Daniel Greenberg Ltd (referred to as “we”, “us” or “our” in this privacy notice) are committed to protecting and respecting your privacy.
This policy applies where Daniel Greenberg Ltd identify as the data controller and where we are responsible for your personal data as per the General Data Protection Regulation (GDPR) or Data Protection Act 2018.
Daniel Greenberg Ltd have appointed a Data Protection Manager, who will be responsible for privacy matters and the protection of personal data we hold as an organisation, their details are below:
Name: Daniel Greenberg
Email address: email@example.com
Telephone number: + 44 (0) 7950 491 512
Daniel Greenberg Ltd is a company registered in England and Wales (registration number 06650332) whose address is 9 Holders Hill Crescent, London, NW4 1NE.
If you are unhappy with the way we collect or process your personal information, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO) who are the UK’s supervisory authority for data protection.
Complaints and concerns can be lodged with the ICO via this link: https://ico.org.uk/concerns/
We kindly ask that before any complaints are lodged with the ICO, that you contact us first to try and resolve any issues you may have.
Information we may collect from you – and from where
We may collect and process the following data about you:
- Information you give us. You may give us information about you by filling in forms on our site or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our site, search for a product, place an order on our site, and when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information.
- Information we collect about you. With regard to each of your visits to our site we may automatically collect the following information:
Technical information, including the Internet protocol (“IP”) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- information about your visit, including the full Uniform Resource Locators (“URL”) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
- Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on this site. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Our lawful purposes for collecting and processing your information
We have identified that we will use your information for the following reasons:
- Where we need to perform the contract between us.
- 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 or regulatory obligation.
Generally, we do not rely on consent as a lawful purpose for processing your personal data, other than in relation to sending marketing communications to you when you are not already an existing client. You have the right to withdraw consent to marketing at any time by emailing us at firstname.lastname@example.org.
Uses made of the information
We use information held about you in the following ways:
- Information you give to us. We will use this information:
- to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, and products that you request from us;
- to provide you with information about other goods we offer that are similar to those that you have already purchased or enquired about;
- to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data (the “Online Checkout”);
- to ensure that content from our site is presented in the most effective manner for you and for your computer.
- Information we collect about you. We will use this information:
- to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of our service, when you choose to do so;
- as part of our efforts to keep our site safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
- Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may us this information and the combined information for the purposes set out above (depending on the types of information we receive).
Disclosure of your information
We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
We may share your information with selected third parties including:
- Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.
- Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience.
- Analytics and search engine providers that assist us in the improvement and optimisation of our site.
We may disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- If Daniel Greenberg Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions of supply and other agreements; or to protect the rights, property, or safety of Daniel Greenberg Ltd, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Where we do share your information with third parties, Daniel Greenberg Ltd ensures that the highest levels of data protection are in place in accordance with the law. Third parties with whom we share data are only permitted to process this data for the specified purposes we stipulate with them.
Where we store your personal data
Where possible, we ensure that your data is stored within the European Economic Area (EEA), however some of our storage locations and service providers may be hosted outside of the EEA. When we do need to transfer your personal data out of the EEA, we ensure one of the following safeguards are in place to provide a similar level of security of your data:
- Your personal data has been transferred to a country that has been deemed to provide an adequate level of protection for personal data by the European Commission; or
- The hosting environment we use has specific contracts, codes of conduct or certification mechanisms in-place which have been approved by the European Commission; or
- Where we transfer data to the United States, we ensure our providers are certified as part of the EU-US Privacy Shield programme.
If none of these safeguards are available, we will only transfer your data with your explicit consent – which can be removed at any time by contacting us.
Please email us at email@example.com. if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
Under the General Data Protection Regulation/Data Protection Act (2018), you have certain rights regarding your personal data, these include:
- Request access to your personal data
- Request correction of your personal data
- Request erasure of your personal data
- Object to processing of your personal data
- Request restriction of processing your personal data
- Request transfer of your personal data
- Right to withdraw consent
You may exercise any of these rights by raising a subject access request with us. You can do this by contacting out Data Protection Manager via the details below:
Name: Daniel Greenberg
Email address: firstname.lastname@example.org
Telephone number: +44 (0) 7950 491 512
We will not charge you for making a request and we will make all reasonable efforts to respond to you within 30 days. Sometimes it may take longer than 30 days to gather all the information we may hold on you, in this situation we will keep you updated at all times.
You can instruct us at any time to stop processing your personal data for the purposes of marketing.
We may refuse your request or withhold any personal information that you request if there is an overriding legal reason for us to do so.
Daniel Greenberg Ltd takes the security of your information extremely seriously. In order to protect your data, we implement a risk-based approach to adopt the strongest organisational and technical controls in order to protect the confidentiality, integrity and availability of your data.
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
We keep this policy under regular review and we will always keep you notified of any changes to it. This policy was last reviewed on 4th December 2018. Any questions about this policy can be directed to our Data Protection Manager via the details set out in this policy.