As part of our Code of Ethics, we are committed to protecting and respecting your privacy and data.
Your privacy is important to us. It is Grain Limited’s policy to respect your privacy regarding any information we may collect from you across our website, grain-sustainability.com, and other sites we own and operate.
Any personal information collected shall be held and used in accordance with the EU General Data Protection Regulation 2016/679 (“GDPR”), the UK General Data Protection Regulation, and any legislation that replaces it in whole or in part and any other legislation relating to the protection of personal data. This document details how we store and use your data. Should you require any further information, please contact us directly.
How and what data do we collect?
We may process data about your use of our website. The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your website use. The source of the usage data is Google Analytics. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
We may process account data (“account data”) if you enter your details in our contact form. The account data may include your name and email address, telephone number, job title, company name. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is the performance of a contract between you and us and / or taking steps, at your request, to enter into such a contract.
We also collect data when you use or view our website via your browser’s cookies. There is further detail about cookies here.
How will we use your data?
We may process information relating to our customer relationships, including customer contact information (“customer relationship data”). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is our legitimate interests, namely the proper management of our customer relationships.
We may process information that you provide to us (contact form) for the purpose of subscribing to our email notifications and / or newsletters (“notification data”). We also use your data to answer any specific queries. The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is explicit consent requested at the time of entering the notification data.
We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our business and communications with clients and website visitors.
How do we store your data?
Your data is stored in HubSpot, which is GDPR-compliant. We use GDPR-compliant Google Business for our email.
Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes, i.e. information taken from the contact data capture form.
Account data, customer relationship data, correspondence data will be retained for the duration of the business relationship following commencement of contract, and for a maximum period of three years following the cessation of the relationship.
Notwithstanding the other provisions of this section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
At Grain, we aim to keep clients and prospects informed on sustainability and business. We would like to send you information about our products and services that we think you may benefit from. If you have agreed to receive marketing, or asked us to contact you, you may always opt out later.
You have the right at any time to stop Grain from contacting you for marketing purposes.
If you no longer wish to be contacted for marketing purposes, please email us or ring +44 (0)20 8187 7040.
What are your data protection rights?
We want to make sure you are fully aware of all your data protection rights. Some of the rights are complex, and not all the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights. Every user is entitled to the following:
The right to access – You have the right to confirmation as to whether we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data.
The right to rectification – You have the right to the request that Grain correct any information you believe to be inaccurate, and in the matter of processing, to have any incomplete information held about you to be completed.
The right to erasure – Under certain conditions, you have the right to request that Grain erase your personal details. Those conditions include that the personal data is no longer necessary in relation to the purposes for which they were collected or processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed.
The right to restrict processing – You have the right to object to Grain’s processing of your data, under certain conditions. Included in these conditions are that if we are processing your Information based on our legitimate interests and there are no compelling legitimate grounds for our processing which override your rights and interests. You also have the right to object to use of your information for direct marketing purposes.
You may also have the right to restrict our use of your information, such as in circumstances where you have challenged the accuracy of the information and during the period where we are verifying its accuracy.
The right to data portability – You have the right to request that Grain transfer the data that we have collected to another organisation, or directly to you, under certain conditions, in a structured, commonly used and machine-readable format.
This right exists in respect of information that:
· you have provided to us previously; and
· is processed by us using automated means. Title of goods, services and administrator level passwords remains with Grain Limited until all outstanding sums are paid for in full prior to any release of information.
Most of the above rights are subject to limitations and exceptions. We will provide reasons if we are unable to comply with any request for the exercise of your rights.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact our Data Protection Officer: Madelyn Postman, firstname.lastname@example.org, 19 Crawford Place, Unit 707, London W1H 1PJ, Tel +44 (0) 20 8187 7040