Introduction
At Grid Capital Guernsey Limited ("Grid", "we", "our" and "us") we respect your privacy and we are committed to protecting your information. This privacy notice will inform you about the personal data that we collect about you, the reasons why we use that data, how we use it, and tell you about your privacy rights.
About us
Grid is a controller and we are responsible for the personal data that we collect, including from information collected via our website at gridcap.co.uk. If you have any queries about any aspect of this privacy notice, please contact us at marianne.domaille@gridcap.co.uk or by writing to us at:
Fairbairn House, Rohais, St Peter Port, Guernsey, GY1 1FE
Personal data we collect
If you are a customer, or prospective customer, we collect personal data such as:
- your contact details, such as your name, address, telephone number and email address;
- your date of birth, nationality, country of birth, country of residence, employment status and tax identification number;
- passport details, driving licence and utility bills;
- details of the services you request from us; and
- certain additional information which may be necessary in order for us to provide particular services to you.
If you are an employee, or candidate for employment, we collect personal data including your name, date of birth, nationality, telephone number, address, email, existing job title, education history, passport details, bank details, payroll details, former employers and positions held, medical sickness certificates, times and dates of starting work, records of internet or email usage, job applications and interview records, performance ratings and reviews, records of disciplinary investigations, meetings or grievances, stock option, pension and other insurance documentation, references and details of existing remuneration.
We may also collect technical data, including your IP address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other information about the devices you use to access our website.
We obtain information from third-party sources such as merchants, data providers, and credit bureaus, where permitted by law.
If you communicate with us via our Contact Us form or by writing to us by email or by post, depending on the nature of your correspondence, we will collect personal data about you from your communications.
We may collect special categories of personal data about you, such as about your health and criminal record, where we a required to do so by law.
Why we use personal data
We will only collect and use personal data where we have a legal basis for doing so. This includes where the use of your personal data is necessary to fulfil a contract with you, to comply with our legal duties, for the purposes of our legitimate interests or where you have consented to the collection and use of your personal data.
How we use personal data
If you are a customer, or prospective customer, we may use the personal data that we collect about you for the following purposes:
- to register you as a new customer;
- to manage our relationship with you;
- to run your accounts and provide our services;
- for administration and accounting, billing and auditing and other legal purposes;
- to carry out checks on you that are necessary in order for us to provide our services, such as credit checks, identification verification checks and anti-money laundering checks, for the purposes of meeting our obligations under anti-money laundering and counter terrorist financing laws and any other applicable legislation and for the purposes of crime prevention;
- for security, payment verification, insurance, debt tracing and debt recovery;
- to deal with any queries, complaints or problems reported by you;
- to enable you to participate in our promotions and competitions;
- to enable you to participate in the interactive features of our website;
- to notify you about changes to our services or the terms on which our services are provided;
- for the continuing operation of our systems;
- to keep our records up to date;
- to use data analytics to improve our website, products or services, marketing, customer relationships and experiences;
- to manage risk and protect our website, our services and you from fraud;
- to comply with our obligations and to enforce the terms of our website and our services, including to comply with all applicable laws and regulations;
- to make suggestions and recommendations to you about products or services that may be of interest to you; and
- to market our products and services to you. This may include sending direct marketing emails and other communications relating to our services or those of our partners, conducting statistical and marketing analysis, undertaking marketing research and sending to you advisories and invitations to seminars and other events.
If you are an employee, or candidate for employment, we may use the personal data that we collect about you for the following purposes:
- to comply with our obligations under legal, regulatory and tax requirements;
- for management and administrative uses;
- during the recruitment process to enable us to assess your suitability for employment;
- to create an IT system account and deliver IT services and activities to you;
- to communicate with you about our business or your employment with us; and
- for all legitimate purposes related to Grid's business.
We shall only send marketing communications to you to the extent that doing so is necessary for our legitimate interests or where you have consented to us doing so. As set out in the Your Rights section below, you may withdraw that consent at any time by contacting us at marianne.domaille@gridcap.co.uk. Each electronic marketing communication that you receive from us will also have an "unsubscribe" option, which will allow you to stop receiving similar communications in the future.
Opting out
You can ask us to stop sending marketing messages to you at any time by contacting us at marianne.domaille@gridcap.co.uk. Where you opt out of receiving these marketing messages, we may continue to collect and use other personal data about you.
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. In this case, we may have to cancel a product or service you have with us, or refuse your application to volunteer with us, but we will notify you at the time if this is the case.
Cookies
Cookies are text files containing small amounts of information that are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies are useful because they allow a website to recognise a user’s device. Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improve the user experience. They can also help to ensure that adverts you see online are more relevant to you and your interests. For information about the cookies used on our website, please contact us at marianne.domaille@gridcap.co.uk.
Please note that we may collect and use your personal data without your knowledge or consent, where this is required or permitted by law.
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 that allows us to do so.
Disclosures of your personal data
We have business relationships with third parties, including financial institutions and companies that provide services to us. In some instances we may disclose your personal information to third parties where this is necessary to perform the services for which you have engaged us or otherwise in furtherance of an outsourcing or other data processing arrangement. In those circumstances we will ensure that the third party is contractually bound to only process personal data in accordance with applicable data protection laws and, if applicable, with our specific instructions and requirements, and at all times in a manner that protects your rights under applicable data protection laws. Our suppliers and service providers will be required to meet our standards on processing information and security. The information we provide them, including your information, will only be provided in connection with the performance of their function. They will not be permitted to use your information for any purposes other than those outlined in this privacy notice.
In relation to any other third parties, we will only disclose or transfer your information where you have given your consent or where we are required to do so by law or other regulatory code or practice, or where it is necessary for the purpose of, or in connection with legal proceedings or in order to exercise or defend legal rights.
Your personal data may be transferred to, or accessed from, countries whose laws provide a level of protection for personal data not always equivalent to the level of protection that may be provided in your own country. In particular, if you are located inside Guernsey or the European Economic Area ("EEA") your personal data may be transferred to a country outside of Guernsey or the EEA. We will ensure that cross border transfers comply with all relevant laws and regulations.
Unless:
- you have expressly consented to the transfer of your personal data;
- the transfer is necessary for the performance of the services for which we have been engaged or the conclusion or performance of a contract concluded in your interests; or
- the transfer is otherwise permitted by applicable data protection laws,
we will only transfer your personal data to a country that is deemed to have an adequate level of protection under the applicable data protection law or otherwise where we have put in place adequate safeguards to protect the personal data. In particular, where we send your personal data outside of Guernsey or the EEA, we shall only do so where the recipient of the data is subject to:
- binding corporate rules;
- standard data protection clauses approved under applicable law;
- an approved code of conduct; or
- an approved certification mechanism.
Further details on the safeguards adopted by us may be obtained by contacting us at marianne.domaille@gridcap.co.uk.
How long we keep personal data
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 relation 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.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Your legal rights
Under certain circumstances, you have the following rights under data protection laws in relation to your personal data. In each case, the exercise of these rights is subject to the provisions of the data protection legislation:
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. This enables you to object to processing your personal data where we are relying on a legitimate interest (or those of a third party). 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:
- if you want us to establish the data's accuracy.
- where our use of the data is unlawful but you do not want us to erase it.
- where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- 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 at marianne.domaille@gridcap.co.uk.
Third-party links
Our 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 policies. When you leave our website, we encourage you to read the privacy notice of every website that you visit.
Changes to the privacy notice
We keep our privacy notice under regular review. This privacy notice may be updated from time to time and was last updated on 5 August 2020. The current version of this privacy notice shall be displayed at this page on our website or may otherwise be requested at marianne.domaille@gridcap.co.uk.
If you would like to access previous versions of this policy please contact us at marianne.domaille@gridcap.co.uk.
Complaints
You have the right to make a complaint at any time to the Guernsey Data Protection Authority, the Guernsey supervisory authority for data protection issues, which is contactable at odpa.gg. We would, however, appreciate the chance to deal with your concerns before you approach the Authority, so please contact us in the first instance.