Privacy Notice
This Privacy Notice describes how we collect and use personal information about you during and after your relationship with us under the Data Protection (Jersey) Law 2018.
LifeCycle Data Trust (the “Trust”) isa pilot project to help explore whether Jersey data trusts (as formal legal trust structures) are a viable mechanism through which to govern, steward,create and share insights from data. To achieve this, LifeCycle (Trustee)Limited has been incorporated as a Jersey company to act as trustee of the Trust (the “Trustee” or “we” or “LifeCycle”). The Trustee is administered by ICECAP Limited, regulated to provide trust company business by the Jersey Financial Services Commission.
The Trustee in itscapacity as trustee of the Trust is a "Data Controller", which meanswe are responsible for deciding how we hold and use personal information.
LifeCycle is committed to protecting the privacy and security of your personal information. This Privacy Notice describes how we collect and use personal informationabout you during and after your relationship with us under the Data Protection(Jersey) Law 2018 (“DPJL”).
We are required under data protection legislation to notify you of the information contained in this Privacy Notice.
LifeCycle is registered with the Jersey Office ofthe Information Commissioner (“JOIC”) – Registration No. 71285.
We will comply with the relevant data protection laws, the principles of which says that the personal information we hold aboutyou 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 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 collected it.
6. Kept securely.
We will also only transfer your information toanother organisation when it is safe to do so, when necessary, and your information is protected in the same way that we protect it.
LifeCycle is accountable to you and the competent authorities to show compliance with the relevant data protection laws and demonstrate how we are compliant.
We have appointed a DPM to oversee compliance withthis Privacy Notice.
If you have any questions about this Privacy Noticeor how we handle your personal information, contact the DPM at LifeCycle@propelfwd.com.
You havethe right to make a complaint at any time to JOIC , further contact details for these are included at the bottom of this Privacy Notice.
Personal data, or personal information, means any information about an individual from which that person can be identified, directly or indirectly. It does not include data where the identity has been removed (anonymous data).
We collect personal information about you when:
- you sign up to be a cyclist for the Lifecycle pilot
- you cycle with the See.Sense light when it is switched on and paired with the See.Sense app to generate data about your cycling habits
- you contact us (or our Data Processor(s)on our behalf)
What information do we collect about you?
Information we collect when you signup as a cyclist for the Lifecycle pilot:
- Name (First and Last)
- Address
- Date of Birth
- Telephone number
- Email address
- Signature
- Gender
- How often you cycle
- If you travel with children
- Type of bike used
Additional information you may chooseto provide when signing up, if you consent to provide it (Optional)
- Do you ride an Adaptive Bike?
- Household income (Range)
- Country of Birth
Information collected via the Mobile App and when pairedwith the Bike Light;
· Email address
· Gender (optional)
· Age range
· Weight (optional)
· Emergency contact mobile number(optional)
· Incident/Infrastructure reports
- Location (GPS)
- Speed
- Environmental data
- Bike movement (Theft alert – optional)
- Road conditions
- Privacy zones (optional)
“Special Category data” is any information relating to racial or ethnic origin, political opinion, religious or philosophical beliefs, trade union membership, genetic or biometric data, your health, sexlife or sexual orientation, or relating to your criminal record or alleged criminal activity.
When and if we collect Special Category data about you, we will always have a clear legal basis to process this. If this legal basis is your explicit consent, you can withdraw this at any time by contacting our DPM at LifeCycle@propelfwd.com. Please use the words “Withdrawal of consent” in the subject line of your email and include your name and the email address signed up with and that you are withdrawing yourconsent.
An example of processing of special category datails the question we ask about whether you ride an adaptive bike. The response to this question is likely to reveal information about a disability and includeyour health data. We rely on your Explicit Consent as a legal basis to collectthis information; it is optional for you to respond to that question. If you Consent to provide this information, but later wish to withdraw your consent, you can do so at any time by emailing our DPM at LifeCycle@propelfwd.com containing the information noted above.
We will use information about you for the purposes of the LifeCycle pilot project which has been launched by Digital Jersey and the JOIC and supported by several local firms and organisations. The project is exploring how Jersey trust law and local trustees can be used to look after and make use of data subject to governance principles enshrined in trust law and data governance principles.
This means that we will use your personal data to support the purposes of the Trust that has been established for the pilot project.
These purposes include:
• To enable us to create a new database about localcyclists, community cycling and cycling conditions in Jersey with a particularfocus on cycling as a mode of transport in order for data to be aggregated andanalysed by us and, if the we deem it appropriate, shared with third party datausers subject to the terms of the data request procedure, as referred to in the Agreement to Cycle.
• To provide data analytics and create datainsights from the data collected.
• To publish, report, broadcast or otherwise communicate to the public any data insights or data analysis for the benefit of the public, including to advocate to encourage cycling as a mode of transport or to make cycling easier, safer or better in Jersey. Any published data insights or analyses will not include your personal data in identifiable form.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following limited circumstances:
- Where we need to perform our obligations under and connected with the contract referred to as the “Agreement to Cycle”, we are about to enter into or have entered into with you.
- Where you have provided your consent or explicit consent to give information to us.
- 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 or regulatory obligation
- Where it is necessary for the purposes of legal proceedings.
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 explain the legal basis that allows us to do so.
The Trust has been established to create a new database about local cyclists, community cycling and cycling conditions in Jersey with a particular focus on cycling as a mode of transport in order for the data to be aggregated and analysed and if the Trustee deems appropriate, shared with third party data users provided that:
· the data requestors are constituted organisations which can demonstrate compliance with the DPJL;
· that any such organisation has an explicit mandateor has made a public commitment to encourage cycling or make cycling easier,safer or better in Jersey and
· that the data requestor can demonstrate that access to the data will be used to inform decisions about how to encourage cycling or make it easier, safer or better to cycle in Jersey.
We will not share your Personal Information withthird party data users without your explicit consent.
We may share aggregated and analysed data insights derived from your Personal Information with third party data users subject to the criteria above.
We may, on occasions, pass your Personal Information to an organisation outside of LifeCycle exclusively to process on our behalf; these organisations are called Data Processors.
We require these parties to agree to process this information based on our instructions and requirements consistent with this Privacy Notice.
The below table explains what Data Processors we use and the reason for doing so.
We do not pass on information gained from your engagement with us without a clear legal basis for doing so. However, we may disclose your Personal Information to meet legal obligations, regulations, or valid requests.
The personal data we collect from you may be transferred to and stored at a destination outside the European Economic Area("EEA").
It may also be processed by companies outside the EEA who work for one of our service providers or us.
If we do this, we ensure that your privacy rights are respected in line with this Notice and the same protection is given to your personal information as laid down by the DPJL.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, altered or disclosed, or accessed in an unauthorised way. In addition, we limit access to your personal information to those Data Processors and other third parties on a need-to-know basis.
Our Data Processors will only process your personal information on our strict instructions, and they are subject to a duty of confidentiality.
Details of these measures may be obtained from our DPM.
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.
All data is retained securely and only used for the purposes of the LifeCycle Data Trust and as permitted by law. Data is retained to comply with our statutory obligations and in accordance with our retention schedule. If you would like a copy of our retention schedule, please contact our DPM at LifeCycle@propelfwd.com
To determine the appropriate retention period forpersonal data, we consider the amount, nature, and sensitivity of the personaldata, the potential risk of harm from unauthorised use or disclosure of yourdata, the purposes for which we process your data and whether we can achievethose purposes through other means and applicable legal requirements.
In some circumstances, we may anonymise yourpersonal information so that it can no longer be associated with you, in whichcase we may use such information without further notice to you.
The personal information we hold about you must be accurate and current.
Please keep us informed if your information changes during your relationship with us.
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 right enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request rectification of the personal information that we hold about you. This right enables you to have any incomplete or inaccurate data we hold about you corrected.
- Request erasure of your personal information. This right enables you to ask us to delete or remove personal data where there is no good reason for us to continue 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). We may have a legal obligation to hold your data, so this right is not always available to you.
- Object to processing your personal information where we rely on a legitimate interest (or those of a third party). You also have the right to object to processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This right 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 data portability, this is the transfer of your personal information to another data controller.
If you want to review, verify, or request your personal information, object to the processing or request that we transfer a copy of your personal information to another party, contact our DPM at LifeCycle@propelfwd.com as outlined above.
You will not have to pay a fee to access your personal information (or exercise any other rights). However, we may charge a reasonable fee if your access request is unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
Use the Data Subject Access Request form, available on our cookie banner accessible in the bottom left corner of this page. If you have any questions about this process or any of your rights, contact our DPM at LifeCycle@propelfwd.com as outlined above.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or exercise any of your other rights).
We will respond to your request without undue delay, but within Four Weeks after satisfactory verification of your identity. We also have the right to extend this time frame by up to eight weeks. If this is needed, we will inform you as soon and with the reason why an extension is required.
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, contact our DPM at LifeCycle@propelfwd.com as outlined above.
Once we have received notification that you havewithdrawn your consent, we will no longer process your information for thepurpose or purposes you originally agreed to.
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 or requesting you to confirm the accuracy of the information we hold on you.
We want the chance to resolve any complaints youhave about how we process your information. You have the right to complain to the Jersey Office of the Information Commissioner about how we have used your data.
The details for each of these contacts are:
LifeCycle Trustee Ltd
1st Floor, Osprey House 5-7 Old Street St Helier, JE2 3RG
Email: LifeCycle@Propelfwd.com
Office of the Information Commissioner – Jersey
2nd Floor, 5 Castle St, St Helier, Jersey JE2 3BT
Telephone +44 (0) 1534 716530 or Email: enquiries@jerseyoic.org
