Main Privacy Notice
1. INTRODUCTION
This Privacy Notice provides you with details of how we collect and process your
personal data through your use of our website and if you become a client or supplier
to us.
By providing us with your data, you warrant to us that you are over 13 years of age.
Genuine Connection Limited is the data controller, and we are responsible for your
personal data (referred to as “we”, “us” or “our” in this privacy notice).
We have appointed a Data Privacy Manager who is in charge of privacy related
matters for us. If you have any questions about this Privacy Notice, please contact
the Data Privacy Manager using the details below.
Our full details are:
Full name of legal entity: Genuine Connections Limited
Company Number: 15540044
Registered Address: The Roller Mill, Mill Lane, Uckfield, East Sussex TN22 5AA
Name of Data Privacy Officer: Cath Gosden
Email: Connect@genuineconnections.co.uk
It is very important that the information we hold about you is accurate and up to date.
Please let us know if at any time your personal information changes by emailing us
at: Email: Connect@genuineconnections.co.uk
2. WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON
WHAT GROUNDS WE PROCESS IT
Personal data means any information capable of identifying an individual. It does not
include anonymised data.
We may process the following categories of personal data about you:
• Communication Data that includes any communications that you send to us
whether that be through the contact form on our website, through email, text,
social media messaging, social media posting, becoming a supplier to us or
any other communication that you send us. We process this data for the
purposes of communicating with you, for record keeping and for the
establishment, pursuance or defence of legal claims. Our lawful ground for
this processing is our legitimate interests which in this case are to reply to
communication sent to us, to keep records and to establish, pursue or defend
legal claims.
• Customer and Supplier Data that includes data relating to any purchases of
goods and/or services such as your name, title, billing address, delivery
address, email address, phone number, contact details, purchase details,
bank details and your card details. We process this data to supply the goods
and/or services you have purchased and to keep records of such
transactions. Our lawful ground for this processing is the performance of a
contract between you and us and/or taking steps at your request to enter into
such a contract.
• User Data that includes data about how you use our website and any online
services together with any data that you post for publication on our website or
through other online services. We process this data to operate our website
and ensure relevant content is provided to you, to ensure the security of our
website, to maintain back-ups of our website and/or databases and to enable
publication and administration of our website, other online services and
business. Our lawful ground for this processing is our legitimate interests
which in this case are to enable us to properly administer our website and our
business.
• Technical Data that includes data about your use of our website and online
services such as your IP address, your login data, details about your browser,
length of visit to pages on our website, page views and navigation paths,
details about the number of times you use our website, time zone settings
and other technology on the devices you use to access our website. The
source of this data is from our analytics tracking system. We process this data
to analyse your use of our website and other online services, to administer
and protect our business and website and to understand the effectiveness of
our advertising. Our lawful ground for this processing is our legitimate
interests which in this case are to enable us to properly administer our
website and our business and to grow our business and to decide our
marketing strategy.
• Marketing Data that includes data about your preferences in receiving
marketing from us and our third parties and your communication preferences.
We process this data to enable you to partake in our promotions such as
competitions, prize draws and free give-aways and measure or understand
the effectiveness of this advertising. Our lawful ground for this processing is
our legitimate interests which in this case are to study how customers use our
products/services, to develop them, to grow our business and to decide our
marketing strategy.
• We may use Customer data, User Data, Technical data and Marketing Data to
deliver relevant website content and advertisements to you (including
Facebook adverts or other display advertisements) and to measure or
understand the effectiveness of the advertising we serve you. Our lawful
ground for this processing is our legitimate interests which is to grow our
business. We may also use such data to send other marketing
communications to you. Our lawful ground for this processing is either
consent or legitimate interests (namely to grow our business).
Sensitive Data
We do collect any Sensitive Data about you. Sensitive data refers to data that includes
details about your race or ethnicity, religious and sexual orientation. We do not collect any
information about criminal convictions and offences.
We need to collect the above sensitive data about you in order to deliver the services of
Genuine Connections
We require your explicit consent for the processing of sensitive data when you submit your
details for membership.
When we are required to collect personal data by law, or under the terms of the contract
between us and you do not provide us with the data when requested, we may not be able to
perform the contract (for example, to deliver goods or services to you). If you don’t provide
us with the requested data, we may have to cancel a product or service you have ordered
but if we do, we will notify you at the time.
We will only use your personal data for the purpose it was collect for or a reasonably
compatible purposed if necessary. For more information on this please email us at
Connect@genuineconnections.co.uk In case we need to use your details for an unrelated
new purpose we will let you know and explain the legal grounds for processing.
We may process your personal data without your knowledge or consent where this is
required or permitted by law.
We do not carry out automated decision making or any type of automated profiling.
3. HOW WE COLLECT YOUR PERSONAL DATA (include only if you collect via a third
party).
We may collect data about you by you providing the data directly to us (for example by filling
in forms on our website or by sending us emails). We may automatically collect certain data
from you as you use our website by using cookies and similar technologies. Please see our
cookie policy for more details about this.
We may receive data from third parties such as analytics providers like Google based
outside the UK, advertising networks like Facebook based outside the UK and search
information providers again like Google based outside the UK, providers of technical,
payment and delivery services.
We may also receive data from publicly availably sources such as Companies House and
the Electoral Register based inside the UK.
4. MARKETING COMMUNICATIONS
Our lawful ground of processing your personal data to send you marketing communications
is either your consent or our legitimate interest (namely to grow our business).
Under the Privacy and Electronic Communications Regulations, we may send you marketing
communications from us if (i) you made a purchase or asked for information from us about
our goods or services or (ii) you agreed to receive marketing communications and, in each
case, you have not opted out of receiving such communications since. Under these
regulations, if you are a limited company, we may send you marketing emails without your
consent. However, you can still opt out of receiving marketing emails from us at any time.
Before we share your personal data with any third party for their own marketing purposes,
we will get your express consent.
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 emailing us at
Connect@genuineconnections.co.uk at any time.
If you opt out of receiving communications this opt-out does not apply to personal data
provided as a result of other transactions, such as purchases, warranty registrations etc.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below:
• Service providers who provide IT and system administration services.
• Professional advisers including lawyers, bankers, auditors and insurers.
• Government bodies that require us to report processing activities.
• Third parties to whom we sell, transfer, or merge parts of our business or our assets.
• Any other relevant third parties such as our Stylist, photographer, event organisers
and relationship coach which form part of your membership package.
We required all third parties to whom we transfer your data to respect the security of your
personal data and to treat it in accordance with the law. We only allow such third parties 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 of the UK. However, some of our third-party
providers may do.
We are subject to the provisions of the General Data Protection Regulation that protects
your personal data. Where we transfer your data to third parties outside the UK, we will
ensure that certain safeguards are in place to ensure a similar degree of security for your
personal data. As such:
• We may transfer your personal data to countries that the United Kingdom regulatory
authorities have approved as providing an adequate level of protection for personal
data by; or
• If we use US-based providers that are part of UK regulator approved privacy
framework, we may transfer data to them, as they have equivalent safeguards in
place; or
• Where we use certain service providers who are stablished outside the UK, we may
use specific contracts or codes of conduct or certification mechanisms approved by
the European Commission which give personal data the same protection it has in
Europe.
If none of the above safeguards is available, we may request your explicit consent to the
specific transfer. You will have the right to withdraw this consent at any time.
7. DATA SECURITY
We have in place security measures to prevent your personal data from being accidentally
lost, used, altered, disclosed or accessed without authorisation. We also allow access to
your personal data only to those employees and partners who have a business need to
know such data. They will only process your personal data on our instructions, and they
must keep it confidential.
We have procedures I place to deal with any suspected personal data breach and will notify
you and any applicable regulator of a breach if we are legally required to do so.
8. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we
collect it for, including for the purposes of satisfying any legal, accounting, or reporting
requirements.
When deciding what the correct time is to keep the data for, we look at its amount, nature
and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing
purposes, if these can be achieved by other means and legal and requirements.
For tax purposes the law requires us to keep basic information about our clients and
suppliers (including contact, identity, Financial and Transaction Data) for six years after they
stop being clients or suppliers.
In some circumstances we may anonymise your personal data for research or statistical
purposes in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Under data protection law you have the rights in relation to your personal data that include
the rights 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 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; thought we may need to
verify the accuracy of the new data you provide to us.
Request erasure of your personal data. (“also known as the right to be forgotten”) 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 to 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 for erasure for specific legal reasons which will be
notified to you, if appliable, at the time of your request.
Object to processing of your personal data where we are relying om 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.
Where you object to direct marketing, we shall maintain a restricted record of Contact and
Identity Data recording that you have opted out of receiving marketing and we can ensure no
future marketing is carried out. Unless otherwise informed no other processing shall be
carried out in relation to this restricted record.
Request restriction of processing of your personal data. This enable 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 a third party. We will provide you, or a
third party you have chosen, your personal data in a structured, commonly used, machinereadable format. Note 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 these rights set out above, please email us at
Connect@genuineconnections.co.uk
You will not have to pay a fee to access your personal data (or exercise any of the other
rights). However, we may charge a reasonable fee if your request is clearly unfounded,
repetitive or excessive or refuse to comply with your request in these circumstances.
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 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 for further information in relation to your
request to speed up our response.
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. I this case, we will notify you.
If you are not happy with any aspect of how we collect and use your data, you have the right
to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for
data protection issues (www.ico.org.uk) We should be grateful if you would contact us first if
you do have a compliant so that we can try to resolve it for you.
10. 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 statements. When you leave our website, we encourage you to read the privacy
notice of every website you visit.
11. 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