Privacy Policy

Grain has several key principles in relation to the processing of personal data;

• We will be fair, lawful and transparent about how we use your personal data
• We will only use your personal data for the purpose we collected it
• We will only collect and process the minimum amount of personal data we need for that purpose
• We will always ensure that the personal data we hold about you is accurate
• We will only keep your personal data for as long as it is needed to fulfil the purpose for which it was collected and no longer
• We will always endeavour to keep your personal data secure

How do we protect your personal information?

Grain takes appropriate organisational and technical measures to protect the personal data and traffic data provided to us or collected by us and does not retain it any longer than permitted or as required under relevant legislation. Your personal data and traffic data can only be accessed by authorised employees of Grain who need to access to this data to be able to fulfil their given duties.

Grain takes appropriate technical measures to manage its Information Security policy and processes and is working towards ISO:27001 accreditation.

Grain takes appropriate technical measures to protect the confidentiality of the communications content via its services and observes applicable obligations and exceptions under the relevant legislation.

This section explains how we will use your information and the legal basis we rely on to allow us to do that.

Why we collect your information? We will use this information in the following ways:

• to carry out our obligations and to enforce our rights arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us as part of those contracts (e.g. to install services or deliver products, billing).
• to notify you about changes to our service (e.g. terms and conditions, this privacy policy).
• to notify you about network maintenance, planned and unplanned outages.
• to arrange access to your property for essential maintenance and repair.
• to manage Network Access Agreements. This may include sharing your information with other utility providers if we are using their infrastructure to deploy our network (e.g. shared ducts, poles). This information will not be used for any other purpose and is securely processed.
• to provide you with information about other services we offer, upgrades, special offers, events and other promotions
• to respond to any queries, complaints and requests
• to send you surveys from time to time
• to monitor the performance of our network build contractors
• to ensure that content from our site is presented in the most effective manner for you and for your computer or device
• to comply with any legal obligations we have because we run a business and because we are an Internet Service Provider and an Electronic Communications Provider

We will not use your information for the following; 

• monitoring what you do on the internet, i.e. what web sites you visit or the content of your emails or messages sent via other messaging services. The only exception to this is where we are required to provide certain information to enable us to comply with any requirements imposed on us by law or court order.

The legal basis of our use of your information.   

When using your information, we do so primarily to fulfil our contractual and legal obligations. Where we require your consent, we will use your information in accordance with that consent. We will only use your personal data to provide you with marketing information with your prior consent.

We also use your information to enable us to run our business and to ensure the quality of our work.  It is in our legitimate business interests (or those of a third party) to do this where this does not materially impact on your freedoms or rights.

We collect and process your data in several ways. Generally, this is to provide you with the product or service you need or have asked for.

Why we collect your information you give us. You may give us information in several ways. These might include;

• filling in forms on our site or in person
• corresponding with us by phone, email or otherwise
• via our social media pages
• when you purchase a product or service from us
• via surveys, competitions and promotions
• during engineering visits
• requesting marketing to be sent to you

We may also collect information you provide when you engage with us to discuss access to your property or land applying or when you report a problem with our communications equipment or the network.

Type of information we may collect.  The information you give us may include;

• bank account details, payment card details and financial transactions
• contact details (your name, title, username, date of birth, sex / gender, address, email, social media handle and phone numbers)
• health information and information about special requirements for vulnerable customers
• call recordings with Customer Services
• CCTV if you visit our offices
• marketing and communications data (your marketing contact preferences),
•  employment information (such as your curriculum vitae, employment history, previous job titles) when you apply for a role with us.

Information we may collect about you on our website. When you visit our site, we may automatically collect the following information:

• Limited personal, mostly anonymous technical information, including the Internet protocol (IP) address used to connect your device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
• Anonymous information about your visit, including the full Uniform Resource Locators (URL) you access, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page and any phone number used to call our customer service number.

We may 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 or product feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

This information is predominantly collected using cookies and similar technologies. It is generally only used to enhance the way you can access and view our websites and to provide anonymous site statistics. For more information, please refer to our . The Cookie settings will allow you to control what information is used.

Information we may collect about you from emails. When you receive an email from us, we may automatically collect the following information:

• Whether they are delivered to you
• Whether you open them (and time and date of opening)
• What links you click on
• Details of the type of device you have viewed on

This information is used for analytical purposes to allow us to improve our service and communications to you.

Information we may collect about you from social media. When you interact with one of our social media pages (including Facebook, Twitter, Trustpilot) we may automatically collect the following information:

• Posts you make
• Comments you make
• Name/profile handle

This information is used to respond to comments and posts and to help us understand what is being said about our company, our products and our services.

Social media sites will also have their own privacy policies and settings that allow you to have more control over your privacy.

Information we receive from other sources. We may obtain information about you from the following sources:

• public sources such as the Land Registry (to help us identify landowners for our network build)
• if you use any of the other websites we operate or the other services we provide – in this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on this site.
• third parties we work with including, for example;
  • business partners and sub-contractors
  • suppliers
  • payment and delivery services
  • advertising networks
  • social media networks and public posts
  • analytics providers
  • search information providers
  • tracing and fraud prevention providers
  • credit reference agencies

We may share your information with any member of our group, which means our subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

We will not share your information for marketing purposes with companies outside our group unless we have specifically asked for your consent to do this.

We may share your information with selected third parties including:

• Business partners, suppliers and sub-contractors for the performance of any contract we enter into with you. This includes our installation partners who will connect you to our broadband service and operatives who may enter your property to install or repair our network.
• Our professional advisers, to enable them to provide legal, accountancy and insurance services to our business
• Analytics and search engine providers that assist us in the improvement and optimisation of our site
• Credit reference agencies for assessing your credit score where this is a condition of us entering into a contract with you
• Tracing and Fraud prevention partners

We may disclose your information to third parties:

• If we sell or buy any business or assets, in which case we may disclose your information to the prospective seller or buyer of such business or assets.
• If Grain or substantially all its assets are acquired by a third party, in which case the information we hold about our customers will be one of the transferred assets.
• If we are under a duty to disclose or share information to comply with any legal obligation, or to enforce or apply our standard terms and other agreements; or to protect the rights, property, or safety of Grain, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
• To comply with any legal obligations we have as an Internet Service Provider and an Electronic Communications Provider.

Information collected by third parties. Please note that third party service providers such as telephone, mobile phone, wi-fi or other communications service providers which provide a service to you using Grain’s Broadband, may also separately collect, access and retain data about you and your use of services across the Internet. They are controllers of the data they collect about you, and you should ask them about their privacy policy.

Our site may, from time to time, contain links to and from the websites of our partners, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal or confidential data to these websites.

All information we process about you is held securely.

Any payment transactions will be made using authorised 3rd party payment gateways using appropriate encryption. The privacy policy of the appropriate provider will be displayed at the time of transaction.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

The data that we collect from you is primarily stored and managed in the UK, but some of our systems and other suppliers may transfer and store your information outside the European Economic Area (“EEA”).

Whenever we or one of our authorised sub-processors transfer your personal data out of the UK/EEA, we ensure that appropriate safeguards are in place which afford you a similar degree of protection, such as ensuring we have carried out appropriate due diligence on our sub-processors, and having protective contractual arrangements in place with them.

Grain will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. 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.

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.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your information, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk.  Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

You have the following rights in relation to your information that we collect and process:

For your security we may request verification prior to actioning your request.

For more information or to exercise any of these rights please contact us at dataprotection@grain.com or complete the form here.

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. The below table sets out the general retention periods for certain types of data we process. 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 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, regulatory, tax, accounting or other requirements. We have set retention periods for all personal information and will take reasonable steps to destroy or anonymise personal information at the end of the retention period.

In some circumstances you can ask us to delete your data: see Your Rights above 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.

There are strict obligations which define for how long we may hold personal data about you. These obligations are included in data protection and data retention legislation.

We will regularly review and update this policy. Any changes we make will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our Privacy Policy.

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to data.protection@grainconnect.com  or in writing to;

c/o The Data Protection Officer

Grain Connect Ltd, Clifford Court, Cooper Way, Parkhouse Road, Carlisle CA3 0JG

Our telephone number is 0330 223 2266.

In the unfortunate event that you wish to complain about the way we’ve processed your data you can contact the regulator below, although we would appreciate being able to handle the issue in the first instance;

The Information Commissioner’s Office (ICO) Click here or call their helpline on 0303 123 1113.

Our ICO registration number is ZA261174

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