This website is not intended for minors. We do not knowingly collect personal information from children under the age of 13. If we become aware that we have inadvertently received personal information from a child under the age of 13, we will delete such information from our records.
For the purposes of General Data Protection Regulation ((EU) 2016/679) (EU GDPR), the UK retained law version of EU GDPR (UK GDPR), the UK Data Protection Act 2018 (UK DPA 2018), and the Jersey Data Protection (Jersey) Law 2018 (JE GDPR), where we are the party that determines the purposes and means of the processing of personal data, TCA Digital Ltd is the controller and responsible for your personal data.
However, we may also collect or be provided with certain personal data pursuant to our agreements with our clients and partners, which we process on their behalf. In this case, we act as a processor of the relevant client or partner, who remains the controller.
Our UK Representative
Under Article 27 of the UK Data Privacy Act, we have appointed a UK Representative to act as our data protection agent. Our nominated UK Representative is:
Our EU Representative
Under Article 27 of the GDPR, we have appointed an EU Representative to act as our data protection agent. Our nominated EU Representative is :
You have the right to make a complaint at any time to the supervisory body for the relevant jurisdiction you live in. In the UK this is the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
If you are a user of our services, we may be legally obligated under article 18 of the EU Market Abuse Regulation No 596/2014 (“MAR”) to collect and store personal data from you such as: (i) name and surname, (ii) personal identification number, (iii) surname by birth, (iv) private and work phone number, (v) position, and (vi) home address.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Type of data
|Lawful basis for processing
including basis of legitimate interest
|To register you as a new
|Performance of a contract with
|To process and deliver your
(a) Manage payments, fees and
(b) Collect and recover money
owed to us
|(a) Performance of a contract
(b) Necessary for our
legitimate interests (to recover debts due to us)
|To manage our relationship with
you which will include:
(a) Notifying you about changes
(b) Asking you to leave a review
or take a survey
|(a) Performance of a contract
(b) Necessary to comply with a
(c) Necessary for our
legitimate interests (to keep our records updated and to study how customers
use our products/services)
|To administer and protect our
business and this website (including troubleshooting, data analysis, testing,
system maintenance, support, reporting and hosting of data)
|(a) Necessary for our
legitimate interests (for running our business, provision of administration
and IT services, network security, to prevent fraud and in the context of a
business reorganisation or group restructuring exercise)
(b) Necessary to comply with a
|To deliver relevant website
content to you and measure or understand the effectiveness of the services we
provide to you
|Necessary for our legitimate
interests (to study how customers use our products/services, to develop them,
to grow our business and to inform our marketing strategy)
|To use data analytics to
improve our website, products/services, marketing, customer relationships and
|Necessary for our legitimate
interests (to define types of customers for our products and services, to
keep our website updated and relevant, to develop our business and to inform
our marketing strategy)
|To make suggestions and
recommendations to you about goods or services that may be of interest to you
|Necessary for our legitimate
interests (to develop our products/services and grow our business)
We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may share your personal data with the parties set out below for the purposes set out in the table above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We store and process your personal data on servers located within Jersey, the UK and the European Union (the “EU”).
Whenever we transfer your personal data out of the EU, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
TCA employs encryption technology to protect certain transmissions of data to/from the Services, but e-mail and other communications are not encrypted. By employing e-mail or other insecure electronic communication means you acknowledge that you have no expectation of privacy with respect to the information delivered and that TCA will not be responsible for any loss or damage that could result from interception by third parties of any information so sent.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider 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, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for six years after they cease being clients.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
If you wish to exercise any of the rights set out above, please contact us .
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
External third parties means:
Internal third parties means other companies in our Group (acting as joint controllers or processors) and who are based Jersey and provide IT and system administration services and undertake leadership reporting.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.