Privacy Policy

Seymour (Services) Limited, referred to as ‘Seymour’, ‘we’ or ‘our’, is committed to protecting the privacy and security of your personal information.

This Privacy Notice describes how we collect and use personal information about you during and after your relationship with us pursuant to the Data Protection (Jersey) Law 2018 (“DPJL”).

Seymour is a “Data Controller“, meaning we are responsible for deciding how we hold and use personal information. We are also registered with the Jersey Office of the Information Commissioner (“JOIC”) – Registration No. 17973.

We will comply with data protection law, the principles of which says that the personal information we hold about you must be: -

•    Used lawfully, fairly and transparently
•    Collected only for valid purposes that we have clearly explained to you and not used in any way incompatible with those purposes
•    Relevant to the purposes we have told you about and limited only to those purposes
•    Accurate and kept up to date
•    Keep your data only for as long as necessary for the purposes we collect
•    Kept securely

Seymour is accountable to you and the authorities for showing compliance with DPJL and demonstrating how we are compliant.

We have appointed a DPO to oversee compliance with this Privacy Notice.

If you have any questions about this Privacy Notice or how we handle your personal information, contact the DPO at DPA@seymourhotels.com.

You have the right to complain to the JOIC at any time.

Contact details for these are outlined at the bottom of this Privacy Notice.

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).

To explain this, we will list our different services when we collect or use additional information about you.

When you contact us, engage us to provide a service or provide us with your data for another specific purpose, and we collect personal information about you.

What information do we collect about you?

•    Name
•    Title
•    Date of birth
•    Address
•    Identification documents
•    Telephone number
•    Occupation
•    Email address
•    Signature
•    Bank details 
•    Vehicle registration numbers

What Special Category information do we collect about you?

•    Health information
•    Mobility information
•    Sight or hearing impairments

Seymour uses CCTV in their hotels and leisure facilities to capture your image when you enter and any movement within these buildings and surrounding areas. CCTV is also used within some of the office buildings, external car parks, external areas, entrances, stairways, corridors, and elevators. CCTV is used to detect and prevent crime, ensure the safety of residents and visitors to the premises, and ensure the health and safety of any Seymour staff or contractors working on the premises. It is also used in any internal team member disputes or disciplinaries. All recordings are retained for 30 days.

When you contact Seymour by telephone, the calls are recorded for training and customer service. These recordings can be used as evidence if any party is rude or abusive and will be retained for 7 days only.

We will only use your personal information when the law allows us to. 

Most commonly, we will use your personal information in the following circumstances:

•    You have entered a Contract with us to provide you with a service; an example would be when you entered into a tenancy agreement with us for one of our properties
•    The processing is necessary for Legal Obligation; this is where Seymour has a legal duty to process your information; for example, under the Housing laws, we must ensure you are entitled to live in the property we provided
•    Where the processing is allowed under Public Function, we can share data with other parties, such as the government, to ensure we have accurate details about you and your circumstances
•    Where it is necessary for our Legitimate Interests (or those of a third party), your interests and fundamental rights do not override those interests. An example is when we use CCTV to monitor the safe environments where you live or record telephone conversations for training and customer service purposes

We may also use your personal information in the following situations, which are likely to be rare:

• You have Consented to contact us for a specific purpose, such as receiving marketing material about Seymour services or being on a waiting list for a home

We will only use your personal information for the purposes we collected it unless we reasonably consider that we need to use it for another reason. That reason is compatible with the original purpose. 

If we need to use your personal information for an unrelated purpose, we will notify you and explain the legal basis that allows us to do so.

We do not pass on information gained from your engagement with us without a clear legal basis. However, we may disclose your Personal Information to meet legal obligations, regulations, or valid governmental requests.

We use certain third parties, or Processors, to provide or support our services. We have appropriate agreements with those processors to ensure the safety of your information. For information on these processors, please see the table below.

If you are on our waiting list of individuals looking to rent or purchase a property, we share your information with processors for direct marketing purposes. In this instance, we will provide your information to authorised local estate agents who will assist us with the available properties.

The current data processors used by Seymour are available to view on their website.

Processors are other organisations/services carefully chosen by Seymour to process your information correctly and securely. In the case of organisations outside of Jersey, the United Kingdom and the European Economic Area (EEA):

(a) we have prior written instructions for the transfer

or 

(b) We have entered specific contractual terms with them to ensure that they treat your personal data in a way that is equivalent to what they would be required to do if they were established in Jersey

We ensure that your privacy rights are respected in accordance with this notice and that your data is protected as laid down by the DPJL.

Seymour is a very reputable owner of a group of hotels and leisure facilities in the tourism sector in Jersey, and we want to tell everyone about what is going on. Jersey is an amazing island to visit, so we want all our guests, current, past, and future, to know what is going on and what the Seymour experience is all about.

So, how do we let you know about all of this fantastic information? If you are a guest of Seymour or a user of any of our facilities, we will use Legitimate Interest to send you information about us and other cool stuff, letting you know about what is going on. We will always place an ‘Unsubscribe’ button on our digital communications.

If you have nothing to do with Seymour and have no business relationship with us but want to know what is going on with the tourism sector in Jersey, subscribe to our website and consent to us sending you this information. Again, we use Unsubscribe when you want this to stop.

You can also contact us or our DPM to withdraw your consent at any time. 

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, altered, disclosed, or accessed unauthorised. In addition, we limit access to your personal information to those Staff, Agents, Contractors and other third parties on a need-to-know basis. 

They will only process your personal information on our strict instructions and are subject to a duty of confidentiality. 

Details of these measures may be obtained from our DPO.

We have implemented procedures to deal with any suspected data security breach and notify you and any applicable regulator of a suspected breach where we are legally required.

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements. 

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data and the potential risk of harm from unauthorised use or disclosure of your data. The purposes for which we process your data and whether we can achieve those purposes through other means and the applicable legal requirements. 

You can request our Data Retention Schedule from our DPO if required.

In some circumstances, we may anonymise your personal information so that it can no longer be associated with you, in which case we may use it without further notice. 

Rights of Data Subjects

You may have certain legal rights concerning the Personal Information processed by Seymour pursuant to DPJL.

•    The rights of access
•    Right to have your data corrected, updated, rectified or erased
•    Right to object to the processing of or restrict the processing of your data
•    Right to withdraw your consent previously given to the processing of your data and to 
•    Request the transfer of your data to another party

Please note that the rights set out above are subject to certain exemptions and conditions. We may decline to comply with any request to access, correct, delete or restrict the use of your information if there is a specific legal ground or exemption.

Where we are processing your information based on contractual necessity or legal and regulatory requirements, the provision and processing of such information will likely be mandatory. In addition, where the provision of your Personal Information is generally a contractual or legal requirement or is a requirement for us to enter into a contract if you choose not to provide any Personal Information or to exercise one or more of the rights above to restrict the processing of your information, this may limit the services which Seymour can provide. 

If you wish to exercise any of your rights, send your request to DPA@seymourhotels.com. We will respond to your request in accordance with Data Protection Legislation.

We reserve the right to ask for proof of your identity and address (such as a copy of your driving license or passport - please do not send any original documents), and we also further reserve the right, under DPJL, to request for additional information reasonably required to identify the specific information being requested or referred to, or any additional information reasonably required to confirm your identity.

You can use the Data Subject Access Request form on our Cookie Banner or click here to complete our online form. If you have any questions about this process or your rights, contact our DPO at DPA@seymourhotels.com. You can also email or verbally make your request over the telephone to one of our team, whatever way you feel more comfortable with it.

We will respond to your request without undue delay, but certainly within Four Weeks after satisfactory identity verification. In some circumstances, we can apply an eight-week extension to this time frame if the request is complex and cannot be answered in four weeks. If this is to happen, we will inform you as soon as possible.

Pomme d’Or Hotel Wi-Fi and Chromecast Privacy Notice

Last updated: 11 March 2025

1. Introduction

Pomme d’Or Hotel, part of Seymour (Services) Limited, respects your privacy and is committed to protecting your personal data. This privacy notice explains how we collect, use, and safeguard your personal data when you use our Wi-Fi and Chromecast services. It complies with the Data Protection (Jersey) Law 2018 and ensures that you are fully informed about how your personal data is processed. By using our Wi-Fi and Chromecast services, you acknowledge that your personal data will be processed as described in this notice.

2. Who We Are

Seymour (Services) Limited, trading as Pomme d’Or Hotel, is the data controller responsible for processing your personal data when you use our Wi-Fi and Chromecast services. Our registered address is 1 Wharf Street, St Helier, Jersey JE4 0ZX. You can contact us for any data protection queries by writing to us at DPA@Seymourhotels.com.

If you have any questions about how we handle your personal data, you may also contact our Data Protection Officer, Paul Byrne, who can be reached at DPA@Seymourhotels.com.

3. What Personal Data We Collect

When you use our Wi-Fi and Chromecast services, we collect information about your device, including its MAC address, IP address, and device type. We record connection data, including log-in times, duration of connection, bandwidth usage, and general browsing activity in compliance with legal and security obligations. Chromecast usage data may be collected, including technical logs, but we do not track specific content viewed. If authentication or billing is required, we may also process your name, email address, and room number.

4. Why We Collect Your Data and Our Legal Basis for Processing

We collect and process your personal data to provide Wi-Fi and Chromecast services as part of the contract between you and Pomme d’Or Hotel. We use your data to ensure network security, prevent fraud, and maintain service functionality, which is in our legitimate interest as a hospitality provider. Some data processing is also necessary to comply with legal obligations, such as retaining connection logs for a specified period under applicable regulations. Where required, we may request your consent for optional processing activities, such as personalised service enhancements.

5. Who We Share Your Data With

We may share your personal data with WiFirst, our managed Wi-Fi service provider, to facilitate the operation and maintenance of the Wi-Fi and Chromecast services. If required by law, we may also disclose data to law enforcement authorities or regulatory bodies. Any data shared externally is managed under strict agreements to ensure it is protected and only used for lawful purposes.

6. International Data Transfers

Some of our service providers, including WiFirst, may process personal data outside Jersey. Where this occurs, we ensure that appropriate safeguards are in place to protect your rights, such as contractual clauses or reliance on jurisdictions that provide an adequate level of protection under data protection law.

7. How Long We Keep Your Data

We retain personal data only for as long as necessary to fulfil the purposes outlined in this notice. Connection logs and network usage data are retained for security and compliance reasons for a limited period, in accordance with our data retention policy. Personal data used for account authentication or billing is retained for as long as required to administer the service and meet legal obligations. Once data is no longer needed, it is securely deleted or anonymised.

8. Your Data Protection Rights

Under the Data Protection (Jersey) Law 2018, you have rights over your personal data. You have the right to request access to the data we hold about you and to ask for corrections if it is inaccurate or incomplete. You can request that we delete your personal data where it is no longer needed, subject to legal obligations requiring us to retain certain records. You have the right to object to processing based on legitimate interests and to request the restriction of processing in certain circumstances. If processing is based on your consent, you have the right to withdraw that consent at any time.

If you wish to exercise any of these rights, you can contact us using the details provided in this notice or click here to use our website portal. We will respond within the timeframe required by law.

9. Automated Decision-Making

We do not use your personal data for automated decision-making or profiling that has legal or similarly significant effects on you.

10. Complaints

If you have any concerns about how we process your personal data, we encourage you to contact us so we can resolve the issue. If you are not satisfied with our response, you have the right to lodge a complaint with the Jersey Office of the Information Commissioner. Further information about how to do this can be found at https://jerseyoic.org/ or by contacting them at enquiries@jerseyoic.org.

11. Data Provision Requirements

Providing personal data for Wi-Fi access and Chromecast services is not a statutory requirement, but some data, such as device identifiers, must be processed to provide network connectivity. If you choose not to provide the necessary data, you may not be able to use our Wi-Fi or Chromecast services.

12. Changes to This Privacy Notice

We may update this privacy notice from time to time to reflect changes in our services or legal requirements. Any updates will be posted on our website and made available when you connect to our Wi-Fi service. We encourage you to review this notice periodically to stay informed about how we handle your personal data.

For further information or to exercise your rights, please contact us at DPA@Seymourhotels.com.

In the limited circumstances where you may have provided your consent to collect, process and transfer your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. 

To withdraw your consent, contact our DPO at DPA@seymourhotels.com.

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.

We reserve the right to update this privacy notice at any time and will provide you with a new one when we make any substantial updates.

We may also notify you in other ways from time to time about processing your personal information or requesting you to confirm the accuracy of the information we hold on you.

We want to resolve any complaints you have about how we process your information. You have the right to complain to the JOIC about how we have used your data.

The details for each of these contacts are:

Seymour Limited
1 Wharf Street
St Helier
Jersey
JE4 0ZX 

Telephone: +44 (0)1534 875926
Email: DPA@seymourhotels.com

Jersey Office of the Information Commissioner (JOIC)
2nd Floor
5 Castle Street
St Helier
Jersey
JE2 3BT

Telephone: +44 (0)1534 716530
Email: enquiries@jerseyoic.org