- Important information and who we are
Full name of legal entity: Gris Paints Limited
Name of data privacy manager: Elizabeth Michael
Email address: firstname.lastname@example.org
Postal address: Suite 5, 39-41 Chase Side, London N14 5BP
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This 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.
- The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data – first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data – billing address, delivery address, email address and telephone numbers.
- Financial Data – bank account and payment card details.
- Transaction Data – details about payments to and from you and details of products you have purchased from us.
- Technical Data – internet protocol (IP) address, your login data, browser type and version, location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Profile Data – your username and password where you create an account with us, details of purchases or orders made by you, preferences, feedback and survey responses.
- Usage Data – information about how you use our website and ordering service.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.
We do not collect any Special Categories of Personal Data about you (this 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). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of our contract with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods). In this case, we may have to cancel an order you have placed with us but we will notify you if this is the case at the time.
- How is your personal data collected?
We use different methods to collect data from and about you including through:
a) Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- place an order for our products;
- create an account on our website; or
- give us feedback or contact us.
c) Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:
- Technical Data from the following parties:
- analytics providers;
- advertising networks; and
- search information providers.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
- Identity and Contact Data from data brokers or aggregators.
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
- How we use your personal data
We will only use your personal data for the purposes for which we collected it and when the law allows us to, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
The reasons for which we will use your personal data include the following:
a) to register you as a customer
b) to process and deliver your order
c) to manage your relationship with us
d) to improve our website, products or customer relationships.
e) 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.
f) where we need to comply with a legal obligation that we are subject to.
Our legitimate interest means the interests of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests.
We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Purposes for which we will use your personal data
We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. 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 note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest To register you as a new customer (a) Identity
Performance of our contract with you To process and deliver your order including management of payments, fees and charges, and to collect money owed to us (a) Identity
(a) Performance of our contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
(a) Performance of our contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(a) 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)
(b) Necessary to comply with a legal obligation
To deliver relevant website content to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
We will not use or share your personal data for marketing purposes.
- Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.
- External Third Parties
- Service providers based in the UK who provide IT and system administration services, including our website developer and host, Hambly Freeman Ltd.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, accountants and insurers based in the UK who provide banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.
- Keim Limited and our designated courier services for the processing and delivery of your order.
- Stripe, Inc. who provide our payment gateway to receive payments for your order on our behalf.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
- External Third Parties
- International transfers
We share your personal data with Stripe, Inc., based in the US, who provide our payment gateway. This will involve transferring your data outside the European Economic Area (EEA).
Where such transfer is required, we ensure that a similar degree of protection is afforded to it and will only transfer your data to countries that have been deemed to provide an adequate level of protection for your personal data by the European Commission. The US is one of those countries and we confirm that Stripe, Inc. are part of the EU-US Privacy Shield which requires them to provide similar protection to personal shared between Europe and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data outside 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. 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
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Your legal rights below for further information.
In some circumstances we will 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
In certain circumstances, you have rights under data protection laws in relation to your personal data including the right to receive a copy of the personal data we hold about you and the right to make a complaint to the Information Commissioner’s Office, (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).
We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
You have the right to:
- Request access – you can ask us for a copy of the personal data we hold about you to check that we are lawfully processing it.
- Request correction – you can ask us to correct any incomplete or inaccurate data we hold about you, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure – you can ask us to delete or remove personal data where there is no good reason for us continuing to process it, where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground, as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing – you can ask us to suspend the processing of your personal data if you want us to establish the data’s accuracy, where our use of the data is unlawful but you do not want us to erase it, where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims or you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. This right only applies to automated information which you initially provided consent for us to use or where we used the information to perform our contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
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 could refuse to comply with your request in these circumstances.
What we may need from you
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.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than this 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.