Tax Relief Clarification


If you are a Jersey resident and make a lump sum donation of £50 or more, Headway Jersey Ltd. may reclaim tax under the Jersey Lump Sum Donation Scheme. This increases the value of your donation at no extra cost to you.

Accessibility Statement


Headway Jersey Ltd. is committed to ensuring that our Website is accessible to all users, including those with disabilities. If you experience difficulties accessing any content, please contact us so we can improve your experience.