Grist Limited (“we”, “us”, “Grist”) respects privacy and is committed to protecting personal data that is shared with us. This privacy policy explains how we look after personal data.
This privacy policy applies to our clients with whom we have an established relationship or new clients and have been engaged to provide services to. It also applies to visitors to our website and to respondents who respond to and participate in the surveys or research we undertake.
TOPICS COVERED BY THIS POLICY
1. IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY POLICY
This privacy policy explains how Grist collects and processes personal data through use of this website, when a client engages us to provide services and when a respondent participates in our surveys or research.
It is important that you read this privacy policy together with any other privacy policy 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 personal data. This privacy policy supplements the other notices and is not intended to override them.
Please read the following carefully to understand our views and practices regarding personal data and how we will treat it. By using our website, our services and/or participating in our surveys or research, you consent to the collection, use, storage and disclosure of personal information as set out in this policy.
CONTROLLER
Grist is both a controller and a processor. When it is acting as a data controller, it is responsible for your personal data.
If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us via our dedicated email address andrewrogerson@gristonline.com.
CONTACT DETAILS
Our full details are: andrewrogerson@gristonline.com
Name of legal entity: Grist Limited
Postal address: 36 Great Pulteney St, London, W1F 9NS
Email address:
2. INFORMATION WE COLLECT FROM YOU
Personal data, or personal information, means any information about an individual from which that person can be identified and includes special categories of data (which may include 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). 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 (whether you are one of our (potential) clients or one of our respondents) which we have grouped together follows:
“Identity Data” includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
“Contact Data” includes billing address, delivery address, email address and telephone numbers.
“Financial Data” includes bank account, payment card details and in relation to respondents, their income, investments, bank accounts, pension and insurance.
“Marketing and Communications Data” includes your preferences in receiving marketing from us and our third parties and your communication preferences.
“Profile Data” includes your username and password, services purchased, your interests, preferences, feedback and survey responses.
“Special Data” includes data 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 (where used for ID purposes).
“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.
“Transaction Data” includes details about payments to and from you and other details of services you have purchased from us.
“Usage Data” includes information about how you use our website and services.
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 policy.
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 services). In this case, we may have to cancel a 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:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms, completing research surveys or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
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. We may also receive Technical Data about you if you visit other websites employing our cookies.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
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:
5. 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.
|
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
|
To register you as a new client |
(a) Identity (b) Contact |
Performance of a quotation/contract with you. |
|
To process and deliver our services including: (a) manage payments, fees and charges; (b) collect and recover money owed to us. |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
(a) Performance of any contract we enter into with you or for the taking of steps at your request with a view to entering into a contract. (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 Communications |
(a) Performance of any contract we enter into with you or for the taking of steps at your request with a view to entering into a contract. (b) Necessary to comply with a legal obligation. (c) Necessary for our legitimate interests (to keep our records updated and to study how clients use our services). |
|
To enable you to partake in our surveys or research |
(a) Identity (b) Contact (c) Special Data (d) Profile (e) Usage (f) Marketing and Communications |
(a) Performance of any contract we enter into with you or our client or for the taking of steps at your or our client’s request with a view to entering into a contract. (b) Necessary for our legitimate interests (to study how clients use our services, to develop them and grow our business). (c) We have obtained your consent or explicit consent (as the case may be) to use your personal data. |
|
To administer and protect our business and this website (including troubleshooting, 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. |
|
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 Communications (f) Technical |
Necessary for our legitimate interests (to study how clients use our services, to develop them, to grow our business and to inform our marketing strategy). |
|
To use data analytics to improve our website, products/services, marketing, client relationships and experiences |
(a) Technical (b) Usage |
Necessary for our legitimate interests (to define types of clients for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy). |
|
To make suggestions and recommendations to you about goods or services that may be of interest to you |
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile |
Necessary for our legitimate interests (to develop our services and grow our business). |
Marketing
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 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 have previously purchased services from us and, in each case, 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 company outside the Grist group of companies for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages or to participate in our surveys or research at any time by following the opt-out links on any marketing message sent to you or by contacting us at andrewrogerson@gristonline.com.
Where you opt out of receiving these marketing messages or participating in our surveys or research, this will not apply to personal data provided to us as a result of a service purchase, service experience or other transactions.
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, please visit www.aboutcookies.org.
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 andrewrogerson@gristonline.com.
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.
6. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 5 above.
External third parties
You agree that we have the right to share your personal information with the recipients referred to below for the purposes set out in the table in paragraph 5 above (under the heading ‘Purposes for which we will use your personal data’).
|
Recipient |
Category of data |
Purpose |
|
Banks and payment providers services |
(a) Identity (b) Contact (c) Financial |
Processing of payments in the performance of our contract with you |
|
Business partners, suppliers or sub-contractors such as data processers, translators, consultants, copy writers / report writers, research services (fieldwork – qualitative/quantitative) |
(a) Identity (b) Financial (c) Profile (d) Special (e)Marketing & Communications |
Performance of any contract we enter into with you or our client or for the taking of steps at your or our client’s request with a view to entering into a contract |
|
Credit reference agencies |
(a) Identity (b) Contact (c) Technical |
Assessing your credit score which may be a condition of us entering into a contract with you, for fraud prevention and/or to pursue debtors which is necessary for our legitimate interests |
|
Analytics and search engine providers |
Aggregate anonymised information about users of our services |
Improvement and optimisation of our services which is necessary: (a) 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 and study how clients use our products/services, to develop them, to grow our business and to inform our marketing strategy); (b) to comply with a legal obligation. |
|
Professional advisers such as insurers, accountants, lawyers, business advisers, pension advisers and financial advisors |
(a) Identity (b) Contact |
Supporting Grist investigations which is necessary for: (a) any contract we enter into with you or for the taking of steps at your request with a view to entering into a contract; (b) to comply with a legal obligation; (c) our legitimate interests (for running our business, provision of administration and IT services). |
|
Software development companies and web designers |
(a) Technical (b) Usage |
Our legitimate interests (for running our business, provision of administration and IT services). |
Where it is necessary for us to share your personal information:
We will also disclose your personal information to third parties:
Internal third parties
We may also share your personal data with other companies in the Grist group which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006. This is necessary for our legitimate interests for running our business, to study how clients use our products/services, to develop them, to grow our business and to inform our marketing strategy.
7. INTERNATIONAL TRANSFERS
Many of our external third parties are based outside the European Economic Area (“EEA”) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us andrewrogerson@gristonline.com. If you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
8. 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 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.
9. DATA RETENTION
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.
Personal identifiable information collected in relation to respondents will in most cases, be kept for no longer than twelve months from the expiry of the project, but in some cases it may be necessary to keep it for a maximum of twenty four months, unless we tell you otherwise at the time of participating. Non-identifiable data may be kept for longer.
Where we have to keep basic information about our clients by law (including Contact, Identity, Financial and Transaction Data), we shall retain such personal data for six years after they cease being clients for tax purposes.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
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.
10. YOUR LEGAL RIGHTS
Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:
If you wish to exercise any of the rights set out above, please contact us andrewrogerson@gristonline.com.
Right to lodge a complaint with a supervisory authority
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 (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.
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.
11. LINKS TO OTHER WEBSITES
Our services may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which our services are advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.
12. OUR POLICY TOWARDS CHILDREN
Our services are not directed to children and we never knowingly invite children under the age of 16 to participate in surveys or research without taking steps to ensure appropriate consent from a responsible adult has been obtained. If a parent or guardian becomes aware that his or her child has provided us with personal data without their consent, please contact us. If we become aware that a child has registered for a service and has provided us with personal data, we will delete such information from our files.
13. CHANGES TO PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
Any changes we may make to our privacy policy in the future will be posted on this page. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the applicable service. This privacy policy was last updated on 1 Nov 2022.
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.