Privacy Policy

True Limited

PRIVACY POLICY
True Limited is a Jersey Limited Company (“True”).

This Privacy Policy (the “Policy”) describes how True collects, uses and shares the information you provide to us and the information we collect in the course of operating our website and our business.

If you would like to request any further information for True please contact james.painter@trueesg.com.

TRUE PRIVACY PLEDGE
Within the provision of True services, we commit to the principles of respecting your privacy, keeping your Personal Data (as defined in the Data Protection (Jersey) Law 2018 (the “Data Protection Law”) secure and keeping the decision as to how your information is used or shared in your control.

Our privacy pledge:

True will collect Personal Data only that is useful and necessary for providing the services, or improving our products, services and your experience;

True will consistently act fairly and with transparency with respect to the collection of and processing of your Personal Data;

True will not sell your Personal Data, and will share your Personal Data only when given your explicit consent to do so for a specific reason, or where it is in the legitimate interests of the business to utilise your data in specific circumstances;

True will not make decisions based solely on automated processing or profiling of Personal Data; and

True will always take seriously the security of your Personal Data.

To understand more about the Personal Data potentially collected by True, please read the full Privacy Policy statement across the following paragraphs.

YOUR RIGHTS
Under the Data Protection Law, you have the following rights, which True will always work to uphold:

a) The right to be informed about our collection and use of your Personal Data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions at james.painter@trueesg.com.
b) The right to access the Personal Data we hold about you. We set out below how to do this.
c) The right to have your Personal Data rectified if any of your Personal Data held by us is inaccurate or incomplete.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your Personal Data that we have.
e) The right to restrict (i.e. prevent) the processing of your Personal Data.
f) The right to object to us using your Personal Data for a particular purpose or purposes.
g) For more information about our use of your Personal Data or exercising your rights as outlined above, please contact us at james.painter@trueesg.com.

Please contact us at james.painter@trueesg.com to find out more about any of the items listed above.

DATA COLLECTION AND PROCESSING
Subject to relevant local law, True may process certain information about you if this information is necessary in order to perform our contract with you, if you provide your consent, or where it is in our legitimate interests in order to provide our services to you in the most effective way. Personal Data is defined by the in accordance with the requirements of the Data Protection (Jersey) Law 2018 (as may be amended or replaced from time to time) (the “Data Protection Law”) Data Protection Lawas ‘means any data relating to a data subject’ ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal Data that may include information that could identify you as a natural person, including but not limited to names (current and former), address, contact details, date and place of birth, nationality, occupation and other personal identifiers such as tax identification numbers. Personal Data also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

True processes your Personal Data in line with its Privacy Policy and T&C’s to provide you with the information that is of most interest to you, and deliver the services you have requested.

AUTOMATED PROFILING
True does not carry out automated profiling and will not make any decisions based on the automated processing of Personal Data. No statement or information on this site constitutes a recommendation, offer or invitation to invest in any investments, securities or products of True.

SENSITIVE DATA
True does not seek to collect special categories of Personal Data (“sensitive data”), including but not limited to data revealing racial/ethnic origin, political opinions, gender, religious or philosophical beliefs, health, genetic and biometric data, or trade union memberships, via this site. We may however ask you to provide this information directly to a third party life assurance provider for the purposes of an application made to them. In such an instance we do not store this data in any way.

Please note that, if you freely provide True with unsolicited sensitive data, subject to the relevant laws, you are explicitly consenting True to use the said data in conformity with this Privacy Policy.

VISITING THE TRUE WEBSITE
True maintains www.trueesg.com (the Site).

We collect some Personal Data from anyone who visits our Site, we will also track usage patterns with the aim of refining and expanding our service. We may gather details of your domain name, IP address and the details of the website you came from to enable us to improve the Site. True uses Google Analytics to gather this data, we also collect data for cookies.

For more details on what cookies are and what they are used for, please read our full Cookie Policy.

LINK TO THIRD PARTIES WEBSITES
The True Privacy Policy does not apply to third party websites which our Site links to or which advertise on the True website.

True does not control or endorse and is not responsible for the contents of these linked Third Party Sites. True provides hyperlinks to other websites for your convenience only. When you use Third Party Sites, you will be legally bound by the specific terms of use posted on such websites. Please note that True has no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

COOKIE POLICY
The Cookie Policy is part of our Privacy Policy. True uses cookies on its websites to ensure that you receive the best user experience possible when browsing the Site.

What are Cookies?
Cookies are pieces of data that are sent by servers to web browsers and stored on your computer. Cookies were designed to be a reliable mechanism for websites to remember stateful information (such as items added in the shopping cart in an online store) or to record the user’s browsing activity. The cookies tell us which parts of the Site you have visited so that we can ensure we provide you with information that you are interested in and make any future visits to our website simple and easy for you. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and Personal Data is protected and respected at all times. The information and data collected by True cookies expire after two years.

What are Social Buttons?
Social media tools, like widgets and plug-ins, are sometimes used so that you can share information from True on other sites such as Twitter or LinkedIn. These interactive mini-programs collect your IP address, record the pages you visit on our site, and set cookies that will enable the widget to function properly. Your interactions with these widgets are governed by the privacy policy of the company providing them, not by True’s Privacy Policy. We may also use Twitter, Facebook and LinkedIn pixel tags to help us understand how effective our marketing is on those sites.

What is Browser control?
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. Certain features of our website depend on Cookies to function. The law deems these Cookies to be “strictly necessary”. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that our website may not work properly if you do so. True has taken great care to ensure that your privacy is not at risk by allowing them.] If you wish to decline the use of cookies please refer to the instructions for your file management software. Most browsers allow you to see what cookies you have and delete them on either an individual basis, or block them. You can block cookies for specific websites or for all websites, depending on your preferences.

You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.

It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

EMAIL MARKETING
If you are subscribed to a True marketing list, we may periodically send you relevant updates. When you receive marketing emails from True, we may use web beacons, customised links, or similar technologies to determine whether e-mails have been opened and which links you activate, to ensure we can provide focused e-mail communications or other information going forwards.

UNSUBSCRIBING
You may choose to stop receiving marketing emails from True at any time, by Unsubscribing/Opting Out. There is a link at the bottom of every marketing email within which you should update your preferences by selecting/deselecting items based on your personal interests, or unsubscribe in respect of all marketing communications. If you prefer you can make a direct request to unsubscribe by emailing james.painter@trueesg.com.
Please note, that by unsubscribing from all marketing emails True will remove your contact details from all mailing lists and place you on a “no mail” list. If you wish to amend or update your preferences use the link at the bottom of any True marketing email or if preferable contact james.painter@trueesg.com.

CROSS BORDER TRANSFERS AND THIRD PARTIES
True may share your Personal Data with: –

True affiliates and third-party vendors who process information on True’s behalf, including providers of information technology, identity management, website hosting and management, data analysis, data back-up, security and storage services; or,

Other third parties where you have given your consent to the disclosure (either to True or the third party).

To competent authorities (including tax authorities), courts and bodies as required by law or requested or to affiliates for internal investigations and reporting.

The disclosure of personal information to the third parties, as set out above, will only involve the storage or transfer of your Personal Data within Jersey, Guernsey, Isle of Man, the United Kingdom and/or the European Economic Area (the “EEA”) in accordance with the requirements of the Data Protection Law. The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein.

The disclosure of personal information to the third parties set out above may involve the transfer of data to Jersey, Guernsey, Isle of Man, the United Kingdom and/or the EEA in accordance with the requirements of the Data Protection Law.

In the event that True transfers your Personal Data to countries that may not have the same level of data protection as that provided in your home country, True will put a contract or other legal instruments available in place to ensure that your Personal Data is protected in accordance with the relevant laws and regulations, or operate in accordance with your consent where you have provided instructions to us.

INFORMATION SECURITY
True is committed to protecting the security of your Personal Data. True has put in place measures to protect the security of your Personal Data and information from loss, misuse, alteration or destruction. True ensures that all appropriate confidentiality obligations, technical, and organisational security measures are in place to prevent unauthorised or unlawful disclosure or processing of such information and data as well as the accidental loss or destruction of or damage to this information and data.

In addition, we limit access to your personal information to authorised True employees and service providers whom are authorised to access the data, and are legally obliged to ensure confidentiality of this information.

DATA RETENTION
The data you submit to True will only be retained for as long as required in order to carry out our contractual, regulatory or legal obligations. When the data is no longer necessary or relevant for the rationale of its collection, True will erase all your Personal Data held in its systems without undue delay.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once our business relationship has terminated we will retain and securely destroy your personal information in accordance with our data retention and destruction policy and applicable laws and regulations.

RIGHT OF ACCESS AND CORRECTION
Your duty to inform us of changes: –

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

Subject to the relevant laws, you have the right to access your personal information (commonly known as a ‘data subject access request’), which enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. Please note that for the execution of this request, you must provide us with a clear identification of yourself and the Personal Data you require. Such requests should be made by email to james.painter@trueesg.com.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within 30 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your Personal Data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

You also have the right to request rectification of inaccurate Personal Data we hold about you. If you would like to exercise this right, you may provide True with a supplementary statement by email to james.painter@trueesg.com. Please note True does not assume responsibility for verifying the ongoing accuracy of the Personal Data provided.

RIGHT TO BE FORGOTTEN
This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. Such requests should be made by email to james.painter@trueesg.com.

Please note, if you wish to exercise your ‘right to be forgotten’ we recommend that you request True retain your information on its ‘no mail’ list. If you are totally removed from the system you could be legitimately and legally added back into the system at some point in the future and therefore could receive future communications from True. If your data is kept on the ‘no mail’ list you will not receive any future marketing communications from True, unless you revise your decision and explicitly request it.

LEGAL DISCLOSURE
True may disclose your personal information to law enforcement, regulatory, or other government agencies or to other third parties as required by, and in accordance with, applicable laws or regulations.

CONTACT AND COMPLAINTS
If you have any questions about this Privacy Policy, you may contact us at james.painter@trueesg.com or post at the following address:

True Limited
First Floor
Forum 4
Grenville Street
St Helier
JE2 4UF

If you have any cause for complaint about our use of your Personal Data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details listed above.
The Office of the Information Commission in respect of Jersey matters can be contacted at enquiries@oicjersey.org or in respect of UK matters https://ico.org.uk/concerns, should you wish to make a complaint.

AMENDMENTS
True is entitled to update the terms of this Privacy Policy in line with new regulations or directions by the relevant Information Commissioner at any time and without giving you notice. When we make changes to our Privacy Statement, we will amend the revision date at the bottom of this page, and modifications of amendments shall be considered effective as of that revision date for you and your information. Any changes will be immediately posted on our website and you will be deemed to have accepted the terms of the Privacy Policy on your first use of our website following the alterations. We recommend that you check this page regularly to keep up-to-date.

This Privacy Policy was last updated September 2021