(for the Protection of Personal Information)
2. Important information and who we are
Full name of legal entity: Greengage & Co. Ltd
Postal address: 4th Floor, 33 Cavendish Square, Marylebone, London W1G 0PW
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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
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.
3. The types of personal data we collect
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 and process the following personal data about you:
Information that you provide to us. By “information” we mean all of the personal and financial information about you that we collect, use, share and store. This includes information about you that you provide to us. Such information may include (by way of a non-exhaustive list) basic personal data such as first name; family name; job title; company name; company email address; business phone number; business address; city; postcode; and country. Most of the information collected by us is information which you have provided to us directly, whether this is from you signing up online to receive information from us or by your providing information to us should you become a client of ours.
Information that we collect or generate about you. This includes (by way of a non-exhaustive list):
a file with your client records and contact history to be used for enquiry purposes; and
details of site and marketing/communication preferences.
Information we obtain from other sources. This includes:
Anonymised data. In addition to the categories of personal data described above, we will also process further anonymized information and data that is not processed by reference to a specific individual. Your information may be converted into statistical or aggregated data which cannot be used to re-identify you. It may then be used to produce statistical research and reports which may be shared within Greengage.
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).
4. How we use your personal data
4.1 Your personal data may be stored and processed by us in the following ways and for the following purposes:
for ongoing review and improvement of the information provided on our websites to ensure they are user friendly and to prevent any potential disruptions or cyber-attacks;
to conduct analysis required to detect malicious data and understand how this may affect your IT system;
for statistical monitoring and analysis of current attacks on devices and systems and for the on-going adaptation of the solutions provided to secure devices and systems against current attacks;
to understand your needs and interests;
for the management and administration of our business;
to communicate with you in order to provide you with services or information about the Greengage group of companies and its services, products and funds; or
in order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures.
4.2 However we use personal data we make sure that the usage complies with law and the law allows us and requires us to use personal data for a variety of reasons, including but not limited to the following:
in order to perform our contractual obligations;
where we have obtained your consent;
where we have legal and regulatory obligations that we have to discharge;
where we may need to do so in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings;
the use of your personal data as described is necessary for our legitimate business interests, such as:
allowing us to effectively and efficiently manage and administer the operation of our business; and
maintaining compliance with internal policies and procedures.
4.3 We will take steps to ensure that your personal data is accessed only by Greengage employees that have a need to do so for the purposes described in this Privacy Notice.
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.
5. Disclosures of your personal data
5.1 We may share your personal data within Greengage for the purposes described above.
5.2 We may also share your personal data outside of Greengage for the following purposes:
with third-party agents and contractors for the purposes of providing services to us (for example, our accountants, professional advisors, and IT and communications providers). These third parties will be subject to appropriate data protection obligations and they will only use your personal data as described in this privacy notice and in accordance with our instructions;
to the extent required by law, for example if we are under a duty to disclose your personal data in order to comply with any legal obligation (including, without limitation, in order to comply with tax reporting requirements and disclosures to regulators), or to establish, exercise or defend our legal rights; and/or
6. Storage, transfers and retention
The information that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (the “EEA”). It may be processed by staff who work for one of our service providers.
Where we transfer your information to another country outside the EEA, we will ensure that it is protected and transferred in a manner consistent with legal requirements. In relation to information being transferred outside of the EEA, for example, this may be done in one of the following ways:
the country that we send the information to might be approved by the European Commission as offering an adequate level of protection for information;
the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your information;
the country that we send the information to may subscribe to an “international framework” intended to enable secure data sharing;
where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme; or
in other circumstances the law may permit us to otherwise transfer your information outside the EEA.
7. Data security
We have 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 now. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
As a condition of employment, Greengage employees are required to follow all applicable laws and regulations, including data protection laws. Unauthorised use or disclosure of confidential client information by a Greengage employee is prohibited and may result in disciplinary measures.
We will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
How long will you use my personal data for?
We will retain information as needed to fulfill the purposes for which it was collected. We will retain and use your information as necessary to comply with our business requirements, legal obligations, regulatory obligations, resolve disputes, protect our assets, and enforce our agreements. We will not retain your information for longer than is reasonably necessary.
9. Your legal rights
In all the above cases in which we collect, use or store your personal data, you may have the following rights and, in most cases, you can exercise them free of charge. You have the right, among other things, to:
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. 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. Please note that there may be circumstances where you ask us to erase your information but we are legally entitled to retain it;
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 the DPG as detailed above.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). Greengage reserves the right to 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.
Our requirements 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.
We endeavour to respond to all legitimate requests within 30 days. Occasionally it may take us longer than the 30-day period if your request is particularly complex or you have made a series of requests. In such cases, we will notify you and keep you updated of our progress and expected response timeframes.