This privacy notice sets out how we look after your personal data and tells you about your privacy rights and how the law protects you. Personal data is any information about you from which you can be identified. It does not include data where your identity has been removed.
This privacy notice applies when you have provided your personal data to us yourself or someone else has provided your personal data to us.
Please read this privacy notice in full, so that you understand how your personal data is used by us.
1. WHO WE ARE, WHO TO CONTACT AND IMPORTANT INFORMATION 2. PERSONAL DATA WE COLLECT ABOUT YOU 3. HOW WE COLLECT YOUR PERSONAL DATA 4. HOW WE USE YOUR PERSONAL DATA 5. DISCLOSING YOUR PERSONAL DATA 6. INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA 7. HOW WE KEEP YOUR PERSONAL DATA SECURE 8. HOW LONG WE KEEP YOUR PERSONAL DATA 9. YOUR LEGAL RIGHTS
We may also provide you with other privacy notices on specific occasions when we are collecting or processing personal data about you, to make sure that you are fully aware of how and why we are using your personal data. This privacy notice is in addition to those other notices and is not intended to override them.
1. WHO WE ARE, WHO TO CONTACT AND IMPORTANT INFORMATION
Who we are
GroVentive Ltd. Registered Office: 52 Grosvenor Gardens, 6th Floor, London, SW1W 0AU. Tel: +44 (0)20 8870 3987 company reg: 11692123 who is responsible for your personal data and may be referred to as “COMPANY”, “we”, “us” or “our” in this privacy notice.
Who to contact
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
Our full details are:
Full company name: GroVentive Ltd
Name: Bruno Pannetier
Email address: firstname.lastname@example.org
Postal address: 52 Grosvenor Gardens London SW1W 0DH United Kingdom
Telephone number: +44 (0)20 8870 3987
Your right to complain
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO). The ICO is 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.
Changes to the privacy notice
We may update this privacy notice from time to time by publishing a new version on our website. You should check this page occasionally to ensure you are happy with any changes to this notice. We may also notify you of changes to this notice by email or through any messaging system on our site.
This version was last updated on 03/01/2023
Telling us if your personal data changes
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 (for example, if your contact details have changed).
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 or notices. When you leave our website, we encourage you to read the privacy notice of every website you visit.
This website and our service is not intended for children. We do not knowingly collect personal data relating to children.
2. PERSONAL DATA WE COLLECT ABOUT YOU
The types of personal data we collect
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
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 notice.
We do not collect any Special Categories of Personal Data about you. Special Categories of Personal Data 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 an order for a product or service you have with us but we will notify you if this is the case at the time.
Other people’s personal data
Please do not provide us with any other person’s personal data, unless we ask you to do so.
3. HOW WE COLLECT YOUR PERSONAL DATA
We use different methods to collect personal data from and about you, as follows
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms 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 or use our services, we may automatically collect Usage 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 Usage Data about you if you visit other websites employing our cookies.]
Cookies are small files that collect anonymous information about how visitors use our site, which is then used to help improve the site. The information collected includes the number of site visitors, where visitors come to the site from and the pages they visited. For further information visit www.aboutcookies.org
Third parties or publicly available sources. We may receive personal data about you from various third parties (which may include public sources) as set out below:
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:
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message or where we are required to have your consent by law. You have the right to withdraw consent to marketing at any time.
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.
What can we do?
We are only allowed to use your personal data to send you marketing messages if:
We will not share your personal data with any company outside of GroVentive Ltd for marketing purposes without your express opt-in consent.
You have the right at any time to ask us to stop sending you marketing messages. You can do this by:
If you opt out of receiving some or all of our marketing, we will retain your Marketing and Communications Data for our records in order to ensure that we know that you have opted out.
If you change your mind after opting out, you can update your choices at any time by contacting us or logging into the website and adjusting your marketing preferences.
COOKIES and Tracking Technologies
Technologies such as: cookies, beacons, tags and scripts are used by GroVentive and our partners, including marketing partners affiliates, or analytics service providers and business process service providers. These technologies are used in analysing trends, administering Our Site, tracking users’ movements around Our Site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
Additionally, we use an ad-publishing service to display 3rd party ads on Our Site. When you view or click on an ad a cookie will be set to help better provide advertisements that may be of interest to you on this and other Web sites. You may opt-out of the use of this cookie by visiting the above tracking preference manage
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.
GroVentive Ltd is the owner of the goodwill and intellectual property of the GroVentive brand and Marks. GroVentive Ltd (by way of current and future assignment of rights) owns all right, title and interest to (and all Intellectual Property Rights in) this Branded Service Platform and its database (including all Branded Service Data obtained). By registering your details on the GroVentive Ltd platform and agreeing to the terms set out in this policy you therefore consent that your personal data will become an asset of GroVentive Ltd.
4. DISCLOSING YOUR PERSONAL DATA
Disclosing your personal data to others
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
Internal Third Parties:
By registering your details on the GroVentive Ltd platform and agreeing to the terms set out in this policy you therefore consent that your personal data will be shared with GroVentive Ltd, and will therefore become an asset of GroVentive Ltd.
Requirements for our third party service providers
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.
Other disclosures we may make
We may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure
Disclosure on our website
Please note that personal data you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
5. HOW WE KEEP YOUR PERSONAL DATA SECURE
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.
6. HOW LONG WE KEEP YOUR PERSONAL DATA
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. Details of retention periods for different aspects of your personal data are [available in our retention policy which you can request from us by contacting us] OR [are set out below]
We will retain your personal data as follows:
In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on 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.
In some circumstances you can ask us to delete your data: see Erasure of Data 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.
We may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another person.
7. YOUR LEGAL RIGHTS
Under certain circumstances, you have the following rights under data protection laws in relation to your personal data. A summary of those rights is set out below.
If you wish to exercise any of the rights set out above, please contact us.
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.