We take your privacy very seriously.
We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation ((EU) 2016/679) (GDPR) which applies across the European Union (including in the UK) and we are responsible as “controller” of that personal information for the purposes of those laws.
This website is not intended for children and we do not knowingly collect personal information relating to children.
It would be useful to explain to you some key terms used in this policy:-
|We, Us, Our|
Greenzone Facilities Management Limited
|Our Data Protection Officer (DPO)|
We are not required to appoint a DPO but all enquiries regarding your personal information should be directed to our Company Secretary who is responsible for overseeing questions in relation to data privacy. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Company Secretary:
Telephone: 0845 884 4550
Address: The Corner House, Brunel Drive, Newark, Nottinghamshire NG24 2EG.
Any information relating to an identified or identifiable individual. It does not include data where the identity has been removed (anonymous data).
|Special category persoanl information|
Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership. Genetic and biometric data. Data concerning health, sex life or sexual orientation.
Personal Information We Collect About You
We may collect and use the following personal information about you:
- Identity Information any or all of first name, maiden name, last name, username or similar identifier, marital status, title, job title, date of birth and gender.
- Enhanced Identity Information in relation to the performance of services to certain customers with enhanced security requirements, any or all of previous name, previous address, nationality at birth, current nationality (if different to nationality at birth), whether you have ever possessed any other nationality or citizenship, immigration status, Home Office/Port Reference number and for spouse/partner, father, step father, mother and step mother: nationality now; nationality at birth; and place of birth.
- Contact Information any or all of billing address, delivery/collection address, email address and telephone numbers.
- Financial Information includes bank account and payment card details.
- Transaction Information includes details about payments to and from you and other details of services you have purchased from us.
- Technical Information 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 Information includes your username, purchases or orders made by you.
- Usage Information includes information about how you use our website and services.
- Marketing Communications and Newsletter (MCN) Information includes your preferences in receiving newsletters and marketing communications about our services (including non-waste services, e.g. energy, water and telecoms) from us and our third parties and your communication preferences.
We do not collect any Special Categories of Personal information about you. Nor do we collect any information about criminal convictions and offences.
How Your Personal Information Is Collected
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Enhanced Identity, Contact, Financial and MCN Information by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal information you provide when you:
- request our services;
- create and use an account in our CustomerZone on our website;
- sign up for our newsletter or to receive information about our non-waste services;
- supply goods or services to us; or
- contact us for any other reason.
- Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Information about your equipment, browsing actions and patterns. We collect this personal information by using cookies, server logs and other similar technologies.
Third parties or publicly available sources. We may receive personal information about you from various third parties and public sources as set out below:
Technical Information from the following parties:
(a) analytics providers such as Google and facebook pixel based outside the EU; and
(b) email marketing companies such as MailChimp based outside the EU.
- Identity and Contact Information from publicly available sources such as Companies House.
- From your employer before and when we provide services to your employer (or any member of your employer’s group) or if we receive services from your employer.
- IT Systems. For example, door entry systems and CCTV at our office.
How And Why We Use Your Personal Information
Under data protection law, we can only use your personal information if we have a proper reason for doing so. Proper reasons include complying with legal and regulatory obligations, for the performance of a contract with you, or for our legitimate interests or those of a third party, or where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
Generally we do not rely on consent as a legal basis for processing your personal information other than in relation to sending 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 at email@example.com.
The table below explains what we use (process) your personal information for and our reasons for doing so:
|What we use your personal information for||Our reasons|
|To provide our services||For our legitimate interest or those of a third party, to perform our contract with your employer or to take steps at the request of your employer before entering into a contract|
|To receive goods and services||For our legitimate interest or those of a third party, to receive services from your employer or for you to take steps at our request before entering into a contract with your employer|
|Conducting checks to identify our suppliers and their employees who are employed in the performance of a contract and verify their identity||To comply with our contractual, legal and regulatory obligations|
|Gathering and providing information required by or relating to enquiries or investigations by regulatory bodies||To comply with our legal obligation, for example to provide waste information to the Environment Agency if requested|
|Statistical analysis to help us manage our business, e.g. in relation to customer base, service range or other efficiency measures||For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for our customers at the best price|
To process and deliver services including:
(a) manage payments, fees and charges (paid by us or to us)
(b) collect and recover money owed to us
|For our legitimate interests to recover debts due to us and to pay suppliers|
|To manage our relationships with our customers and suppliers.|
Necessary to comply with contractual obligations
For our legitimate interests to comply with contracts and maintain good customer and supplier relationships
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)|
For our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise
To comply with a legal obligation
|To use data analytics to improve our website, services, marketing, customer relationships and experiences||For our legitimate interests to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy|
|To make suggestions and recommendations to you about services that may be of interest to you||For our legitimate interests to develop our services and grow our business|
|To notify you of updates in the waste management industry||For our legitimate interests to provide added-value to our customers|
|External audit and quality checks, e.g. for ISO and audit of our accounts|
For our legitimate interests or those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards
To comply with our legal obligations
Change Of Purpose
We will only use your personal information 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 information 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Who We Share Your Personal Information With
We routinely share personal information with the parties set out below for the purposes set out in the table above [How and why we use your personal information].
- Suppliers [acting as processors or joint controllers] we use to help deliver our services to our customers
- Customers to whom we provide services [acting as processors]
- Third parties we use to help us run our business [acting as processors or joint controllers], e.g. including email service providers, direct debit bureau, insolvency practitioners, Court Service, Collection Agencies, Bailiffs, Service Agencies, who provide email administration, direct debit administration, and for the purpose of payment collection/enforcement
- Regulatory bodies and authorities [acting as processors or joint controllers], e.g. the Environment Agency, the Health and Safety Executive, Information Commissioner’s Office, HM Revenue & Customs based in the UK who require reporting of activities in certain circumstances
- Professional advisers [acting as processors or joint controllers] including consultants, lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services
- Specific third parties such as MailChimp (email administration), MyColl Online (payment collection) and Bottom Line Technologies (direct debit administration)
- 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 information in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
Transferring Your Personal Information Out Of The EEA
Whenever we transfer your personal information 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 information to countries that have been deemed to provide an adequate level of protection for personal information by the European Commission. For further details, see European Commission: Adequacy of the protection of personal information in non-EU countries.
- Where we use providers based in the US (e.g. Mailchimp, facebook, google), we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal information shared between the 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.
Keeping Your Personal Information Secure
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know.
They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How Long Your Personal Information Will Be Kept
We will keep your personal information while you receive services from us or provide goods and services to us. Thereafter, we will keep your personal information for as long as is necessary:
- to respond to any questions, complaints or claims made in respect of any goods or services;
- to show that we treated your fairly;
- to keep records required by law, e.g. for accounting, legal, tax or reporting purposes.
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information. Please contact us if you require further information about our retention periods. Generally, we have to keep basic information about our customers and suppliers (including Contact, Identity, Financial and Transaction Data) for at least six years after they cease being customers for legal and tax purposes.
In some circumstances you can ask us to delete your data: see “Your Legal Rights” below for further information.
Your Legal Rights
You have the right to:
Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information 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 information. This enables you to ask us to delete or remove personal information 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 information 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 information 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 information 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 information 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 information. This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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 information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information 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 information. 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 services to you. We will advise you if this is the case at the time you withdraw your consent.
Data portability. This is the right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party – in certain situations.
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 information (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 may 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 information (or to exercise any of your other rights). This is a security measure to ensure that personal information 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 may 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.
This website or a newsletter 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 notice of every website you visit.
How To Complain
We hope we can resolve any query or concern you may raise about our use of your information.
However, 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) who may be contacted at https://ico.org.uk/concerns or telephone 0303 123 1113.
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 Notice And Your Duty To Inform Us Of Changes
This version was last updated on 24 May 2018.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.