Last updated: 19th February 2020
As a rule, it is possible to use our website without entering your personal data. In so far as personal data (e.g. name, address or E-Mail addresses) are collected on our pages, then this is always done as far as possible on a voluntary basis. Should you provide such data, it will not be passed on to third parties for marketing purposes without your explicit agreement.
We draw your attention to the fact that the transmission of data on the internet (e.g. in the course of communication per e-mail) can be subject to security vulnerabilities. Absolute protection of data from access by third parties is not possible.
Griffin & Black Associates Limited is the entity that acts as the controller or processor of your information, as explained in more detail in the “Identifying the Data Controller and Processor” section below.
Our Commitment to Privacy
Your privacy is important to us. To better protect you, we provide this Policy explaining our online information practices and the choices you can make about the way your information is collected and processed.
By using the Sites or any of our services you consent to the privacy practices described in this Policy.
Griffin & Black Associates Limited reserves the right to change this Policy without notice at any time. If we make any changes to our Policy, we will post a new policy on our Site and update the “last updated” date shown above. The updated Policy will be effective immediately and will govern each use of the Site from the date of update onwards. Therefore, we recommend that you check the Policy prior to using any of our Sites.
How We Collect Information
To the extent permissible under applicable law, we collect information about you and any other party whose details you provide to us (hereinafter referred to as “Customer Information”) when you:
- register to use our Sites or services – this may include your name (including business name), address, email address, IP address and telephone number. We may also ask you to provide additional information about your business and your preferences;
- place an order using our Sites or services – this may include your name (including business name), address, contact (including telephone number and email address), IP address and payment details;
- complete online forms (including call back requests), take part in surveys, post on our message boards, post any blogs, enter any competitions or prize draws, download information such as white papers or other publications or participate in any other interactive areas that appear on our Sites;
- interact with us using social media; and
- contact us offline, for example by telephone, fax, SMS, email or post.
We will also collect your information where you only partially complete and/or abandon any information inputted into our Sites and/or other online forms and may use this information to contact you to remind you to complete any outstanding information and/or for marketing purposes.
We also collect information from your devices (including mobile devices) and applications you or your users use to access and use any of our Sites or services (for example, we may collect the device identification number and type, location information and connection information such as statistics on your page views, traffic to and from the sites, referral URL, ad data, your IP address, your browsing history and your web log information) and we will ask for your permission before we do so. We may do this using cookies or similar technologies (as described further below).
How We Use Your Information
Griffin & Black Associates Limited uses Customer Information in furtherance of our legitimate interests in operating our Sites and business. More specifically, Griffin & Black Associates Limited uses Customer Information:
To the extent permissible under applicable law, we use your information to:
- provide any information and services that you have requested or any applications or services that you have ordered;
- provide, maintain, protect and improve any applications, products, services and information that you have requested from us;
- manage and administer your use of applications, products and services you have asked us to provide;
- manage our relationship with you (for example, customer services and support activities);
- monitor, measure, improve and protect our content, website, applications and services and provide an enhanced, personal, user experience for you;
- provide you with any information that we are required to send you to comply with our regulatory or legal obligations;
- detect, prevent, investigate or remediate, crime, illegal or prohibited activities or to otherwise protect our legal rights (including liaison with regulators and law enforcement agencies for these purposes);
- contact you to see if you would like to take part in our customer research (for example, feedback on your use of our applications, products and services);
- to monitor, carry out statistical analysis and benchmarking, provided that in such circumstances it is on an aggregated basis which will not be linked back to you or any living individual;
- deliver targeted advertising, marketing (including in-product messaging) or information to you which may be useful to you, based on your use of our Sites and services;
- deliver joint content and services with third parties with whom you have a separate relationship (for example, social media providers); and
- provide you with location-based services (for example, advertising and other personalised content), where we collect geo-location data.
To the extent permitted by applicable law, we retain information about you after the termination of your relationship with Griffin & Black Associates Limited or if we collect data about you and your business you decide not to proceed with us. This information will be held and used for as long as permitted for legal, regulatory, fraud prevention and legitimate business purposes.
Our website, applications (including mobile applications) and services may contain technology that enables us to:
- check specific information from your device or systems directly relevant to your use of the websites, applications or services against our records to make sure the websites, applications or services are being used in accordance with our end-user agreements and to troubleshoot any problems;
- obtain information relating to any technical errors or other issues with our website, applications and services;
- collect information about how you and users use the functions of the features of our website, applications and services; and
- gather statistical information about the operating system and environment from which you access our applications or services.
You can manage your privacy settings within your browser or our Sites (where applicable).
In addition to the purposes described in this section, we may also use information we gather to deliver targeted advertising, marketing (including in-product messaging) or information to you which may be useful, based on your use of the Sites or services or any other information we have about you.
We may monitor and record our communications with you, including e-mails and phone conversations. Information which we collect may then be used for training purposes, quality assurance, to record details about our website, applications and services you order from us or ask us about, and in order to meet our legal and regulatory obligations generally.
Sharing Your Information
We will not sell your personal information to third parties. We may, however, share your information with:
- our service providers and agents (including their sub-contractors) or third parties which process information on our behalf (e.g. internet service and platform providers, payment processing providers and those organisations we engage to help us send communications to you) so that they may help us to provide you with the applications, products, services and information you have requested or which we believe is of interest to you;
- partners, including system implementers, resellers, value-added resellers, independent software vendors and developers that may help us to provide you with the applications, products, services and information you have requested or which we believe is of interest to you;
- third parties used to facilitate payment transactions, for example clearing houses, clearing systems, financial institutions and transaction beneficiaries;
- third parties where you have a relationship with that third party and you have consented to us sending information (for example social media sites or other third party application providers);
- regulators to meet Griffin & Black Associates Limited’s legal and regulatory obligations;
- law enforcement agencies so that they may detect or prevent crime or prosecute offenders;
- any third party in the context of actual or threatened legal proceedings, provided we do so lawfully (for example in response to a court order);
- any third party in order to meet our legal and regulatory obligations, including statutory or regulatory reporting or the detection or prevention of unlawful acts;
- our professional advisors and auditors for the purpose of seeking professional advice or to meet our audit responsibilities;
- another organisation if we sell or buy (or negotiate to sell or buy) any business or assets;
- another organisation to whom we may transfer our agreement with you; and
- Government departments where reporting is mandatory under applicable law.
We may share non-personally identifiable information about the use of our website, applications, products or services publicly or with third parties but this will not include information that can be used to identify you.
We will use commercially reasonable endeavours to ensure the confidentiality of your personal information. However, we cannot guarantee that your personal information will not be disclosed to third parties. For example, we may be legally obligated to disclose information to the government or third parties under certain circumstances, or third parties may circumvent our security measures to unlawfully intercept or access transmissions or private communications.
Our Commitment to Data Security
In order to prevent unauthorised access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online.
These safeguards help prevent unauthorised access, maintain data accuracy, and ensure the appropriate use of data, but no guarantee can be made that your information and data will be secure from intrusions and unauthorised release to third parties.
If you believe your account has been compromised, please contact us at email@example.com .
From time to time, we may use your information to contact you with details about our applications, products and services which we feel may be of interest to you. We may wish to contact you for this purpose by telephone, post, SMS or email. You have the right at any time to stop us from contacting you for marketing purposes. If you wish to exercise these rights you can do so by selecting your contact preferences at the point where you provide us with your information on our websites, applications or services, using any preference centres we give you access to or by sending us an email to: firstname.lastname@example.org. You can also unsubscribe from any email marketing using the links provided in the emails we send to you.
Your information and your rights
If you are based within the EEA or within another jurisdiction having similar data protection laws, in certain circumstances you have the following rights:
- the right to be told how we use your information and obtain access to your information;
- the right to have your information rectified or erased or place restrictions on processing your information;
- the right to object to the processing of your information e.g. for direct marketing purposes;
- the right to have any information you provided to us on an automated basis returned to you in a structured, commonly used and machine-readable format, or sent directly to another company, where technically feasible (“data portability”);
- where the processing of your information is based on your consent, the right to withdraw that consent subject to legal or contractual restrictions;
- the right to object to any decisions based on the automated processing of your personal data, including profiling; and
- the right to lodge a complaint with the supervisory authority responsible for data protection matters (e.g. in the UK, the Information Commissioner’s Office).
If you request a copy of your information you may be required to pay a statutory fee.
If we hold any information about you which is incorrect or if there are any changes to your details, please let us know by so that we can keep our records accurate and up to date.
We will retain your personal information for the duration of our business relationship and afterwards for as long as is necessary and relevant for our legitimate business purposes, or as otherwise permitted by law. Where we no longer need your personal information, we will dispose of it in a secure manner (without further notice to you).
Transfers outside of the European Economic Area
Personal information in the European Union is protected by data protection laws but other countries do not necessarily protect your personal information in the same way.
Our Sites and some of our applications or services or parts of them may also be hosted in the United States or otherwise outside of the EEA (which means all the EU countries plus Norway, Iceland and Liechtenstein) (“EEA”) and this means that we may transfer any information which is submitted by you (through the Sites or offline) outside the EEA to the United States or to other territories outside of the EEA. When you send an email to us, this will also be stored on our email servers which may be hosted outside the EEA.
We may use service providers based outside of the EEA to help us provide our Sites, applications and services to you (for example, platform and payment providers who help us deliver our applications and services, or advertising or execute your payments) and this means that we may transfer your information to service providers outside the EEA for the purpose of providing our applications, advertising and services to you.
We take steps to ensure that where your information is transferred outside of the EEA by our service providers and hosting providers, appropriate measures and controls are in place to protect that information in accordance with applicable data protection laws and regulations. In each case, such transfers are made in accordance with the requirements of Regulations (EU) 2016/679 (the General Data Protection Regulations or “GDPR”) and may be based on the use of the European Commission’s Standard Model Clauses for transfers of personal data outside the EEA.
Cookies, Analytics and Traffic Data
Our cookies may be session cookies (temporary cookies that identify and track users within our websites, applications or services which are deleted when you close your browser or leave your session in the application or service) or persistent cookies (cookies which enable our websites, applications or services to “remember” who you are and to remember your preferences within our websites, applications or services and which will stay on your computer or device after you close your browser or leave your session in the application or service).
We use the following different types of cookies:
Strictly necessary cookies
These are cookies which are needed for our websites, applications or services to function properly, for example, these cookies allow you to access secure areas of our website or to remember what you have put into your shopping basket.
Performance cookies and analytics technologies
These cookies collect information about how visitors and users use our websites, applications and services, for instance which functionality visitors use most often, and if they get error messages from areas of the websites, applications or services. These cookies don’t collect information that identifies a visitor or user. All information these cookies collect is aggregated and therefore anonymous. We only use these cookies to improve how our website, applications and services work.
These cookies allow our websites, applications and services to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
Web beacons and parameter tracking
IP Address and traffic data
We keep a record of traffic data which is logged automatically by our servers, such as your Internet Protocol (IP) address, device information, the website that you visited before ours and the website you visit after leaving our site. We also collect some site, application and service statistics such as access rates, page hits and page views. We are not able to identify any individual from traffic data or site statistics.
Our Commitment to Children’s Privacy
Protecting the privacy of the very young is especially important to us. For that reason, we never collect or maintain information at our website from those we actually know are under the age of 16, and no part of our website is structured to attract anyone under 16.
Our Sites contain links to other websites. Please note that when you click on one of these links, you are entering another website over which Griffin & Black Associates Limited has no control and will bear no responsibility. We encourage you to read the privacy statements on all such websites as their policies may be different to ours.
Identifying The Data Controller And Processor
Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. In general, Customer is the controller of Customer Data. In general, Griffin & Black Associates Limited is the processor of Customer Data and the controller of Other Information.
Individuals located in certain countries, including the European Economic Area, have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete or correct this Information. You can usually do this using the settings and tools provided in your Services account. If you cannot use the settings and tools, contact Customer for additional access and assistance.
To protect your privacy and security, we will also take reasonable steps to verify your identity before granting access or making corrections.
To the extent that Griffin & Black Associates Limited’s processing of your Personal Data is subject to the General Data Protection Regulation, Griffin & Black Associates Limited relies on its legitimate interests, described above, to process your data. Griffin & black Associates Limited may also process Other Information that constitutes your Personal Data for direct marketing purposes and you have a right to object to Griffin & Black Associates Limited’s use of your Personal Data for this purpose at any time.
Data Protection Authority
Subject to applicable law, you also have the right to (i) restrict Griffin & Black Associates Limited’s use of Other Information that constitutes your Personal Data and (ii) lodge a complaint with your local data protection authority or the Information Commissioner’s Office in the UK, which is Griffin & Black Associates Limited’s lead supervisory authority. If you are a resident of the European Economic Area and believe we maintain your Personal Data within the scope of the General Data Protection Regulation (GDPR), you may direct questions or complaints to our lead supervisory authority:
Information Commissioner’s Office
Tel: 0303 123 1113 (local rate) or 01625 545 745 (national rate number)
Fax: 01625 524 510
Contacting Griffin & Black Associates Limited
Griffin & Black Associates Limited,
13 Meadow Way,
Tel: 01293 822755