We take your privacy very seriously. This privacy notice will inform you as to how we look after your personal data when you visit our website (“our Website”) (regardless of where you visit from) and when you correspond with us by telephone, email or otherwise. It tells you about your privacy rights and how the law protects you.

IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy notice

This privacy notice aims to give you information on how Grain London Limited collects and processes your personal data through the use of our Website, including any data you may provide when you visit our Website as a customer or create your own story, and when you correspond with us by telephone, email or otherwise.

Our Website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Who we are

Grain London Limited (“we”, “us”, “our”) is a ‘data controller’ for the purposes of your personal data. This means that we determine the purpose and means of the processing of your personal data. You will find our contact details at the end of this privacy notice (see below: “How to contact us”).

PERSONAL DATA WE COLLECT ABOUT YOU

Personal data is any information relating to an identified or identifiable individual.

We collect, use, store and transfer different kinds of personal data about you.

This may include:

  • Full name
  • Job title
  • Business name
  • Name of your employer or the organisation you represent
  • Address
  • Email address
  • Telephone numbers (mobile and landline)
  • Information to enable us to undertake credit or other financial checks on you
  • Information about how you use our Website
  • Marketing and communications information, including your preferences in receiving marketing from us and your communication preferences and
  • Information that you volunteer to us when you correspond with us by telephone, email or otherwise.

If you do not provide personal data

For individual suppliers, where we need to collect personal data to enter into a contract with you and you fail to provide that data when requested, we may not be able to enter the contract with you.

HOW YOUR PERSONAL DATA IS COLLECTED

Depending on the circumstances, we use different methods to collect personal data from and about you including:

Directly from you. You may give us your personal data by logging on to our story section of our Website and creating a story, by creating an account with us or by corresponding with us by email, telephone or otherwise.

Other sources. We may receive personal data about you from various third parties or other sources as set out below:

Credit reference agencies; From an employee or representative of the organisation for whom you work; and From our CCTV systems.

HOW AND WHY DO WE USE YOUR PERSONAL DATA?

Under data protection law, we can only use your personal data if we have a proper reason for doing so, for example:

to comply with our legal and regulatory obligations; for the performance of our contract with you or to take steps at your request before entering into a contract; for our legitimate interests or those of a third party; or where you have given consent.

A legitimate interest is when we or a third party have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use your personal data for and our lawful basis for doing so.

What we use your personal data for Our lawful basis for processing data
For individuals who work for or represent corporate customers (or prospective corporate customers) e.g. for corresponding with you about the products and services we offer, to provide a price quote, to respond to your queries and to take steps under the contract with your organisation For individuals who work for or represent corporate customers (or prospective corporate customers) e.g. for corresponding with you about the products and services we offer, to provide a price quote, to respond to your queries and to take steps under the contract with your organisation
For individuals who work for or represent our suppliers (or prospective suppliers) e.g. for corresponding with you about the goods or services your organisation offers and obtain a price quote Necessary for our legitimate interests or those of a third party e.g. to deal with pre-contractual enquiries or issues
For individual suppliers with whom we have contracts – for performance of the contract Necessary for the performance of our contract with you or to take steps at your request before entering into a contract with you.

Necessary for our legitimate interests or those of a third party e.g. to deal with pre-contractual enquiries or issues and to take steps under the contract with your organisation
For individuals who work for or represent our suppliers (or prospective suppliers) e.g. for corresponding with you about the goods or services your organisation offers and obtain a price quote Necessary for our legitimate interests or those of a third party e.g. to deal with pre-contractual enquiries or issues
For individual suppliers with whom we have contracts – for performance of the contract Necessary for the performance of our contract with you or to take steps at your request before entering into a contract with you
To manage our relationship with you which will include notifying you about changes to our terms or privacy notice Necessary to comply with our legal obligations

Necessary for our legitimate interests i.e. to manage our relationship with you and to analyse and improve the products or services we offer
Other processing necessary to comply with legal and regulatory obligations that apply to our business or as otherwise permitted or required by law Necessary to comply with our legal obligations
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies Necessary to comply with our legal obligations
Ensuring the confidentiality of commercially sensitive information Necessary to comply with our legal obligations

Necessary for our legitimate interests or those of a third party i.e. to protect commercially valuable information
Statistical analysis to help us manage our business e.g. in relation to our financial performance, customer base, product range or other efficiency measures Necessary for our legitimate interests of those of a third party i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Updating and maintaining customer and supplier records Necessary to comply with our legal obligations

Necessary for our legitimate interests or those of a third party i.e. to make sure we can keep in touch with our customers and other contacts
To make suggestions and recommendations to you about goods or services that may be of interest to you Necessary for our legitimate interests i.e. to develop our products/services and grow our business
To enforce or apply our Website terms and conditions or any other agreements Necessary for our legitimate interests or those of a third party i.e. to enforce our legal rights and protect our business
To administer and protect our business and our Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) Necessary to comply with our legal obligations

Necessary for our legitimate interests i.e. for running our business, provision of administration and IT services, network security and to prevent fraud
For testimonials on our Website With your consent

Where we rely on consent as a lawful basis to process your personal data, you have the right to withdraw your consent at any time. To do this, please telephone, email or write to us (see below: “How to contact us”).

Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.

Marketing communications

We may use your personal data to send you periodic communications by email and post about our services or news about our business.

We have a legitimate interest in processing your personal data for marketing purposes. This means we do not usually need your consent to send you information about our services or news about our business. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes.

You have the right to opt out of receiving marketing communications at any time by:

  • emailing studio@grain.london, FAO Peter Rogers
  • writing to us Grain, Exmouth House, 3-11 Pine Street, London, EC1R 0JH (for the attention of Peter Rogers
  • using the ‘unsubscribe’ link in our emails.

We may ask you to confirm or update your marketing preferences, or if there are changes in the law, regulation, or the structure of our business.

WHO DO WE SHARE YOUR PERSONAL DATA WITH

Depending on the circumstances, we may share your personal data with:

External service providers e.g. website hosting provider, email service provider, IT providers, and postal/courier service providers who provide website hosting, email hosting, IT, and postal/courier services; and Professional advisers including lawyers, insurers and accountants who provide legal, insurance and accounting services.

We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal obligations.

We may also need to share some personal data with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible.

TRANSFERRING YOUR PERSONAL DATA OUTSIDE OF THE EUROPEAN ECONOMIC AREA

We do not transfer your personal data outside of the European Economic Area.

YOUR RIGHTS IN RESPECT OF YOUR PERSONAL DATA

You have the following rights, which you can exercise free of charge:

Access The right to be provided with a copy of your personal data
Rectification The right to require us to correct any mistakes in your personal data
To be forgotten In certain situations, the right to require us to delete your personal data
Restriction of processing In certain situations, the right to require us to restrict processing of your personal data e.g. if you contest the accuracy of the data
Data portability In certain situations, the right to ask us to transfer any personal data you provided to us to another organisation
To object The right to object at any time to your personal data being processed for direct marketing and in certain other situations to our continued processing of your personal data e.g. where processing is carried out for the purpose of our legitimate interests

We do not use personal data for automated decision making.

For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please email or write to us (see below: “How to contact us”) and let us have enough information to identify you e.g. your full name and address as well as what right you want to exercise and the personal data to which your request relates.

HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for (e.g. whilst we are providing a product or service to you), including:

  • to respond to any questions, complaints or claims made by you or on your behalf
  • to show that we treated you fairly
  • to keep records required by law to comply with our legal obligations

We will not retain your data for longer than necessary for the purposes set out in this notice. Different retention periods apply for different types of personal data.

KEEPING YOUR PERSONAL DATA SECURE

We have put in place reasonable and appropriate security measures to endeavour to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website; any transmission is at your own risk.

Our Website 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 policy of every website you visit.

We have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

HOW TO COMPLAIN

We hope that we can resolve any query or concern you may raise about our use of your personal data. If you want to complain about how we have used your personal data, please email or write to us (see below: “How to contact us”). However, if we are not able to resolve your complaint to your satisfaction, you can complain to the UK’s supervisory authority, the Information Commissioner’s Office (ICO). Further information about how to make a complaint to the ICO can be found on the ICO website

The EU General Data Protection Regulation also gives you right to lodge a complaint with the supervisory authority in the European Union state where you work, normally live or where any alleged infringement of data protection laws occurred.

CHANGES TO THE PRIVACY POLICY

This version was last updated in June 2018.

We may change this privacy notice from time to time and when we do so, we will inform you via our Website. If any changes are likely to have an adverse impact on your rights under data protection law, we will use reasonable endeavours to notify you of the changes in advance by email or by alternative means.

HOW CAN YOU CONTACT US

If you have any queries about this privacy notice or how we use your personal data, you can contact us by email or post as follows:

Grain London Limited
Exmouth House
3 – 11 Pine Street
London
EC1R 0JH