Privacy Notice

INTRODUCTION  

Here at Green Light PBS Ltd we are committed to building and keeping the trust and confidence of everyone we have contact with.  We think it’s important that you know that we record your personal data when you do things like visit our website, our Facebook page or use our online services in any way.  We want you to trust us with any information we collect and hold. This privacy policy explains all you need to know about:

Green Light PBS Ltd is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

If you want to contact us about anything contained in this policy our email address is: dataprotection@glpbs.com.

Our postal address is:

Green Light PBS Ltd

Treloggan Lane

Newquay

Cornwall

TR7 2FP

If you aren’t happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).  However we would be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

It is very important that the information we hold about you is accurate and up to date.  Please let us know if at any time your personal information changes by emailing us at: dataprotection@glpbs.com

Sensitive Data

We do not collect any Sensitive Data about you from this website.  Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.  We do not collect any information about criminal convictions and offences.

You are not required to provide any personal information on the public areas of this website, however, you may choose to do so by completing the application forms on various sections of our websites and Facebook pages, including:

We may also obtain personal information from your IP address, operating system and web browser that you use to access our website or Facebook site.  You may also provide us with personal information if you contact us by email, telephone or letter.

We require your explicit consent for processing sensitive data and we will request your signature for this consent.

HOW WE USE YOUR PERSONAL DATA  

We will only use your personal data when legally permitted.  The most common uses of your personal data are:

Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message.  You have the right to withdraw your consent to receiving marketing information from us at any time by emailing us at:

dataprotection@glpbs.com

Purposes for processing your personal data  

Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data.  We have also explained what our legitimate interests are where relevant.

We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data.  Please email us at dataprotection@glpbs.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose / Activity Type of Data Lawful Basis for Processing
To register you as a new customer
  1. Identity
  2. Contact
  1. Performance of a contract with you
To manage our relationship with you which will include:

  1. Notifying you about changes to our terms or Privacy Policy
  2. Asking you to leave a review or take a survey
  1. Identity
  2. Contact
  3. Financial
  4. Marketing and communications
  1. Performance of a contract with you
  2. Necessary to comply with a legal obligation
  3. Necessary for our legitimate interests to keep our records updated and to study how customers use our services
To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
  1. Identity
  2. Contact
  3. Technical
  1. Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud, and in the context of a business reorganisation or group restructuring exercise
  2. Necessary to comply with a legal obligation
To deliver relevant content and advertisements to you and measure and understand the effectiveness of our advertising
  1. Identity
  2. Contact
  3. Profile
  4. Usage
  5. Marketing and Communications
  6. Technical
Necessary for our legitimate interests to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy
To use data analytics to improve our website, services, marketing, customer relationships and experiences
  1. Technical
  2. Usage
Necessary for our legitimate interests to define types of customers for our services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy
To make suggestions and recommendations to you about goods or services that may be of interest to you
  1. Identity
  2. Contact
  3. Technical
  4. Usage
  5. Profile
Necessary for our legitimate interests to develop our services and grow our business

Marketing communications

You will receive marketing communications from us if you have:

(i)  requested information from us or purchased goods or services from us; or

(ii)  if you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications; and

(iii)  in each case, you have not opted out of receiving that marketing.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by emailing us at dataprotection@glpbs.com at any time].

Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product / service purchase, service experience or other transactions.

DISCLOSURES OF YOUR PERSONAL DATA  

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 2 above:

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law.  We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

We share your personal data within our group of companies which involves transferring your data outside the European Economic Area (EEA).

Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:

If none of the above safeguards is available, we may request your explicit consent to the specific transfer.  You will have the right to withdraw this consent at any time.

Please email us at dataprotection@glpbs.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

DATA SECURITY  

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.  In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process

your personal data on our instructions and they are subject to a duty of confidentiality.

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

DATA RETENTION  

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers and staff (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers or staff for tax purposes.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

YOUR LEGAL RIGHTS  

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

You can see more about these rights at:

https://ico.org.uk/for-organisations/guide- to-the- general-data- protection-regulation- gdpr/individual-rights/

If you wish to exercise any of the rights set out above, please email us at dataprotection@glpbs.com

You will not have to pay a fee to access your personal data (or to exercise any of the other rights).  However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights).  This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month.  Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests.  In this case, we will notify you and keep you updated.