GDPR
Data Protection Officer
We have appointed a data protection officer (‘DPO’) who is responsible for ensuring that our privacy policy is followed.
If you have any questions about how we process your personal data, including any requests to exercise your legal rights, contact our DPO, Nicholas Kendall, at info@thegreenbroom.co.uk.
Personal data we process
- How we obtain personal data
The information we process about you includes information that you have directly provided to us.
- Types of personal data we collect directly
When you use our website, our services or buy from us, [for example, when you create an account on our website,] we ask you to provide personal data. This can be categorised into the following groups:
- personal identifiers, such as your first and last names, your title and your date of birth
- contact information, such as your email address, your telephone number and your postal addresses for billing, delivery and communication
- account information, including your username and password
- payment information, such as a debit or credit card number and expiry date and bank account details
- records of communication between us, including messages sent through our website and email messages.
In addition, we may also process:
- documentation that confirms your identity, such as an image of your passport or driver’s licence
- an image that shows your face, such as a passport photograph
- documentation that confirms your address, such as a tenancy agreement or utility bill.
- Types of personal data we collect from third parties
We confirm some of the information you provide to us directly using data from other sources. We also add to the information we hold about you, sometimes to avoid asking you to provide it again and sometimes to assess the quality of the services you offer.
The additional information we collect can be categorised as follows:
- information that confirms your identity
- information that confirms your contact information
- unsolicited complaints by other users
- Types of personal data we collect from your use of our services
By using our website and our services, we process:
- your username and password, and other information used to access our website and our services
- information you contribute to our community, including reviews
- your replies to polls and surveys
- technical information about the hardware and the software you use to access our website and use our services, including your Internet Protocol (IP) address, your browser type and version and your device’s operating system
- usage information, including the frequency you use our services, the pages of our website that you visit, whether you receive messages from us and whether you reply to those messages
- transaction information that includes the details of the products and services you have bought from us and payments made to us for those services
- your preferences to receive marketing from us; how you wish to communicate with us; and responses and actions in relation to your use of our services.
- Our use of aggregated information
We may aggregate anonymous information, such as statistical or demographic data, for any purpose. Anonymous information is that which does not identify you as an individual. Aggregated information may be derived from your personal data, but is not considered as such in law because it does not reveal your identity.
For example, we may aggregate usage information to assess whether a feature of our website is useful.
However, if we combine or connect aggregated information with your personal data so that it can identify you in any way, we treat the combined information as personal data, and it will be used in accordance with this privacy notice.
- Special personal data
Special personal data is 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.
It also includes information about criminal convictions and offences. We do not request, require, or process criminal records or DBS checks. We also do not collect any data that is classified as special category data under the GDPR.
- If you do not provide the personal data we need
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 that contract.
In that case, we may have to stop providing a service to you. If so, we will notify you of this at the time.
The basis on which we process information about you
The law requires us to determine under which of six defined bases we process different categories of your personal data, and to notify you of the basis for each category.
If the basis on which we process your personal data is no longer relevant, then we shall immediately stop processing your data.
If the basis changes, then if required by law, we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.
- Information we process because we have a contractual obligation with you
When you create an account on our website, buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.
In order to carry out our obligations under that contract, we must process the information you give us. Some of this information may be personal data.
We may use it to:
- verify your identity for security purposes when you use our services. This includes processing your identity documentation and proof of address for the purpose of verifying your eligibility to be listed as a cleaner on our platform.
- provide you with our services
- provide you with suggestions and advice on services and how to obtain the most from using our website
We process this information on the basis that there is a contract between us, or that you have requested we use the information before we enter into a legal contract.
We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
- Information we process with your consent
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including our products and services, you provide your consent to us to process information that may be personal data.
Wherever possible, we aim to obtain your explicit consent to process this information; for example, we ask you to agree to our use of non-essential cookies when you access our website.
If you have given us explicit permission to do so, we may, from time to time, pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.
We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by instructing us at info@thegreenbroom.co.uk. However, if you do so, you may not be able to use our website or our services further.
We aim to obtain and keep your consent to process your information. However, while we take your consent into account in decisions about whether or not to process your personal data, the withdrawal of your consent does not necessarily prevent us from continuing to process it. The law may allow us to continue to process your personal data, provided that there is another basis on which we may do so. For example, we may have a legal obligation to do so.
- Information we process for legitimate interests
We may process information on the basis that there is a legitimate interest, either to you or to us, of doing so.
Where we process your information on this basis, we do so after having given careful consideration to:
- whether the same objective could be achieved through other means
- whether processing (or not processing) might cause you harm
- whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so
For example, we may process your data on this basis for:
- improving our services
- record-keeping for the proper and necessary administration of our
- responding to unsolicited communication from you, to which we believe you would expect a response
- preventing fraudulent use of our services
- exercising our legal rights, including to detect and prevent fraud and to protect our intellectual property
- insuring against or obtaining professional advice that is required to manage business risk
- protecting your interests where we believe we have a duty to do so
- Information we process because we have a legal obligation
Sometimes, we must process your information to comply with a statutory obligation.
For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation, such as a search warrant or court order.
This may include your personal data.
How and when we process your personal data
- Information you provide
Our website allows you to post information with a view to that information being read, copied, downloaded, or used by other people.
For example, when you leave a review or post a message on our website, we reasonably assume that you consent for the message to be seen by others. We may include your username with your message, and your message may contain information that is personal data.
Other examples include:
- tagging an image
- clicking on an icon next to another visitor’s message to convey your agreement, disagreement or thanks
In posting personal data, it is up to you to satisfy yourself about the privacy level of every person who might use it.
We do not specifically use this information except to allow it to be displayed or shared.
We do store it, and we reserve the right to use it in the future in any way we decide.
We provide you with a public profile page, the information on which may be indexed by search engines or used by third parties. The information you provide on that profile page may be made available to the public.
Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time.
Provided your request is reasonable, and there is no legal basis for us to retain it, then at our discretion we may agree to your request to delete personal data that you have posted. You can request this by contacting us at info@thegreenbroom.co.uk
- Payment information
At the point of payment, you are transferred to a secure page on the website of Stripe, a reputable payment service provider. That page may be branded to look like a page on our website, but it is not controlled by us. We do not receive or store your full payment card details.
- Information obtained from third parties
Although we do not disclose your personal data to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal data from third parties whose services we use.
No such information is personally identifiable to you.