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 [email protected] or complete the form here.

Your Rights

• Be informed – We hope that this Privacy Policy tells you what you need to know about how we use your information. If you would like any further information, please contact [email protected] (Example – Our Privacy Policy, consent statements, within contracts, within letters/emails).
• Access -You have the right to ask us what information we hold and how we process it (Example – copy of voice recordings, copy of the data we hold).
• Rectification – You have the right to ask us to correct inaccurate information (Example – changes to your contact details, changes of direct debit details).
• Erasure -You have the right to ask us to erase the information we hold about you. However, there are some circumstances where this right does not apply, or where we are not required to comply with your request – for example if we need to retain your data for regulatory or other legal reasons (Example – Delete obsolete contact details, delete all data if you leave).
• Restrict – As an alternative to erasure, you may ask us to restrict certain processing (Example – To not contact you via a certain channel e.g. phone).
• Object – You can object to certain aspects of our processing of your information (Example – To stop us sending you marketing).
• Automated decision making and profiling – The right to request human intervention where we have relied on automated decision making or profiling (Example – We do not currently conduct any automated decision making or profiling).
• Portability enables – You to have a copy of your data given to you or transferred securely to another data controller (Example – Provide your data to a new provider).

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.

• Data Retained Retention Period
• Provision of Service(s) 3 years
• Call and SMS Usage 12 months (or as required by legislation)
• Data Usage 30 days (or as required by legislation)
• Invoices and Billing Records 7 years
• Customer Support Records 3 years

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 [email protected] 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

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy.

Purpose of this privacy notice

• This privacy notice aims to give you information on how Grain Connect Limited collects and processes your personal data through your use of this website, including any data you may provide through this website when you contact us.
• This 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 or fair processing 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. Agreement Date.

Controller

• Grain Connect Limited is made up of different legal entities, details of which can be found here and here . This privacy notice is issued on behalf of the Grain Connect so when we mention Grain Connect, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Group responsible for processing your data.
• Grain Connect Limited is the controller and responsible for this website.
• We have appointed a data privacy and compliance manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy and compliance manager using the details set out below.

Contact details
Our full details are:

• Full name of legal entity: Grain Connect Limited
• Email address: [email protected]
• Postal address: 1st Floor, 6 St Andrew Street, London, EC4A 3AE

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

• This version was last updated in May 2018. 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.

Third-party links

• 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. When you leave our website, we encourage you to read the privacy notice of every website you visit.

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 follows:
Identity Data includes first name, maiden name, last name, username or similar identifier.

Contact Data includes email address, telephone number and postal address.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. Usage Data includes information about how you use our website].

Marketing and Communications Data includes [your preferences in receiving marketing from us and your communication preferences].
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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. 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 notice.

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.

We use different methods to collect data from and about you including through:

Direct interactions

You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• Contact us;
• Give us some feedback
• Apply for a job

Automated technologies or interactions

As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy on our website for further details.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• 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
• Where we need to comply with a legal or regulatory obligation

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a list format, 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.

Note that 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 contact us 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: To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Type of data

• (a) Identity
• (b) Contact
• (c) Technical

Lawful basis for processing including basis of legitimate interest

• (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

Purpose/Activity: To deliver relevant website content

Type of data

• (a) Identity
• (b) Contact
• (c) Profile
• (d) Usage
• (e) Marketing and Communications
• (f) Technical

Lawful basis for processing including basis of legitimate interest

• 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)

Purpose/Activity: To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

Type of data

• (a) Technical
• (b) Usage

Lawful basis for processing including basis of legitimate interest

• 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)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

• Opting out – You can ask us to stop sending you marketing messages at any time by contacting us at any time
• Cookies – You can set your browser to refuse all or some browser cookies, or to alert you
  when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.
• Change of purpose – We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose

If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact 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. 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.

We may have to share your personal data with the parties set out below for the
purposes set out in the table in paragraph 4 above:

• Internal Third Parties as set out in the Glossary
• External Third Parties as set out in the Glossary

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.

We do not transfer your personal data outside the European Economic Area (EEA).

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.

How long will you use my personal data for?

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.

In some circumstances you can ask us to delete your data: Request Data Erasure.

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.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

• Request access to your personal data
• Request correction of your personal data
• Request erasure of your personal data
• Object to processing of your personal data
• Request restriction of processing your personal data
• Request transfer of your personal data
• Right to withdraw consent

Your Legal Rights

You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, 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. You also have the right to object where we are processing your personal data for direct marketing purposes. 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 of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
(a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) 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. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, 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 on [email protected]. To submit a Data Erasure Request, please refer to the Data Erasure Request form on our website.

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 may 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 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.

Lawful Basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product 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

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Third Parties

Internal Third Parties – Internal parties to Grain acting as joint controllers or processors who are based in the United Kingdom
External Third Parties:
Service providers acting as processors based in the United Kingdom who provide IT and system administration services.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.