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Privacy Policy

A legal disclaimer

The explanations and information provided on this page are only general and high-level explanations and information on how to write your own document of a Privacy Policy. You should not rely on this article as legal advice or as recommendations regarding what you should actually do, because we cannot know in advance what are the specific privacy policies you wish to establish between your business and your customers and visitors. We recommend that you seek legal advice to help you understand and to assist you in the creation of your own Privacy Policy. 

Privacy Policy - the basics 

Having said that, a privacy policy is a statement that discloses some or all of the ways a website collects, uses, discloses, processes, and manages the data of its visitors and customers. It usually also includes a statement regarding the website’s commitment to protecting its visitors’ or customers’ privacy, and an explanation about the different mechanisms the website is implementing in order to protect privacy. 

 

Different jurisdictions have different legal obligations of what must be included in a Privacy Policy. You are responsible to make sure you are following the relevant legislation to your activities and location.

What to include in the Privacy Policy

Generally speaking, a Privacy Policy often addresses these types of issues: the types of information the website is collecting and the manner in which it collects the data; an explanation about why is the website collecting these types of information; what are the website’s practices on sharing the information with third parties; ways in which your visitors an customers can exercise their rights according to the relevant privacy legislation; the specific practices regarding minors’ data collection; and much much more. 


To learn more about this, check out our article “Creating a Privacy Policy”.

Privacy Notice

1. About this notice

This Privacy Notice explains how Generational Limited, trading as Generational, collects, uses and protects personal information when you visit this website, contact us, or sign up to receive updates.

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Generational Limited is registered in Jersey under registered business number 163846 and is regulated by the Jersey Financial Services Commission in respect of trust company business under the Financial Services (Jersey) Law 1998.

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For the purposes of applicable data protection law, Generational Limited is the controller of the personal information described in this notice.

This notice should be read alongside our Cookie Policy and Legal & Regulatory Notice.

2. Data protection law

We process personal information in accordance with applicable data protection laws, including the Data Protection (Jersey) Law 2018.

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Where UK or EU data protection law applies, we will comply with those requirements as applicable.

3. Personal information we collect

We may collect and use the following personal information:

  • contact information, such as your name, email address, telephone number, organisation and role;

  • enquiry information, such as messages or information you submit through forms, email or other contact routes;

  • marketing preference information, such as whether you have asked to receive updates from us;

  • technical information, such as IP address, browser type, device information, pages visited, referral source and website usage data.

 

We do not currently use this website to collect detailed trust, family, financial, source-of-wealth, identity-verification or client-onboarding information.

4. How we collect personal information

We may collect personal information:

  • directly from you when you complete a form, sign up for updates, contact us or otherwise communicate with us;

  • automatically through cookies and similar technologies when you use our website;

  • from basic website analytics and security tools.

5. How we use personal information

We may use your personal information to:

  • respond to enquiries;

  • send you updates where you have asked to receive them;

  • manage launch, product, service or company updates;

  • maintain a record of your communication preferences;

  • operate, secure, monitor and improve this website;

  • comply with legal or regulatory obligations;

  • ​protect our rights, systems, users and business.

6. Lawful bases for processing

We will only use personal information where we have a lawful basis to do so. Depending on the circumstances, we may rely on:

Purpose

Responding to enquiries

Sending updates you have requested

Managing marketing preferences

Website operation, security and essential analytics

Non-essential cookies or analytics

Legal, regulatory or compliance purposes

Lawful basis

Legitimate interests or taking steps before entering into a contract

Consent or legitimate interests, depending on the communication and applicable law

Consent, legitimate interests and legal obligations

Legitimate interests

Consent, where required

Legal obligations or legitimate interests

7. Marketing and updates

We will only send you marketing communications or updates where permitted by law. You can unsubscribe at any time by using the unsubscribe link in our emails or by contacting us.

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We may keep a suppression record to make sure we do not send you marketing communications after you have opted out.

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We will not sell your personal information.

8. Who we share personal information with

We may share personal information where lawful and necessary with:

  • website, hosting, email, CRM, analytics, security and technology service providers;

  • professional advisers, such as lawyers, accountants, auditors, regulatory or compliance advisers, where necessary for legal, regulatory, governance or business purposes;

  • regulators, public authorities, law-enforcement agencies or courts, where required;

  • other parties where necessary to protect our rights, users, systems or business;

  • other parties where you have asked us to share information or where we are legally permitted or required to do so.

 

We require service providers to protect personal information and use it only for authorised purposes.

9. International transfers

Some of our service providers may process personal information outside Jersey. Where required, we will use appropriate safeguards or lawful transfer mechanisms, such as adequacy decisions, contractual protections or other safeguards permitted by applicable data protection law.

10. How long we keep personal information

We keep personal information only for as long as reasonably necessary for the purposes for which it was collected.

Type of information

Website enquiries

Update / mailing-list records

Suppression records

Website analytics and cookie data

Legal or regulatory records

Indicative retention approach

Retained for as long as needed to respond, manage follow-up and meet legal or risk-management needs

Retained until you unsubscribe or we no longer send updates

Retained as needed to respect your opt-out

Retained as described in our Cookie Policy or cookie settings

Retained as long as needed to meet applicable legal, regulatory or dispute-related requirements

11. Security

We take appropriate technical and organisational measures to protect personal information against unauthorised access, loss, misuse, alteration or disclosure.

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No website, system or transmission is completely secure. You are responsible for taking appropriate precautions when using the internet and communicating electronically with us.

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If a data security incident occurs, we will take appropriate steps and notify affected individuals or regulators where required by law.

12. Accuracy of your information

Please ensure that any personal information you provide to us is accurate and kept up to date. If your details change, please contact us so that we can update our records.

13. Your rights

Depending on the circumstances and applicable law, you may have rights to:

  • access your personal information;

  • request correction of inaccurate or incomplete information;

  • request deletion of your personal information;

  • restrict or object to certain processing;

  • request data portability;

  • withdraw consent where processing is based on consent;

  • object to direct marketing;

  • complain to a relevant data protection authority.

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These rights are not absolute and may be subject to exemptions or limitations.

14. Cookies

Our website may use cookies and similar technologies to operate the website, improve performance, understand usage and support security. For more information, please see our Cookie Policy.

15. Contact us

To contact us about this Privacy Notice or to exercise your data protection rights, please use the contact details provided on this website.

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Please include enough information for us to identify you and respond to your request. We may need to verify your identity before acting on certain requests.

16. Complaints

If you are unhappy with how we handle your personal information, please contact us first so that we can try to resolve your concern.

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You may also have the right to complain to the Jersey Office of the Information Commissioner or another relevant data protection authority.

17. Changes to this notice

We may update this Privacy Notice from time to time. The latest version will be published on this website.

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