Your personal data is of upmost importance to us.
We will take appropriate technical and organisational measures to safeguard your personal information.
This Policy applies to personal information processed by or on behalf of GreenThumb Limited and as we have franchised businesses all companies, businesses, partnerships and individuals trading as GreenThumb Lawn Treatment Service (referred to in this policy as “we” or “us” or the “GreenThumb family”).
In this Policy we will:
Using our Services means:
2. What kinds of personal information about you do we process?
Personal information that we’ll process in connection with all of our Services, if relevant, includes:
3. What is the source of your personal information?
We’ll collect personal information from the following general sources:
4. What do we use your personal data for?
We use your personal data, including any of the personal data listed in section 1 above, for the following purposes:
5. What are the legal grounds for our processing of your personal information (including when we share it with others)?
We rely on the following legal bases to use your personal data:
1. Where it is needed to provide you with our products or services, such as:
a) Assessing a request for our Services, including to consider whether or not to offer you our Services, the price, the payment methods available and the conditions to attach
b) Managing our Services to you, or a request for our Services
c) Updating your records, to contact you about your account
d) Sharing your personal information with business partners and services providers when you request our Services to help manage your order, for example making arrangements for the supply and collection of materials from one of our partners at your home for a Lawn Makeover.
e) All stages and activities relevant to managing our Services including enquiry, application, administration and management of accounts, quotes, requests for beneficiaries to receive our services, setting up/changing/removing details including of beneficiaries
f) For some of our profiling and other decision making to decide whether to offer you our Services (for example depending on the layout of your property and the availability of safe access and egress), particular payment method and the price or terms of this.
2. Where it is in our legitimate interests to do so, such as:
a) Managing our Services relating to that, updating your records, tracing your whereabouts to contact you about your account and doing this for seeking payments (where appropriate)
b) To perform and/or test the performance of our Services and internal processes
c) To follow guidance and recommended best practice of government and regulatory bodies
d) For management and audit of our business operations including accounting
e) To carry out monitoring and to keep records of our communications with you and our staff (see below)
f) To administer our good governance requirements, such as internal reporting and compliance obligations or administration required for auditing purposes
g) For market research and analysis and developing statistics
h) For direct marketing communications and related profiling to help us to offer you relevant Services, including deciding whether or not to offer you certain Services. We will send marketing to you by SMS, email, phone, post and social media and digital channels (for example, using Facebook Custom Audiences and Google Custom Match)
i) Subject to the appropriate controls, to provide insight and analysis of our customers to business partners either as part of providing products or Services, helping us improve products or Services, or to assess or to improve the operating of our businesses
j) For some of our profiling and other decision making
k) Where we need to share your personal information with people or organisations in order to run our business or comply with any legal and/or regulatory obligations
3. To comply with our legal obligations
4. With your consent or explicit consent:
a) For some direct marketing communications
b) For some of our profiling and other decision making
c) For some of our processing of special categories of personal data, such as about your health, or of a family member or beneficiary if relevant to making adjustments to the manner in which we provide our Services.
5. For a public interest, such as:
a) Processing of your special categories of personal data such as about your health, or of a family member or beneficiary where it relates to making adjustments in the arrangements for our Services.
6. When do we share your personal information with other organisations?
We may share information with the following third parties for the purposes listed above:
7. Your rights?
You have the right to:
We will make reasonable efforts to comply with your requests except where we are permitted or required to do so under applicable law. Requests are free of charge however we reserve the right to charge a small fee to cover administrative costs should we consider any request to be excessive, unfounded or unreasonable.
8. Is your personal information transferred outside the UK or the European Economic Area?
We’re based in the UK and your personal information will be stored and processed in the United Kingdom, however, it may also be processed by companies operating outside of the EEA who work for us or for one of our service providers. We will put in place appropriate protection to make sure your personal data remains adequately protected and is treated in line with this Policy.
9. External service providers
We may engage third party companies and individuals to facilitate our Services to you such as payment, data storage or website related services. These third parties may have access to your personal information only to perform these tasks on our behalf and they are obliged through contract not to use your personal information for any other purpose or to disclose your personal information to any third party without our express consent.
10. What should you do if your personal information changes?
We want to make sure that the personal data we hold about you is accurate and up to date and so if any of the details are incorrect you should tell us so that we can update our records using the details in the Update My Details section of our website. We’ll then update your records if we can.
11. Do you have to provide your personal information to us?
We’re unable to provide you with our Services if you do not provide certain information to us. In cases where providing some personal information is optional, we’ll make this clear.
12. Do we do any monitoring involving processing of your personal information?
In this section monitoring means any: listening to, recording of, viewing of, intercepting of, or taking and keeping records (as the case may be) of calls, email, text messages, social media messages, in person (face-to-face) meetings and other communications.
We may monitor where permitted by law and we’ll do this where the law requires it, or to comply with regulatory rules, in the interests of protecting the security of our communications systems and procedures and for quality control and staff training purposes. This information may be shared for the purposes described above.
13. For how long is your personal information retained by us?
Unless we explain otherwise to you, we’ll hold your personal information based on the following criteria:
Your consent to the use of your personal information for such purposes remains valid after the termination of our relationship with you to the extent permitted by applicable law so long as you do not request otherwise, where permitted.
We may anonymise your personal data (in order that you can no longer be identified) for research or statistical purposes and under these circumstances we may retain this information indefinitely.
14. What are your rights under data protection laws?
Here is a list of the rights that all individuals have under data protection laws. They don’t apply in all circumstances. If you wish to use any of them, we’ll explain at that time if they are engaged or not. The right of data portability is only relevant from 25th May 2018.
You have the right to complain to the Information Commissioner’s Office which enforces data protection laws: https://ico.org.uk/. You can contact us using the details below.
15. Your right to object
You have the right to object to certain purposes for processing, in particular to data processed for direct marketing purposes and to data processed for certain reasons based on our legitimate interests although we will be required to continue to process certain personal information in order to provide our Services to you and for legal reasons. You can contact us by going to the Update My Details section of our website to exercise these rights.
16. What are your marketing preferences and what do they mean?
We may use your home addresses, phone numbers, email addresses and social media or digital channels (for example, Facebook, Google and message facilities in other platforms) to contact you according to your marketing preferences. You can stop our marketing at any time by contacting us using the details below or by following the instructions in the communication you receive.
If you have any questions about this policy, or if you wish to exercise your rights or contact the DPO, you can contact us by going to the Contact Us section of our website https://greenthumb.co.uk/contact-us or by writing to the below address, marking it for the attention of the DPO.
Alternatively, you can write to GreenThumb Limited, Integra, Ffordd William Morgan, St Asaph Business Park, St Asaph, Denbighshire LL17 0JD marking it for the attention of the DPO.