This privacy notice was published on 12 March 2025.

Capitalised terms used herein are defined in the Schedule.

1. Privacy Policy and Notice

1.1 Myrecoverease Limited places a high priority on safeguarding your privacy. Please review this privacy notice as it contains important information about us and about the methods and rationale behind the collection, utilisation, retention, and sharing of your Personal Data. Additionally, it outlines your rights concerning your Personal Data and provides guidance on addressing any concerns.

1.2 The purpose of this privacy notice is to address the handling of Personal Data when you engage with us as a Data Subject, in your capacity as a customer. As an entity collecting, utilising, or assuming responsibility for your Personal Data, we must comply with Data Protection Laws.

1.3 The primary establishment (or place of business) of Myrecoverease is in Jersey. The Office of the Information Commissioner, Jersey, serves as the primary supervisory authority for Myrecoverease Limited. Jersey's legal framework for data protection has been certified as 'adequate' under the EU Data Law, indicating equivalence to the required standards.

1.4 Myrecoverease utilises software for rental inventory, bookings and sales. Your Personal Data will be stored on the software (which may include Cloud storage) in order for Myrecoverease to provide services to you. The software is provided by the company Salad Days B.V. (trading name Booqable ((Booqable)) of Blokhuisplein 40, 8911 LJ Leeuwarden, the Netherlands.

1.5 Booqable can be contacted using the following telephone number: +31 20 808 1554 and the following email address: [email protected]. Booqable work in accordance with the requirements for the processing of personal data laid down in privacy legislation including the General Data Protection Regulation. Booqable’s privacy policy can be found on its website here: Privacy and cookie statement - Booqable.

1.6 You can contact us by post, email or telephone if you have any questions about Myrecoverease’s privacy policy or the information we hold about you, to exercise a right under the Data Protection Laws or to make a complaint. Our email address is [email protected], our telephone number is 07985657410 and our postal address is 20 St Peter’s Country Apartments, Le Mont Fallu, St Peter, Jersey, JE3 7GZ. Please contact us directly if you have any queries or concerns about our use of your Personal Data.

1.7 You can also complain to the Office of the Information Commissioner, Jersey, known as “JOIC”. You can lodge a complaint with JOIC:

    1.7.1 using the JOIC website: https://jerseyoic.org

    1.7.2 by email: [email protected]

    1.7.3 by calling: 01534 716530

1.8 We may update this privacy notice from time to time. The current privacy notice can be found on our website at the following address: https://www.myrecoverease.je.

2. Reasons for processing

2.1 Under Data Protection Laws, we can only use your Personal Data if we have a proper reason, including:

    2.1.1 where you have given consent;

    2.1.2 to comply with our legal and regulatory obligations;

    2.1.3 for the performance of the Agreement or other contract with you or to take steps at your request before entering into the Agreement or other contract;

    2.1.4 in the substantial public interest;

    2.1.5 to protect your vital interests; or

    2.1.6 where necessary for the purposes of our legitimate interests (as described in clause 2.2) or those of a third party.

2.2 A legitimate interest includes when we have a business or commercial reason to use your non-sensitive Personal Data, as long as your rights and interests do not override this. We will carry out an assessment when relying on legitimate interests to balance our interests against your own.

2.3 Where our basis for Processing your Personal Data is your consent, you can withdraw such consent without penalty.

2.4 In most cases we envisage that your Personal Data will be processed to enable Myrecoverease to enter into, perform their obligations under or do anything else required in relation to an Agreement or other contract between you and the company.

3. Information processed

3.1 We will Process Personal Data in accordance with the law and your reasonable expectations. Depending on the nature of our interaction with you, the Personal Data we will Process may encompass:

    3.1.1 contact information, including your postal address, email address(es), telephone number(s), company details and, where applicable, social media contact information;

    3.1.2 identity information, including your current and former names, sex, date and place of birth, nationality and proof of identity if requested (such as copy passport information);

    3.1.3 preference information, including dietary restrictions and preferred correspondence language;

    3.1.4 verification information, including government-issued documents, bank statements, and utility bills;

    3.1.5 financial information, including bank account information;

    3.1.6 connected persons information, including information about familial relationships;

     3.1.7 information in the public domain;

    3.1.8 correspondence between you, your agents/representatives, and us;

    3.1.9 billing, transaction and payment information; and

    3.1.10 technical data, including information about how you use our website, IT, communication and other systems.

3.2 When you first access our website, our cookie information is displayed on the home page in the bottom right corner. Further information on how we process cookie data can be obtained by contacting our Alexander Budd, 20 St Peter’s Country Apartments, Le Mont Fallu, St Peter, Jersey, JE3 7GZ, [email protected] or 07985657410.

3.3 We collect and use this Personal Data (and will store it on software provided by Booqable) to be able to enter into Agreements, other contracts and to provide any other relevant services to you. If you do not provide the Personal Data we ask for, it may delay or prevent us from entering into Agreements, other contracts or providing other relevant services to you.

4. Collection

4.1 We collect most of this Personal Data from you, by telephone, video call, text or email and via our website (using Booqable’s software). However, we may also collect information:

    4.1.1 from publicly accessible sources;

    4.1.2 from a third party with your consent;

    4.1.3 from cookies on our website;

    4.1.4 via our IT systems, for example:

      (i) from door entry systems and reception logs; and

      (ii) through automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems.

4.2 We may, from time to time, record telephone calls.

5. Use

5.1 We may use your data in the following ways and for the following reasons:

    5.1.1 When we are preparing to fulfil or fulfilling any Agreement or other contract or service as agreed with you:

      (a) The reason for the processing is to perform the Agreement, other contract or service with or to you or to take steps at your request before entering into any Agreement, contract or service.

    5.1.2 Preventing and detecting fraud or other unlawful financial activity against you or us:

      (a) The reason for the processing is to minimise fraud or other unlawful financial activity that could be damaging for you and/or us.

    5.1.3 Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies:

      (a) The reason for the processing is to comply with our legal and regulatory obligations.

    5.1.4 Operating IT systems, software (including the software provided by Booqable) and business applications:

      (a) The reason for the processing is to provide any agreed services to you safely and efficiently.

    5.1.5 Ensuring security and internet use policies are adhered to:

      (a) The reason for the processing is to ensure we are following our own internal procedures to deliver the best service to you.

    5.1.6 Operational reasons, such as improving efficiency, training and quality control:

      (a) The reason for the processing is to be as efficient as possible so we can deliver the best service to you at the best price.

    5.1.7 Statistical analysis to help us manage our business, e.g. in relation to our financial performance:  

      (a) The reason for the processing is to be as efficient as possible so we can deliver the best service to you at the best price.

    5.1.8 Preventing unauthorised access and modifications to systems:

      (a) The reason for the processing is to prevent and detect criminal activity that could be damaging to you or us and to comply with our legal and regulatory obligations.

    5.1.9 Client/customer communication:

      (a) The reason for the processing is to perform our Agreement, contract or other service with or to you or to take steps at your request before entering into an Agreement or other contract, to comply with our legal and regulatory obligations, to make sure that we can keep in touch with our clients and customers about existing orders and new products and to update our records.

    5.1.10 Statutory returns:

      (a) The reason for the processing is to comply with our legal and regulatory obligations.

    5.1.11 Ensuring safe working practices, staff administration and assessments:

      (a) The reason for the processing is to comply with our legal and regulatory obligations and to ensure we are following our own internal procedures and working efficiently to deliver the best service to you.

    5.1.12 Marketing our services and those of selected third parties to existing and former customers; third parties who have previously expressed an interest in our services; and third parties with whom we have had no previous dealings:

      (a) The reason for the processing is to promote our business to existing and future clients.

    5.1.13 External audits and quality checks:

      (a) To comply with our legal and regulatory obligations.

    5.1.14 Conducting surveillance over electronic/telephonic communication; recording CCTV footage:

      (a) The reason for the processing is to assure service quality, for training, and to detect and prevent potentially unlawful conduct.

    5.1.15 To enforce or defend rights:

      (a) The reason for the processing is to ensure our rights and the rights of those under our scope of responsibility are protected, to liaise with regulatory authorities, and to ensure we meet our reporting obligations and commitment to government agencies that have jurisdiction.

6. Special Category Data

6.1 Where we Process your Special Category Data, we will also ensure we are permitted to do so under the Data Protection Laws for the following reasons:

    6.1.1 to protect your (or someone else's) vital interests where you are physically or legally incapable of giving consent;

    6.1.2 to comply with another law;

    6.1.3 to prevent unlawful acts, including money laundering or other financial misconduct, and the financing of terrorism;

    6.1.4 to establish, exercise or defend legal claims; or

    6.1.5 where we have your express consent.

7. Sharing data

7.1 We will share your Personal Data with relevant third parties (including Booqable) that we use to help deliver our services to you.

7.2 As required, we also share your Personal Data with:

    7.2.1 other third parties we use to help us run our business, e.g. marketing agencies or website hosts;

    7.2.2 organisations with whom we co-host marketing events;

    7.2.3 professional advisors, including lawyers, regulatory specialists, and tax advisers;

    7.2.4 IT service providers;

    7.2.5 our insurers and banks;

    7.2.6 intermediaries;

    7.2.7 third parties you approve, e.g. social media sites you choose to link your account to or third-party payment providers;

    7.2.8 government agencies to whom we have a disclosure obligation; and

    7.2.9 competent courts and tribunals who issue an order with which we are obliged to comply.

7.3 We only allow our service providers to handle your Personal Data if we are satisfied they take appropriate measures to protect it. Our service provider Booqable has a Data Protection Agreement in place in which they agree to only use your personal data to provide services to us and you.

7.4 On occasion, we may also need to:

    7.4.1 share Personal Data with external auditors;

    7.4.2 disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations; and

    7.4.3 share some Personal Data with other parties, such as potential buyers of some or all of our business or during a restructuring. Information will be anonymised, but this may not always be possible. However, the recipient of the information will be bound by confidentiality obligations.

8. Data Retention

8.1 We will keep your Personal Data while you have a relationship with us or we provide services. We will then keep your Personal Data for as long as necessary:

    8.1.1 to respond to any questions, complaints or claims made by you or on your behalf;

    8.1.2 to show that we treated you fairly;

    8.1.3 to keep records required by law.

8.2 Different retention periods may apply for different types of Personal Data. We reserve the right to keep all Personal Data for as long as the longest period required in relation to any particular item of your Personal Data, in order that we may manage your Personal Data efficiently. Once the relevant period has ended we will delete or anonymise the data.

9. Data sent abroad

9.1 Personal data may be held at our offices, third-party agencies (including Booqable), service providers (including CRM systems and servers), representatives and agents.

9.2 To deliver services to you, it is sometimes necessary for us to transfer your Personal Data to another jurisdiction in order to share it with our third party agencies (including Booqable).

9.3 We may transfer data to other jurisdictions on a routine basis or on an ad-hoc basis, as and when particular needs arise. We shall transfer data lawfully and in accordance with applicable requirements.

10. Contacting you

10.1 The utilisation of your Personal Data for marketing purposes involves sending you updates about our services, such as exclusive offers, promotions, or new services, via email, text message, telephone, or post.

10.2 In situations where we have a legitimate interest in utilising your Personal Data for marketing purposes, your consent is not typically required. However, if consent is necessary, it will be explicitly and separately requested.

10.3 You can opt out of receiving marketing communications at any time. This can be accomplished by contacting us at [email protected].

10.4 If you request additional services in the future or there are changes in the law, regulation, or our business structure, we may request your confirmation or update of your marketing preferences.

10.5 We will always treat your Personal Data with respect and refrain from selling or sharing it with other organisations for marketing purposes.

11. Rights

11.1 You may have the following rights in relation to your data, which you can exercise free of charge:

    11.1.1 Access - The right to be provided with a copy of your Personal Data

    11.1.2 Rectification - The right to require us to correct any mistakes in your Personal Data

    11.1.3 Erasure (also known as the right to be forgotten) - The right to require us to delete your Personal Data in certain situations.

    11.1.4 Restriction of processing - The right to require us to restrict processing of your Personal Data in certain circumstances.

    11.1.5 The right to object:

      (a) at any time to your Personal Data being processed for direct marketing (including profiling);and

      (b) in certain other situations to our continued processing of your Personal Data, e.g. processing carried out for the purpose of our legitimate interests.

    11.1.6 Not to be subject to automated individual decision making - The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.

11.2 In many cases, we will have a maximum of four weeks to respond to your request. However, it is important to note that in certain situations this timeframe can be extended by an additional eight weeks. The specificity and focus of your request will directly impact the speed at which we can assist you.

12. Safety of Data

12.1 The organisation has implemented appropriate security measures, both organisational and technical, to prevent any accidental loss, unlawful use, or unauthorised access to Personal Data. Access to Personal Data is strictly limited to individuals with a genuine business need, and they must process the information in an authorised manner and maintain confidentiality. Furthermore, the organisation has established procedures to address any suspected data security breaches.

12.2 In case of a suspected data protection breach, where legally required, you and the relevant supervisory authority will be promptly notified.

SCHEDULE

1 Definitions

1.1 Agreement means the equipment rental agreement between Myrecoverease and the customer.

1.2 Data Protection Laws means the EU Data Law, the Jersey Data Law, the Data Protection Authority (Jersey) Law 2018 and/or any other relevant and applicable equivalent legislation, including the Data Protection Authority (Jersey) Law 2018, as amended from time to time.

1.3 Data Subject means the person who is the subject of the Personal Data in question.

1.4 Data Lead means Alexander Budd.

1.5 EU Data Law means the General Data Protection Regulation 2016/679.

1.6 Equipment means the CTP machine, accessories or other assets that have been made available to you by Myrecoverease as part of the Agreement.

1.7 Jersey Data Law means the Data Protection (Jersey) Law 2018.

1.8 Personal Data under the Data Protection Laws means any information that identifies or could identify you and which is about you.

1.9 Processing means operations performed on Personal Data, 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.

2.0 Myrecoverease means the company known as Myrecoverease Limited (registered number 158053). When we mention 'we', 'us' or 'our' in this privacy notice, we are referring to the Myrecoverease Limited.

2.1 Special Category Data means Personal Data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs, trade union membership, genetic and biometric data (when processed to identify an individual uniquely), data concerning health, sex, life or sexual orientation, and in Jersey, criminal records or alleged criminal conduct.