Privacy Policy

Greentings respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

1. IMPORTANT INFORMATION AND WHO WE ARE

2. THE DATA WE COLLECT ABOUT YOU

3. HOW IS YOUR PERSONAL DATA COLLECTED?

4. HOW WE USE YOUR PERSONAL DATA 

5. DISCLOSURES OF YOUR PERSONAL DATA 

6. INTERNATIONAL TRANSFERS 

7. DATA SECURITY

8. DATA RETENTION 

9. YOUR LEGAL RIGHTS 

10. GlOSSARY 

 

    1. Important information and who we are
      This privacy policy aims to give you information on how Greentings collects and processes your personal data through your use of this website, including any data you may provide through this website when you purchase a product and/or set an account up with us. You are not entitled to use this website if you are under 16.  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 policy together with any other privacy policy or fair processing policy 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 policy supplements other notices and privacy policies and is not intended to override them.ControllerGreentings Limited is the controller and responsible for your personal data (referred to as “Greentings”, “we”, “us” or “our” in this privacy policy).We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below. Contact detailsIf you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:
      Full name of legal entity: Greentings Limited
      Email address: [email protected]
      Postal address: 61 Bridge Street, Kington, HR5 3DJ. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator 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. Changes to the privacy policy and your duty to inform us of changesWe keep our privacy policy under regular review. This version was last updated on 18 June 2022 and is the first version. 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 linksThis 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 policy of every website you visit.
    2. 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:

      1. Identity Data
        includes first name, last name, username or similar identifier and marital status.
      2. Contact Data
        includes billing address, delivery address, email address and telephone numbers.
      3. Financial Data
        includes bank account and payment card details.
      4. Transaction Data
        includes details about payments to and from you and other details of products and services you have purchased from us.
      5. 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. 
      6. Profile Data
        includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.  
      7. Usage Data
        includes information about how you use our website, products and services. 
      8. Marketing and Communications Data
        includes your preferences in receiving marketing from us and our third parties and your communication preferences.
      9. Greeting card messages
        includes any personal messages in a greeting card that you upload to the greentings.co.uk website or any app.  Please do not upload any message which includes, reveals or is concerning any special category data relating to health, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union, genetic data, sex life, sexual orientation. 
      10. Location data
        this is any location that you include in the tracking element of greentings.co.uk to show where a Greentings card has been sent from and to.  Please note that we only ask for nearest town and therefore no personal address details will be used for card tracking purposes.  This tracking functionality is only intended to be used for your own personal interest and we will note use this data for any reason other than to provide the tracking functionality.

      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. 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.

      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 a contract we have 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 or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time. 

    3. How is your personal data collected?
      We use different methods to collect data from and about you including through:

      1. Direct interactions. You may give us your data by filling in forms, submitting data to the webiste or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
      2. apply for our products or services;
      3. create an account on our website;
      4. subscribe to our service or publications; 
      5. request marketing to be sent to you;
      6. enter a competition, promotion or survey; 
      7. give us feedback or contact us;
      8. use the functionality on the website, such as uploading your greeting cards or using the card tracking functionality.
      9. Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.  Please see our cookie policy for further details.
    4. How we use your personal data
      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:

      1. Where we need to perform the contract we are about to enter into or have entered into with you.
      2. 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.
      3. Where we need to comply with a legal obligation.

      Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. 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 table 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 Type of data Lawful basis for processing including basis of legitimate interest
      To register you as a new customer

      (a) Identity 

      (b) Contact

      		 Performance of a contract with you

      To process and deliver your order including:

      (a) Manage payments, fees and charges

      (b) Collect and recover money owed to us

      (c ) To gift you a tree with each purchase

      (a) Identity 

      (b) Contact 

      (c) Financial 

      (d) Transaction 

      (e) Marketing and Communi- cations

      (a) Performance of a contract with you 

      (b) Necessary for our legitimate interests (to recover debts due to us)

      To manage our relationship with you which will include:

      (a) Notifying you about changes to our terms or privacy policy

      (b) Asking you to leave a review or take a survey

      (a) Identity 

      (b) Contact 

      (c) Profile 

      (d) Marketing and Communi- cations

      (a) Performance of a 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 enable you to partake in a prize draw, competition or complete a survey

      (a) Identity 

      (b) Contact 

      (c) Profile 

      (d) Usage 

      (e) Marketing and Communi- cations

      (a) Performance of a contract with you 

      (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
      To administer our business and this website (including troubleshooting, providing fonts (Font Awesome and Google Font), Real Cookie Banner, Google ReCAPTCHA for detecting bots, Google Maps, data analysis, testing, system maintenance, support, reporting and hosting of data)  

      (a) Identity

      (b) Contact

      (c) Technical

      (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

      (c) Consent where you have the choice to opt-out in our cookies banner – see Cookie Policy

       
      To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

      (a) Identity 

      (b) Contact 

      (c) Profile 

      (d) Usage 

      (e) Marketing and Communi- cations 

      (f) Technical 

      (e) Greeting Card Messages

      (f) Location data for the card tracking functionality (nearest town only)

      (a) 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)

      (b) Performance of a contract with you (the agreement to provide greeting card tracking and gallery services to you)

      (c) Consent where you have the choice to opt-out in our cookies banner – see Cookie Policy
      To use data analytics to improve our website, products/services, marketing, customer relationships and experiences.

      (a) Technical 

      (b) Usage 

      Consent – We offer you the opportunity to use the website without accepting data analytics by clicking ‘continue without consent’ in the cookie banner.  In the footer to the website, you can manage your consents at any time.

       
      To make suggestions and recommendations to you about goods or services that may be of interest to you (including Facebook for Woocommerce)

      (a) Identity 

      (b) Contact 

      (c) Technical 

      (d) Usage 

      (e) Profile 

      (f) Marketing and Communi- cations

      (a) Necessary for our legitimate interests (to develop our products/services and grow our business)

      (b) Consent where you have the choice to opt-out in our cookies banner – see Cookie Policy

      We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

      Promotional offers from us 

      We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). 

      You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

      Third-party marketing 

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

      Opting out

      You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us. 

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

      Cookies

      You can set your browser to refuse all or some browser 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 click here.

      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.

    5. 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.

      1. External Third Parties as set out in the Glossary.
      2. Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. 

      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.

    6. International transfers
      We do not transfer your personal data outside the UK with the exception of any access by our hosting provider Hostinger, in providing web-services to us.If we were to transfer your personal data out of the UK, we would ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: 

      1. only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data;
      2. ensure any international transfers are done in a lawful way for example, using model clauses or binding corporate rules.
      3. we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK. 

      Please contact us if you want further information on specific mechanisms used by us when transferring your personal data out of the UK.

    7. 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 will notify you and any applicable regulator of a data breach where we are legally required to do so.
    8. Data retentionHow 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 for the purposes of 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 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.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.
       
    9. Your legal rightsUnder certain circumstances, you have rights under data protection laws in relation to your personal data. Please see the section entitled your legal rights If you wish to exercise any of the rights set out above, please contact us.No fee usually requiredYou 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 youWe 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 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. 

ANNEX

    1. GlossaryLAWFUL BASISLegitimate 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 obligationThis means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.THIRD PARTIES

      External Third Parties

      1. Service providers acting as processors based in the UK and the EEA who provide IT, web hosting and system administration services including Hostinger.
      2. Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
      3. 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.
      4. Woo commerce to power our online store.
      5. Any third parties named in our Cookies Policy including Google Analytics. We may use Google analytics to help us understand how users use our site and if we do we will state this in our Cookies Policy and give you the option to choose whether to accept the analytical cookies.  You can read more about how Google uses data in analytics here google.com/intl/en/policies/privacy.  You can opt-out of Google analytics by clicking ‘continuing without consent’ in the cookies banner or here https://tools.google.com/dlpage/gaoptout 
      6. Royal Mail, Parcel Force and other couriers to allow us to deliver your purchases to you.  We share name, address, email address and phone number.
      7. Tree Nation to gift you a tree with your purchase.  We provide your name and email address which Tree Nation will use to send your tree to you.  Your details will be stored in Tree Nation’s database for the purpose of recognising who the trees are addressed to and for the purpose of sending two reminder emails.  Your details will not be used by Tree Nation thereafter except that if you register at a later date, Tree Nation will ensure you can collect previous trees that you have been gifted.  Tree Nation’s privacy policy can be found here https://info.tree-nation.com/privacy-policy-en/ 

      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: 

      1. If you want us to establish the data’s accuracy.
      2. Where our use of the data is unlawful but you do not want us to erase it.
      3. 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. 
      4. 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.