PRIVACY POLICY
Welcome to Greenthread's privacy policy.
Greenthread respects your privacy and is committed to protecting your personal
data. This privacy policy will inform you as to how we look after your personal data
when you visit our website (regardless of where you visit it from) and tell you
about your privacy rights and how the law protects you.
Purpose of this privacy policy
This privacy policy aims to give you information on how Greenthread collects and
processes your personal data through your use of this website.
This website is not intended for children and we do not knowingly collect data
relating to children.
It is important that you read this privacy policy together with any other privacy
policy or fair processing policy we may provide on specific occasions when we are
collecting or processing personal data about you so that you are fully aware of how
and why we are using your data. This privacy policy supplements other notices and
privacy policies and is not intended to override them.
Controller
Greenthread Limited is the controller and responsible for your personal data
(collectively referred to as ["COMPANY"], "we", "us" or "our" in this privacy policy).
We have appointed a data protection officer (DPO) who is responsible for
overseeing questions in relation to this privacy policy. If you have any questions
about this privacy policy, including any requests to exercise [your legal rights],
please contact the DPO using the details set out below.
Contact details
If you have any questions about this privacy policy or our privacy practices, please
contact our DPO in the following ways:
Full name of legal entity: William Miller at Stronachs
Email address: William.Miller@stronachs.com
Postal address: 28 Albyn Place, Aberdeen, United Kingdom, AB10 1YL
You have the right to make a complaint at any time to the Information
Commissioner's Office (ICO), the UK supervisory authority for data protection
issues. We would, however, appreciate the chance to deal with your concerns
before you approach the ICO so please contact us in the first instance.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review.
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.
Third-party links
This website may include links to third-party websites, plug-ins and applications.
Clicking on those links or enabling those connections may allow third parties to
collect or share data about you. We do not control these third-party websites and
are not responsible for their privacy statements. When you leave our website, we
encourage you to read the privacy policy of every website you visit.
THE DATA WE COLLECT ABOUT YOU
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:
•
Identity Data includes [first name, maiden name, last name, username or
similar identifier, marital status, title, date of birth and gender].
•
Contact Data includes [billing address, delivery address, email address and
telephone numbers].
•
Financial Data includes [bank account and payment card details].
•
Transaction Data includes [details about payments to and from you and other
details of products and services you have purchased from us].
•
Technical Data includes [internet protocol (IP) address, your login data,
browser type and version, time zone setting and location, browser plug-in types
and versions, operating system and platform, and other technology on the
devices you use to access this website].
•
Profile Data includes [your username and password, purchases or orders made
by you, your interests, preferences, feedback and survey responses].
•
Usage Data includes [information about how you use our website, products and
services].
•
Marketing and Communications Data includes [your preferences in receiving
marketing from us and our third parties and your communication preferences].
We also collect, use and share Aggregated Data such as statistical or demographic
data for any purpose. Aggregated Data could be derived from your personal data
but is not considered personal data in law as this data will not directly or indirectly
reveal your identity. For example, we may aggregate your Usage Data to calculate
the percentage of users accessing a specific website feature. However, if we
combine or connect Aggregated Data with your personal data so that it can directly
or indirectly identify you, we treat the combined data as personal data which will
be used in accordance with this privacy policy.
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.
If you fail to provide personal data
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.
HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
•
Direct interactions. You may give us your [Identity, Contact and Financial Data]
by filling in forms or by corresponding with us by post, phone, email or
otherwise. This includes personal data you provide when you:
• apply for our products or services;
• create an account on our website;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us feedback or contact us.
•
Automated technologies or interactions. As you interact with our website, we
will automatically collect Technical Data about your equipment, browsing
actions and patterns. We collect this personal data by using cookies and other
similar technologies. We may also receive Technical Data about you if you visit
other websites employing our cookies. Please see our cookie policy for further
details.
•
Third parties or publicly available sources. We may receive personal data
about you from various third parties [and public sources] as set out below:
• Technical Data from the following parties:
(i) analytics providers;
(ii) advertising networks; and
(iii) search information providers.
• Contact, Financial and Transaction Data from providers of technical,
payment and delivery services
• Identity and Contact Data from data brokers or aggregators
• Identity and Contact Data from publicly available sources
HOW WE USE YOUR PERSONAL DATA
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:
• Where we need to perform the contract we are about to enter into or have
entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and
your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.
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.
Purposes for which we will use your personal data
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.
Marketing
We strive to provide you with choices regarding certain personal data uses,
particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a
view on what we think you may want or need, or what may be of interest to you.
This is how we decide which products, services and offers may be relevant for you
(we call this marketing).
You will receive marketing communications from us if you have requested
information from us or purchased goods or services from us and you have not opted
out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with
any third party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time.
Where you opt out of receiving these marketing messages, this will not apply to
personal data provided to us as a result of a product/service purchase, warranty
registration, product/service experience or other transaction].
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you
when websites set or access cookies. If you disable or refuse cookies, please note
that some parts of this website may become inaccessible or not function properly.
For more information about the cookies we use, please see our Cookie Policy.
Change of purpose
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.
DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below for the purposes
set out in the table above.
• Internal Third Parties.
• External Third Parties.
• Third parties to whom we may choose to sell, transfer or merge parts of our
business or our assets. Alternatively, we may seek to acquire other businesses
or merge with them. If a change happens to our business, then the new owners
may use your personal data in the same way as set out in this privacy policy.
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.
INTERNATIONAL TRANSFERS
We may share your personal data within the Greenthread Group. This will involve
transferring your data outside the European Economic Area (EEA).
Whenever we transfer your personal data out of the EEA, we ensure a similar
degree of protection is afforded to it by ensuring at least one of the following
safeguards is implemented:
• We will only transfer your personal data to countries that have been deemed to
provide an adequate level of protection for personal data by the European
Commission. For further details, see European Commission: Adequacy of the
protection of personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts
approved by the European Commission which give personal data the same
protection it has in Europe. For further details, see European Commission:
Model contracts for the transfer of personal data to third countries.
• Where we use providers based in the US, we may transfer data to them if they
are part of the Privacy Shield which requires them to provide similar protection
to personal data shared between Europe and the US. For further details, see
European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used
by us when transferring your personal data out of the EEA.
DATA SECURITY
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.
DATA RETENTION
How long will you use my personal data for?
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 customers (including Contact,
Identity, Financial and Transaction Data) for six years after they cease being
customers for [tax] purposes.]
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.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation
to your personal data:
Request access to your personal data (commonly known as a "data subject access
request"). This enables you to receive a copy of the personal data we hold about
you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you
to have any incomplete or inaccurate data we hold about you corrected, though we
may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or
remove personal data where there is no good reason for us continuing to process it.
You also have the right to ask us to delete or remove your personal data where you
have successfully exercised your right to object to processing (see below), where
we may have processed your information unlawfully or where we are required to
erase your personal data to comply with local law. Note, however, that we may not
always be able to comply with your request of erasure for specific legal reasons
which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate
interest (or those of a third party) and there is something about your particular
situation which makes you want to object to processing on this ground as you feel
it impacts on your fundamental rights and freedoms. You also have the right to
object where we are processing your personal data for direct marketing purposes.
In some cases, we may demonstrate that we have compelling legitimate grounds to
process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us
to suspend the processing of your personal data in the following scenarios:
• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need
it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we
have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will
provide to you, or a third party you have chosen, your personal data in a
structured, commonly used, machine-readable format. Note that this right only
applies to automated information which you initially provided consent for us to use
or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your
personal data. However, this will not affect the lawfulness of any processing
carried out before you withdraw your consent. If you withdraw your consent, we
may not be able to provide certain products or services to you. We will advise you
if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
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.
What we may need from you
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.
Time limit to respond
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.
GLOSSARY
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.
External Third Parties
• Service providers based the United Kingdom who provide IT and system
administration services.
• Professional advisers including lawyers, bankers, auditors and insurers based in
United Kingdom who provide consultancy, banking, legal, insurance and
accounting services.
• HM Revenue & Customs, regulators and other authorities based in the United
Kingdom who require reporting of processing activities in certain
circumstances.
