Greene, Tweed and its affiliates (collectively Greene, Tweed, ‘we’, ‘us’ or ‘our’, operate this website which collects and processes personal data about you.
For the purposes of the General Data Protection Regulation 2016/679 (if you are in the European Economic Area), we will be a controller of the personal information we hold about you. This means we make decisions about how and why your information is used, and have a legal duty to make sure that your rights are protected when we do so.
2. THE INFORMATION WE COLLECT
Greene, Tweed is a global company, and is headquartered in the United States with offices, affiliates, employees, representatives, partners, and service providers located around the world. As a result, Greene, Tweed may transfer your Personal Data to, or otherwise process your Personal Data in the United States and/or countries other than the country in which your Personal Data was collected or provided.
Greene, Tweed may transfer your Personal Data across borders to Greene, Tweed and our representatives, affiliates, third party partners and service providers in the United States and other countries where we do business. These countries may have different standards of data protection than your home country. In the event of a cross-border transfer of your Personal Data, if the country to which we transfer your Personal Data is not a recipient of an adequacy decision from the European Commission, and if the transfer is no made under a derogation that does not require additional suitable protections (e.g. the transfer is necessary for the performance of a contract with you or of a contract concluded in your interest, or the transfer is necessary for the establishment, exercise of defence of legal claims), then we provide appropriate or suitable safeguards for such cross-border transfers as required by law, which may include EU standard contractual clauses (also known as model clauses), the applicable Privacy Shield Framework, or binding corporate rules.
We collect personal information about you in several ways, as discussed below:
The Information You Give Us:
- If you contact us to enquire about our services, to discuss your requirements or for any other reason, we will keep a record of that correspondence. This may include your name, address, email address and phone number.
- If you are a business customer and we enter into a contract with your employer, we will retain the name and business contact details of the personnel we will be working with, in order to be able to provide the services we have agreed to carry out in that contract.
Sensitive personal information
We will not typically collect information that is particularly sensitive – that is, information relating to your race or ethnic origin, political opinion, religious or other similar beliefs, trade union membership, physical or mental health, sexual orientation or criminal records.
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us. If we become aware that we have collected personal information from children, we will remove it from our servers.
When you visit our Website, we may collect technical data about the device you are using, including where available your IP address, geographic location, operating system and browser type. This is used for system administration and to improve the look and feel of our website. See section 3 for more about the technical data we collect through cookies.
Cookies are small pieces of information that are stored on your browser on the hard-drive of your device. We also use other tracking technologies such as beacons, tags, and scripts to collect and track information and to improve and analyse how our Website is used.
We use the following types of cookies:
(a) Strictly necessary cookies. These are cookies that are required for the operation of our Website.
(b) Analytical/performance cookies. These cookies allow us to recognise and count the number of visitors and to see how visitors move around our Website. This helps us to improve the way the Website works, for example, by ensuring that users are finding what they are looking for easily.
(c) Third-Party Cookies. We use certain third-party cookies which are placed on your device by other websites. These cookies are placed by Google Analytics or Google AdWords, and their function is discussed further below.
Our Website uses Google Analytics for internal analysis of visitor behaviour and trends, to evaluate traffic flow (e.g. busiest times of day/week) and to assess the relative popularity of different parts of our Website. We will also record data about the search terms you used to find our Website, how long you remain on certain pages, and other analytics information. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network. We use the information we collect to monitor the number of visitors to the different sections of our Website, and to help us make it more useful to them. We do not share individual data or track user behaviour after you have left our Website.
If you do not wish to participate, you can:
You can learn more about cookies generally, as well as how to prevent their use, by visiting this page.
4. OTHER SITES
5. HOW WE USE YOUR PERSONAL INFORMATION
We will only use your personal information when the law allows us to. Most commonly, we will use it in the following circumstances:
(a) where we need to perform a contract e.g. when you or your employer contracts us to provide services to the business;
(b) 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 (see the “Legitimate Interests” section below); or
(c) where we need to comply with a legal or regulatory obligation.
We do not sell, rent or trade your personal information to any third party for marketing purposes.
We may use personal information held about you in the following ways:
- if we are contracted to provide services, to communicate with you about them; or
- to deal with your enquiries, comments or requests.
6. LEGITIMATE INTERESTS
We may rely on legitimate interests to process your personal information, provided that your interests do not override our own.
Where we rely on legitimate interests, these interests are:
(a) to keep our records updated and to study how our Website and other services are used;
(b) to administer and protect our business and web presence (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting);
(c) to inform our marketing strategies; and
(d) to grow our business.
7. KEEPING YOUR PERSONAL INFORMATION SAFE
We employ a variety of physical and technical measures to keep your personal information safe and to prevent unauthorised access to, use or disclosure of it. We control who has access to your information (using both physical and electronic means). Our staff receive data protection training and we have a set of detailed data protection procedures which they are required to follow when handling personal information.
8. STORAGE AND RETENTION
We collect and store personal information for purposes connected with our business. As such, we will only retain your personal information for as long as necessary for those purposes.
We may retain backups and archives that may include your personal data as long as reasonably necessary to comply with applicable laws and requirements.
9. DISCLOSING YOUR PERSONAL INFORMATION
Except for as otherwise described in this policy, we will not disclose your personal information to a third party without your consent.
10. DISCLOSURES REQUIRED BY LAW
We are subject to the law like everyone else. We may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.
We also may need to retain and disclose certain personal information about you to regulatory authorities and to appropriate agencies to conduct anti-money laundering and trade sanction checks, or to assist with fraud prevention. We will disclose this information as is required by law.
11. ACCESS TO YOUR PERSONAL INFORMATION
We want you to remain in control of your personal information. Part of this is making sure you understand your legal rights, which are as follows:
(a) where your personal information is processed on the basis of consent, the right to withdraw that consent;
(b) the right to confirmation as to whether or not we are holding any of your personal information and, if we are, to obtain a copy of it;
(c) the right to have certain data provided to you in a portable electronic format (where technically feasible);
(d) the right to have inaccurate personal information rectified;
(e) the right to object to your personal information being used for marketing or profiling, or on the basis of our or a third party’s legitimate interests;
(f) the right to restrict how your personal information is used; and
(g) the right to be forgotten, which allows you to have your personal information erased in certain circumstances (though this is not an absolute right and may not apply if we need to continue using it for a lawful reason).
If you would like further information about any of your rights or wish to exercise them, please use the following email address – [email protected]
Please keep in mind that there are exceptions to the rights above and, though we will always try to respond to your satisfaction, there may be situations where we are unable to do so (for example, because the information no longer exists or there is an exception which applies to your request).
12. UPDATING THIS POLICY
We may update this Policy at any time. When we do, we will post a notification on the main page of our Website and we will also revise the updated date at the bottom of this page. We encourage users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we hold.
This policy was last updated on October 10, 2018