Who we are
We are a data solutions business called greenstone data solutions Ltd. (“greenstone”) registered in England and Wales under company registration number 04811241, whose registered office is at C/O Kreston Reeves LLP, 3rd Floor, 24 Chiswell Street, London, EC1Y 4YX.
We are also members of the Direct Marketing Association (UK) and registered with the Information Commissioners Office; our data protection registration number is Z8230152.
We operate under the brand name of greenstone data solutions. We may provide data which is supplied to us by our data partners to marketing services organisations, media agencies, brokers and brands.
You can contact us about issues relating to personal data, including the contents of this policy, by any of the following methods:
Post: Compliance Manager, greenstone data solutions ltd., Suite 1, 40 Churchill Square Business Centre, Kings Hill, West Malling, Kent ME19 4YU
Telephone: 01732 240290
Subjects Covered in this Policy
- What do we use your data for?
- Legal Basis for Processing: Legitimate Interest vs Consent
- What types of personal data do we source and share?
- Who may we share your data with?
- Do we transfer your data to other countries?
- How long will we keep your data for?
- What are your rights?
- Where do we source data from?
- When else do we have to share your data?
What do we use your data for?
The data that we may collect from you directly via the forms on this website or when we speak to you or communicate directly with you may be used for marketing purposes by us, (where applicable) or more typically may be used for us to carry out our normal business with you.
Where we source your data indirectly from one or more of our data suppliers, this data is processed and held in a database we call “Orchard”, which is used by us to enable us to provide services to our clients in the fields of: marketing, market research, analysis, identity verification, data cleansing, profiling and insight and analytics services. Greenstone is the data controller in the context of the Orchard database.
This means we may share your details (from Orchard) with reputable companies who may want to contact you by post (and occasionally, but very rarely by telephone) to offer you goods and services that may be of benefit to you. We do not process or hold in Orchard personal email addresses and we do not provide personal email data for email marketing campaigns. You can ask us to stop sharing your details at any time now or in the future by contacting us.
We may also profile your information from Orchard and use it for insight and analytics purposes. This means that we might use some of the information that you and other consumers provide to help us and our clients segment data and select target audiences where analysis indicates that they may be more interested in a communication. We DO NOT make automated decisions about you which may have a negative impact on your rights. Clients with whom we share your data with may also use profiling to target you for marketing purposes.
If we receive your details from more than one supplier we may combine the information that they provide about you to create a single view of your details to help our clients personalize the communications sent to you and make them more relevant and interesting for you. This also helps us to ensure that we keep your details accurate and up to date.
We work hard to try to ensure that the data we hold in Orchard is up-to-date and accurate. We clean the data we hold against the Royal Mail Postal Address File and we attempt to correct inaccuracies in names and addresses that we hold. We will also regularly match your record against our registers of people who have moved house or died to make sure that your record is up to date and correct. Additionally, we will regularly check whether you have registered with the Telephone Preference Service, the Corporate Telephone Preference Service, the Mailing Preference Service and the Baby Mailing Preference Service.
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.
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.
Legal Basis for Processing
When supplying your information to our clients for purposes including but not limited to postal direct marketing and profiling and insight and analytics, greenstone rely upon its legitimate interests as our legal basis for processing your data. Specifically, for our legitimate interest to run our business, develop our services and grow our business, to keep our records updated and to inform our marketing strategy.
Direct marketing has been recognised explicitly as a legitimate interest in the GDPR (recital 47).
greenstone and our clients can rely on legitimate interest as a legal basis to process your information where our commercial interest does not override that of yours (the data subject) and where we have carried out a Legitimate Interest Impact Assessment to carefully consider and assess this.
greenstone and its clients will make decisions to ensure we are only processing your data when it has been collected fairly and lawfully, where you would have a reasonable expectation of the data processing activities and where our legitimate interest is not (in our balanced and reasonable opinion) outweighed by your rights and interests.
greenstone does not rely on consent as our legal basis for processing personal data in or from our Orchard product. We may rely on consent as our legal basis for processing data provided to us using the forms on our website or when you provide us with your information directly through another route (most typically when you write to us or call us) and where we specifically ask for your consent. You have the right to withdraw consent to marketing at any time by contacting us.
Comply with a legal obligation
We will sometimes share your personal data with third parties where we have to comply with a legal obligation.
What types of personal data do we source and share?
The information we source into Orchard includes your name and contact information that you provide such as your telephone number and postal address. You might also provide your date of birth and details about your preferences, likes, dislikes, household composition, finance, motoring, spending habits and potentially other (non-sensitive) information. We will never source information about your bank account or credit card details nor will we source sensitive information such as your medical history, religious or political beliefs.
Who may we share your data with?
- Groups of recipients (our clients and prospective clients) within the specific industry sectors listed below
- Marketing service providers and marketing agencies operating on behalf of named brands (End Clients) within the specific industry sectors listed below
- We may sometimes need to pass personal data to a regulator such as the Information Commissioner’s Office.
We require all third-party service providers 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.
Groups of recipients within specific industry sectors listed below:
Automotive, Charity, Gaming, Leisure, Legal Services, Financial Products, Insurance, Health/Mobility, Home Improvements, Wills, Funeral Plans, Mail Order, Market Research, Media, Retail, Telecoms, Travel and Utilities, Shopping, Lifestyle, Family & Home, Property, Local & National Government.
From time to time we also supply data to these sectors via marketing service providers, agencies and brokers.
Do we transfer your data to other countries?
We only store your data in the UK and in the main our clients also operate in the UK or the EEA. From time to time we or our clients might use data processors who are, or whose software services are, cloud based outside of the EEA, primarily in the United States or Canada, but only then under strict contract rules that ensure your personal details are only processed under the same laws that we operate under here in the UK.
How long will we keep your data for?
We will only keep your personal details for as long as is necessary or as long as you want. The law does not put a time limit on the amount of time we should hold your personal details for but as long as you are happy to hear from us we will continue to contact you.
What are your rights?
You have a number of rights under the law under certain circumstance which include:
- Right to be informed
- Right of access
- Right to rectification
- Right to erasure
- Right to restriction of processing
- Right to data portability
- Right to object
- Rights related to automated individual decision-making, including profiling
- Right to withdraw consent at any time where relevant
- Right to lodge a complaint with a supervisory authority
2. Right of access – You have the right to contact us in writing to request details of the information we hold about you.
3. Right of rectification – You have the right to ask us to rectify information that we hold about you if it is inaccurate or incomplete.
4. Right to erasure – This is also known as the right to be forgotten and gives you the right to request your information be removed if there is no compelling reason for its continued processing. A word of warning though; we keep a list of people who have asked not to be contacted which we use to ensure that you receive no further marketing from us or our clients as a result of our activity. Without this “suppression” list your data could enter our system again from another source and we would have no record of the fact that you asked us not to contact you.
5. Right to restrict processing – This is the alternative to erasure and gives you the right to tell us to stop processing your data but allowing us to keep enough information about you to ensure that your wishes are respected in the future.
6. Right to data portability – This gives you the right to ask a holder of your information to transfer that information to another business. This right would most commonly be used if you were switching banks, insurance companies, utilities companies and mobile phone providers.
7. Right to object – You have the right to object to the processing of your data for marketing purposes and profiling for marketing purposes. You also have the right to ask us to cease processing based on our legitimate interests, where there is no overriding justification for the processing of your data. Your rights and freedoms override our interests.
8. Rights related to automated decision making including profiling – We do not use automated decision-making processes which would have a potentially damaging effect on you. But if we did you have the right to obtain human intervention, express your point of view, obtain an explanation of the decision and challenge it.
9. Right to withdraw consent at any time where relevant – You have the right to withdraw your consent to the processing of your information at any time and you must be provided with the information you need to do so, at the time our data providers collect your data and each time they contact you and each time one of our clients contacts you. You can also withdraw consent at any time in the following ways:
In writing to: The Compliance Manager, greenstone data solutions ltd., Suite 1, 40 Churchill Square Business Centre, Kings Hill, West Malling, Kent ME19 4YU
By Email to: email@example.com
By Telephone: 01732 240290
10. Right to lodge a complaint with a supervisory authority – If we cannot deal with your complaint to your satisfaction you also have the right to complain to a relevant supervisory authority which include:
The Information Commissioners Office
The Direct Marketing Association
Where do we source data from?
All of the personal data we collect and process into Orchard is from carefully selected, reputable third-party data suppliers. In each and every case we check carefully that the data they collect and provide us with is collected compliantly and that they can validate their source of your record and how they legally can provide your data for processing by us. We might also rely upon legitimate interest as a legal basis to process your details sourced from the Open Register, Companies House and Land Registry.
We have listed the data supplier partners that we currently work with below, so you can know where your data may have been sourced from.
Our contracted data partners that currently contribute data into our Orchard dataset are:
DBS Datamarketing Ltd
Data On Demand Ltd
Sub2 Technologies Ltd
Mum and Baby Online Ltd
When else do we share your data?
On rare occasions we may be asked to share your information for the prevention of crime, on legal grounds or with regulatory bodies who are investigating a complaint made by a consumer or for any other reason as required by law.