Privacy Policy

This site is provided by Tiller Technologies Limited (also referred to as “Tiller”, “we”, “us”, or “our”), who is registered under the Companies (Jersey) Law 1991 as a private company, and is registered with the Jersey Registry under company number 129056.

We take the security of the data and information we hold seriously and are committed to protecting and respecting your privacy.  This Policy is designed to help you understand what kind of information we collect in connection with our services and how we will process and use this Personal Data.

This Policy describes how we collect, use, share, retain and safeguard Personal Data.  This Policy also sets out your individual rights and who you should contact if wishing to discuss the use of your Personal Data.

Please read the Policy carefully to understand our practices regarding your Personal Data and how we will; collect, use, share, secure and retain it.

Defining Personal Data

Personal Data is information relating to an identified or identifiable natural person.  Examples include an individual’s name, age, address, date of birth, gender and contact details.

Collection of Personal Data

When you or your organisation enters into an agreement with us to provide products and services, we ask you to give us some of your Personal Data to enable us to carry out our contractual obligations to you or your employer.  Failure to provide this information may prevent or delay the fulfilment of these obligations.

We also collect your Personal Data at other times, for example when you contact us.  We are committed to keeping all the Personal Data we hold about you secure, private and confidential.  This Policy explains why we need to collect your Personal Data and what we do with it.  It also sets out the legal basis on which we collect and use your Personal Data and outlines the rights you have under Data Protection (Jersey) Law 2018 and General Data Protection Regulation (“GDPR”) (Regulation (EU) 2016/679).

Use of Personal Data

When you browse our website www.tillertech.com, we will collect the Internet Protocol (“IP”) address of the device you are using, but will be unable to identify you at this point.  We collect this data so that we can identify where customers are dropping out of the website and to identify areas of improvement to make the experience more engaging for our customers.

We use cookies on our website, so please see our Cookie Policy below for more information.

Where you have consented to receive marketing from Tiller, we will collect the following information from you:

  • Your first and last name (so that we market to the right individual);
  • Email address (so that we send the marketing to the right place);
  • The marketing preferences indicated by yourself, such as your areas of interest and how you want to be marketed to; and
  • A record of your consent to confirm what you have consented to and when.

Where you request further information from us by completing a form on our website in relation to our products and services, your details will be added to our marketing database to receive marketing from Tiller relevant to the products and services you have an interest in.  We will collect the following data from you:

  • Your first and last name (so that we market to the right individual);
  • Email address (so that we send the marketing to right place); and
  • The marketing preferences indicated by yourself, such as your areas of interest and how you want to be marketed to.

Tiller attends numerous conferences and events.  Tiller will obtain from each event organiser a delegate list of all attendees who have consented to their personal data being shared with Tiller.

When your organisation enters into an agreement with Tiller to provide products and services, we will collect additional information, which is necessary for:

  • The performance of the contract we have with your organisation, such as billing information; and
  • Providing service updates related to the products and services Tiller are providing to you.

All personal data we collect is held electronically within our Microsoft Dynamics 365 Customer Relationship Management system (“CRM”) which is located in Microsoft Azure Cloud Data Services in the European Economic Area (“EEA”).

Sharing Personal Data

We use selected organisations to help us deliver the service we provide to you.  We may share your Personal Data with:

  • our service providers who provide data processing services to us, for example GB Group Plc (“GBG”) will provide identity solution services to organisations who enter into an agreement with us to provide WealthXcel Onboarding services with us.  We only share the data that’s necessary for them to provide their services.  GBG has offices in 22 locations; their registered head office is The Foundation, Herons Way, Chester Business Park, Chester, United Kingdom CH4 9GB.  Company Registration Number: 02415211.
  • Agencies and other organisations to check your identity, address and source of funds, and to prevent fraud and other financial crime.

We may also share your Personal Data with government bodies, law enforcement agencies, courts or other third parties to comply with our legal obligations or lawful disclosure requests, for example.

Securing Personal Data

We are committed to ensuring the confidentiality of the Personal Data that we hold and we continue to review our security controls and related policies and procedures to ensure that your Personal Data remains secure.

When we contract with third parties, we require that they have appropriate security, privacy and confidentiality measures in place to ensure that Personal Data is kept secure.

Retention of Personal data

We keep your Personal Data where we have an ongoing legitimate or lawful need to do so.  For example, we keep some records for audit purposes for up to seven years after the relationship with us has ended.  When we no longer have a legitimate or lawful need to keep your Personal Data, we will delete it.

Keeping each other informed

We will give you or your organisation information about the products and services we provide.  If we need to get in touch, we will call you or write to you by email and or post.  To make sure you can receive information and communications from us, please make sure you tell us whenever you change your name, address, phone number or email address.

Legal background and your rights

Here we summarise the lawful basis on which we collect and use your Personal Data and outline the rights you have under GDPR.

Lawful basis

The processing of Personal Data will only be lawful if it satisfies at least one of the following conditions:

  • Consent of the data subject;
  • Necessary for the performance of a contract with the data subject or to take steps preparatory to such a contract;
  • Necessary for compliance with a legal or regulatory obligation;
  • Necessary to protect the vital interests of a data subject or another person where the data subject is incapable of giving consent;
  • Necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; or
  • Necessary for the purposes of legitimate interests.

We have a legitimate interest in promoting our services.  For this reason, we may use your Personal Data to, for example, where explicit consent is given, send you marketing information about our own products or services that we think you may be interested in.  You can ask us to stop sending you marketing and/or research at any time by clicking on the “unsubscribe” links in any of the electronic messages we may use for marketing purposes or amending your communication preferences in account management.

Your rights

Under certain circumstances, you have the following rights in relation to your Personal Data such as, the right to:

  • Handling

You have the right to know what Personal Data we collect of you and how we process the data we have collected.

  • Access

You have the right to access Personal Data that we hold about you under GDPR by making a “Subject Access Request”.  You can request the form from info@tillertech.com or by writing to us:

Subject Access Request

Tiller Technologies Limited
5 St Andrews Place
Charing Cross
St Helier
Jersey
JE2 3RP

  • Rectify

You have the right to ask us to rectify Personal Data we hold about you if it is inaccurate or not complete.

  • Erasure

You can request that we erase your Personal Data.  We will keep basic data to identify you and retain it solely for preventing further unwanted processing.

  • Restricted Processing

You have the right to ask us to restrict how we process your data.  This means we are permitted to store the data but not further process it.  We keep just enough data to make sure we respect your request in the future.

  • Data Portability

Where processing is based on consent or performance of a contract, you have the right to data portability.  We must allow you to obtain and reuse your Personal Data for your own purposes in a safe and secure way without this effecting the usability of your data.  This right only applies to Personal Data that you have provided to us as the Data Controller.

  • Object to Processing

Where processing is based on legitimate interests, you have the right to object to us processing your data.  We will discontinue processing your data, unless we can demonstrate compelling legitimate grounds for the processing.  We will keep basic data to identify you and retain it solely for preventing further unwanted processing.

  • Right not to be subject to automated decision-making and profiling

If we have made a decision about you based solely on an automated process (e.g. through automatic profiling) that affects your ability to use the services or has another significant effect on you, you can ask to not to be subject to such a decision unless we can demonstrate to you that such decision is necessary for entering into, or the performance of, a contract between you and us.  Even where a decision is necessary for entering into or performing a contract, you may contest the decision and require human intervention.

Cookie Policy

This site uses cookies to distinguish you from other users of our site.

What is a Cookie?

A cookie is a small file of letters and numbers which asks permission to be placed onto your computer’s hard drive.  Once you have accepted a cookie the file is added to the hard drive of your computer.  Cookies help analyse web traffic and lets web applications respond to you as an individual.  Web applications can tailor their operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

Overall, cookies help us provide you with a better browsing experience, by enabling us to monitor which pages you find useful and which you do not.  A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

Use of Cookies

We implement the following type of cookies in our website:

  • Strictly necessary cookies

These cookies are essential to enable you to move around the website and use its features, such as accessing secure areas of the website.

  • Performance cookies

These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages.  These cookies don’t collect information that identifies a visitor.  All information these cookies collect is aggregated and therefore anonymous.  It is only used to improve how a website works.

We also use a common website analytics tool called Google Analytics which uses cookies similar to performance cookies, which gather and review analytic data such as number of site visits, average session duration, referral sources, devices used to access the website and browsers used to access the website.

Further information on Google Analytics can be found at www.google.com/analytics.

  • Functionality cookies

These cookies allow the website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features.

  • How to control Cookies

You can choose to accept or decline cookies.  Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer.  Disabling or blocking may prevent you from taking full advantage of websites, including ours.  When deleting cookies, please be aware that cookies that are already stored on your computer will not be affected. For that reason, you might want to delete the cookies already stored on your computer before deleting cookies on your browser.

Links to Third Party Websites or Other Services

Our site may contain links to other websites of interest.  However, once you have used these links to leave our site, you should note that we do not have any control over these other websites.  Tiller cannot be responsible for the protection and privacy of any information which you provide whilst visiting such websites and such websites are not governed by this Policy.  You should exercise caution and we encourage you to review the privacy policy applicable to the website in question.

Significant Changes

From time to time we may update this Policy.  You can see the latest version at www.tillertech.com.  If we make a significant change to how we use your Personal Data, we will let you know in advance.

Contact us

Tiller Technologies Limited is the Data Controller of the Personal Data we hold about you.  If you have questions about this Policy, or need further information about our privacy practices, please write to us:

Data Controller

Tiller Technologies Limited
5 St Andrews Place
Charing Cross
St Helier
Jersey
JE2 3RP

If you wish to raise a complaint about how we have handled your Personal Data, you can contact us and we will investigate the matter.

Data Protection Complaints

Tiller Technologies Limited

5 St Andrews Place
Charing Cross
St Helier
Jersey
JE2 3RP

If you are not satisfied with our response you can complain to the Jersey Office of the Information Commissioner (“JOIC”) at www.jerseyoic.org.

Date of Issue: 19th September 2019