Background
Greentalk Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, greentalk.io (“Our Site”) and use our service, and will only collect and use personal data in ways that are described here, and in a way that is consistent with Our obligations and your rights under the law.
This Privacy Policy relates to the Greentalk Product and Service which Greentalk Limited runs. It defines how Greentalk Limited ensures the privacy of users and administrators of this service. For aspects covering the privacy of those who have general interactions with Greentalk Limited please see the Greentalk Limited Privacy Policy, available at www.greentalklabs.com/privacy-policy
Please read this Privacy Policy carefully and ensure that you understand it. Some projects may not utilise all of the features listed and the terms below will be relevant to the specific project being accessed.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
“Provider” - The organisation, company or local authority which has contracted Greentalk Limited to provide them with a service on greentalk.io. You will find the name of this organisation listed at the top of the page.
“Neighbourhood / Project Coordinator(s)” - An individual or individuals representing a named area of the greentalk.io service for the Provider. They are organised and coordinated by the Provider.
“Account” means an account required to access and/or use certain areas and features of Our Site.
“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below.
“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003.
2. Information About us
Our Site is owned and operated by Greentalk Ltd, a limited company registered in England and Wales under company number 13077950 and have our registered office at Abbey House, 342 Regents Park Road, N3 2LJ. Our VAT number is 368381170.
Questions, requests or comments regarding this Privacy Policy should be emailed to: [email protected]
Greentalk Ltd is registered with the ICO, Registration Number: ZA843126.
3. What Does This Policy Cover?
This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
4. What Is Personal Data?
Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
5. What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
- The right to be informed about Our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.
- The right to access the personal data we hold about you. Part 13 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 15 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about Our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about Our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 15.
6. What Data Do You Collect and How?
Depending upon your use of Our Site, we may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. Please also see Part 14 for more information about Our use of Cookies and similar technologies. We do not collect any ‘special category’ or ‘sensitive’ personal data, and we do not collect data relating to criminal convictions and/or offences.
We list the Data Collected and How we Collect the Data below:
Data Collected: Email Address, First Name, Last Name, Postal Address (Project specific), Phone number (Project specific).
How we Collect the Data: When user ‘Follows’ the service, When user Registers for service, When user 'Adopts' through the service.
Data Collected: User generated - Adoptions, likes, comments, text, images, watering care actions.
How we Collect the Data: Through website interaction.
Data Collected: Website analytics such as visits, referrers and page views (we do not track your individual page views or interactions with our website).
How we Collect the Data: Through website Analytics Provider. See Cookies Policy for additional details.
7. How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following describes how we will use your personal data, and Our lawful bases for doing so (What we Do, What Data we Use, Our Lawful Basis):
What we Do: Users who want to follow the Service.
What Data we Use: Email Address.
Our Lawful Basis: Consent to be on the Provider’s mailing list and receive newsletters.
What we Do: All registered users.
What Data we Use: Email Address, First name, Last name.
Our Lawful Basis: Consent to be emailed, notifications about Things you like or comment or adopt or similar functionality available through the website. Consent to be added to Provider's mailing list and receive newsletters.
What we Do: Registered users that want to follow a particular neighbourhood and/or Provider.
What Data we Use: Email, First name, Last name, Neighbourhood, Associated Username, Postal address (Project specific), Telephone number (Project specific).
Our Lawful Basis: Consent to allow specific interactions and information to be provided about that neighbourhood or Project.
What we Do: Greentalk Adopters (registered user).
What Data we Use: Email, First name, Last name, Postal address (Project specific), Neighbourhood, That is an Adopter, Associated Username, Consent, Telephone number (Project specific).
Our Lawful Basis: Consent to allow specific information about the tree adopted to be provided. To confirm that user fulfils location criteria, e.g. that they are an actual resident in the borough.
With your permission and where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email with information, news, and offers on Our services and/or products. You will not be sent any unlawful marketing or spam. we will always work to fully protect your rights and comply with Our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
8. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
Details of the Type of Data and How Long we Keep It below:
Type of Data: Greentalk Project Mailing List subscriptions.
How Long we Keep It: Indefinitely Or until a person unsubscribes (withdraws consent) Or other event under GDPR which triggers deletion Or end of project.
Type of Data: Greentalk Neighbourhood Mailing List subscriptions.
How Long we Keep It: Indefinitely Or until a person unsubscribes (withdraws consent) Or other event under GDPR which triggers deletion Or end of project.
Type of Data: Website User Registration account data.
How Long we Keep It: 2 years since the last interaction (login into the website) from the user Or user asks for account deletion Or other event under GDPR which triggers deletion Or end of project.
Type of Data: Likes by registered users.
How Long we Keep It: With user identity attached when: A registered user deletes their account Or 2 years since the last interaction (login to the website) by the user the identified like data will be deleted but the overall like counts attached to objects will be retained anonymised. All remaining user identified likes (e.g. those by people who keep logging in) will be retained until: End of project.
Anonymised (as a count). The data anonymised as described above will be retained until: End of project Or other event under GDPR which triggers deletion.
Type of Data: Comments by registered users.
How Long we Keep It: Until a registered user deletes their account Or 2 years since the last interaction (login to the website) by the user Or other event under GDPR which triggers deletion Or end of project.
Type of Data: Adoption links to Trees and objects.
How Long we Keep It: Until a registered user asks to no longer adopt the object (no history is retained of their adoption) Or a registered user deletes their account Or 2 years since the last interaction (login to the website) by the user Or other event under GDPR which triggers deletion Or end of project.
9. How and Where Do You Store or Transfer My Personal Data?
We will only store your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the EU GDPR and/or to equivalent standards by law. Transfers of personal data to the EEA from the UK are permitted without additional safeguards.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
- limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
- procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so.
10. Do You Share My Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions:
- The Provider who we operate this Service on behalf of - We will share your email address with the Provider. If you sign up to Follow the Service or if you register an Account with the Service. The Provider is obliged to only use this email address for purposes of contacting you with updates and news on the service and for no other purpose. You may unsubscribe or close your Account at any time, and they are obliged to delete your email address.
- Neighbourhood Coordinators organised by the Provider - We will share your email address with the Neighbourhood Coordinator(s) of the Neighbourhood(s) that you follow within the service. The Neighbourhood Coordinator is obliged to only use this email address for purposes of contacting you with updates and news on the neighbourhood and their local community group and for no other purpose. You may unsubscribe or close your Account at any time, and they are obliged to delete your email address.
We may sometimes contract with the following third parties to supply certain services.
Information of Recipient, Activity Carried Out, Sector, Location below:
Recipient: Sinch (Mailjet, Mailgun) - mailing service - Data Processor.
Activity Carried Out: Managing mailing lists and sending emails.
Sector: Information services.
Location: EEA.
Recipient: Auth0 - authentication service - Data Processor.
Activity Carried Out: User account and authentication management.
Sector: Information Services.
Location: EEA.
If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, Our obligations, and the third party’s obligations under the law, as described above in Part 9.
If any personal data is transferred outside of the UK, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 9.
If we sell, transfer, or merge parts of Our business or assets, your personal data may be transferred to a third party. Any new owner of Our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
11. How Can I Control My Personal Data?
In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict Our use of your personal data. In particular, we aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in Our emails and/or by updating your preferences in your registered Account.
Similarly, if you do not want to be identified through our Service, e.g. by posting a comment or update, then please do not include your name or any identifying information when interacting with the Service.
12. Can I Withhold Information?
You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
You may restrict our use of Cookies. For more information, see Part 14 and our Cookie Policy.
13. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email shown in Part 15. There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover Our administrative costs in responding.
We will respond to your subject access request within a period of one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of Our progress.
14. How Do You Use Cookies?
Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our services and/or products. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times. For detailed information on the cookies we use, and their purposes, then please see our Cookie Policy.
15. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please email: [email protected] (referencing the service that you are using). Alternatively, please contact the Service Client, details of which can be found in the footer of the website.
16. Changes to this Privacy Policy
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change Our business in a way that affects personal data protection.
Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.
