The Better Journey Project (“Better Journeys" or “us” or "we") respects the privacy of those who communicate with better Journeys and the users of Better Journeys websites (each, a “User” or “you”).
This Policy is effective as of 2 March 2022. This Policy may be amended from time to time and notices of amendments will appear at the foot of this Policy. It is your responsibility to review this Policy and to check for notices of amendments.
The information we receive depends on how you communicate with us and what you do when visiting the Websites. You provide personal information to us, if at all, on a voluntary basis. In addition, we receive aggregated information about Users as a whole.
By using the Websites or communicating with us, you represent that you have read, understood, and agree to be bound by this Policy. If you do not agree to this Policy, please do not use our Websites nor communicate with us.
1. What is the purpose of this document?
This privacy notice describes how Better Journeys collects and uses personal information about you and any personal data in accordance with the applicable data protection legislation.
We recognises the importance of this data and the risks related to its possession of such, and are committed to protecting the privacy and security of your personal information.
Better Journeys is a "data controller". This means that we are responsible for deciding how we hold and use personal information about you. To comply with data protection legislation and best practice we are required to notify you of the information contained in this privacy notice. This notice sets out your rights under applicable data protection laws as well as our commitment to you regarding how we treat your data. We may update this notice at any time, do please look at it regularly.
It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
2. Purpose of Websites
The purpose of the Websites is to provide information to the public to further the aims of Better Journeys, to make useful and practical information available to residents, businesses, organisations and visitors.
3. Data protection principles
We are committed to apply the highest standards and will comply with applicable data protection laws. This means that the personal information we hold about you must be:
3.1 Used lawfully, fairly and in a transparent manner.
3.2 Collected only for valid purposes that we have clearly explained to you and not used in any other way without your permission.
3.3 Relevant to the purposes we have explained to you and limited only to those purposes.
3.4 Accurate and kept up to date.
3.5 Kept only for so long as is necessary for the purposes explained to you.
3.6 Kept securely
4. Personal Information Collected
The Personal information that may be collected is limited to your first and last name, name of the organisation you may represent, e-mail address, mobile phone number, service used, and any comments, feedback or inquires that you send to us.
The Websites provide users the opportunity to request to receive communications and information from us. Users may edit their preferences and/or cancel their registration by following the directions provided.
5. How we will use information about you
We will only use your personal information when the law allows us to. Most commonly, we will hold or use your personal information in the following circumstances:
5.1 Where you have chosen to Register on the Websites or access the Toolkits (see specific section below)
5.2 Where you have contacted us
5.3 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
5.4 We may also use your personal information in the following situations, which are likely to be rare:
Where we need to comply with a legal obligation or regulatory requirement
Where we need to protect your interests (or someone else's interests)
Where it is needed in the public interest
6. Better Journeys Day Leaders Challenge
One of the initiatives of Better Journeys is a regular “Better Journey Day” by which Better Journeys aims to encourage as many Islanders as possible to travel more sustainably. This will include a challenge to the community, for instance, to commit to a series of Better Journey Days, and Better Journeys may use details of those who have made commitments to assist the promotion of its broader aims.
Registration is voluntary, the process requires your first and last name, your organisation or business name (if relevant), your email address and your Pledge or Commitment ("your details").
Your name and, if provided, your organisation or business name, may be publicised on the Websites and may be used for the promotion of Better Journey Days or the aims and objectives of Better Journeys, such promotion may utilise the media, including print or electronic media.
Your email address may be used to communicate with you to provide information about Better Journey Day or Better Journeys, or to seek comments or feedback which might help Better Journeys and its aims.
7. Travel Plan & Toolkits ("Toolkits")
The Websites may include Toolkits containing information and templates which an organisation or business might wish to use as part of its own Environmental, Social and Governance planning and implementation.
Downloading the Toolkits from the Websites requires voluntary registration. The registration process requires your first and last name, your organisation or business name (if relevant) and your email address ("your details").
Your details will only be used to communicate with you to provide information about the Toolkits or Better Journeys, or to seek your comments or feedback which might help Better Journeys and its aims.
8. Use of Personal Information
If you send us an electronic mail message (email) that contains personally identifiable information or fill out a form that provides information to us or provide your mobile phone number to us, we will use the personally identifiable information provided.
The comments, feedback or inquiries that you provide to us will be used to try to improve the Websites and the services they provide.
Better Journeys does not share, sell, trade, or rent your personal information to anyone, or disclose personal information except in the following instances:
When law requires disclosure. Please note that comments, feedback or inquiries that you provide may be considered a public record once you provide it and may be subject to public inspection and copying if not otherwise protected by law.
Aggregated information does not include personal identifying information and therefore you cannot be identified from aggregated information.
We use aggregated information to help determine things like which areas of the Websites you prefer, based on traffic to those areas, peak traffic hours, etc. This helps us continue to build a better website for users. We may disclose aggregated data to third parties (such as advertisers) or include it in public records.
9. Aggregated Information Collected
We receive certain types of information about general activity at the Websites. This does not include personal identifying information but does include internet protocol addresses, how many times the website is visited, the date, time, and page you visited on our site, your browser and operating system, and the referring page (the last webpage you visited before clicking on a link to our site), what pages or search terms are frequently requested, what domain names (e.g., “aol.com”) visitors are coming from and the date and time of each visit. We use the aggregated information from all our visitors to measure server performance, analyse user traffic patterns and improve the content of our sites.
Note: If you prefer not to receive cookies, you may configure your browser not to accept them at all, or to notify and require approval before accepting new cookies. Some web pages/sites may not function properly if the cookies are turned off, or you may have to provide the same information each time you visit those pages.
11. Data Retention
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for. Retention periods for your personal information are decided by considering 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 requirements. In general terms, we will retain your information for 1 year after de-registration from the Website, or 1 year after our last communication with you.
12. Rights of access, correction, erasure, and restriction
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.
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 enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal information. This 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 the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact us in writing as per the foot of this Notice.
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 your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
13. Right to withdraw consent
You have the right to withdraw your consent for our holding and processing your personal information at any time. To withdraw your consent, please contact us as per the foot of this Notice. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
14. Access to Information
Unless otherwise prohibited by law, you will be granted the ability to access and correct any personally identifiable information. Better Journeys will take reasonable steps to verify your identity before granting such access. Each service that collects personally identifiable information will allow for review and update of that information.
Any use of the Websites shall conform to all Guernsey laws, rules, and regulations. Unauthorized attempts to upload information or alter information on these websites are strictly prohibited. By visiting these websites, you agree that you will not use the site for a manner that violates this Policy or is illegal, obscene, threatening, defamatory, invasive of privacy, infringing of intellectual property rights (publicity rights), or otherwise injurious to third parties or objectionable.
The Websites provide for voluntary Registration including access to Toolkits ("the Facilities").
You agree to maintain and update this Registration Data as required to keep it current, complete, and accurate.
When you register you will create a user ID and password in order to provide the information required. You must ensure that your password is kept secure and confidential and that it is not revealed to any person. You are entirely responsible for any and all activities that occur under or through the use of your password.
In consideration of being permitted to access the Facilities, you hereby agree to release, indemnify, and hold harmless Better Journeys from and against any and all claims, demands, judgments or liability for damage to persons or property of any kind or nature arising directly or indirectly out of your use of the Website or access to the Facilities.
We may terminate your access to the Facilities at any time, with or without cause, with or without notice, effective immediately, for any reason whatsoever. You may terminate your registration at any time.
17. External Website Links
The Websites contain links to external websites to navigate publicly available information from organisations that are not part of Better Journeys and over whom we exercise no control. The inclusion of these links should not be construed as an endorsement or sponsorship of these external websites, their content, viewpoints, products, services, or their hosts. The privacy policies and procedures described here do not apply to those sites, although they may be similar. We suggest contacting these sites directly for information on their data collection and distribution policies.
While Better Journeys makes the information contained within these websites available to anyone, we retain copyright on all text, graphic images, and other content. This means you may not: distribute the text or graphics to others without express written permission of Better Journeys; ‘mirror’ this information on your server without our permission; or modify or re-use the text or graphics on this system. You may: print copies of the information for your own personal use and reference this server from your own documents. Better Journeys reserves all other rights.
Better Journeys is neither responsible nor liable for any delays, inaccuracies, errors, or omissions arising out of your use of the Websites or with respect to the material contained on the Websites, including without limitation, any material posted on the Websites or any viruses or other contamination of your system. The Websites and all materials contained on it are distributed and transmitted “as is” without warranties of any kind, either expressed or implied, including without limitations, warranties of title or implied warranties of merchantability or fitness for a particular purpose. Better Journeys is not responsible for any special, indirect, incidental, or consequential damages that may arise from the use of, or the inability to use, the Websites and/or the materials contained on the Websites whether the materials contained on the Websites are provided by Better Journeys or a third party. Better Journeys is neither responsible nor liable for any viruses or other contamination of your system.
This Policy is intended to cover the collection of information through the Websites from residents of Guernsey. If you are not a resident of Guernsey or are visiting the Websites from outside Guernsey, and submit any of your personal information through the Websites, please be aware that your information may be transferred to, stored in, or processed in Guernsey. The data protection and similar laws of Guernsey may be different than those in other parts of the world.
21. Communications regarding Privacy
Communications should be addressed to:
By email; email@example.com
By post; The Better Journey Project, La Sauvarinerie, Rue a l'Eau, Castel, GY5 7AL
Updated: 03 May 2022
Mobile phone number if provided – sections 4, 8
Clarification regarding Registration – sections 5.1, 11, 16
Clarification regarding Better Journey Day Pledge or Commitment – section 6