Privacy Notice
Grey Hair Matters Limited (“GHM”) Privacy Notice
Last Updated 14th January , 2021.
This Privacy Notice will help you understand how we process and protect your personal data when you use the GHM Website (“the Website”) , or when you otherwise interact with us. We tell you about your privacy rights and how the law protects you.
If you join GHM and create a user account, you are a “Registered User”. If you apply for and are granted membership of GHM and are using the GHM Services , you are a “Member”. All definitions are as set out in the Terms & Conditions section of the Website.
Purpose of this Privacy Notice
This Privacy Notice aims to give you information on how we process and protect your personal data, as a result of your interest in the Website and/or GHM Services. This is so that you are fully aware of how and why we are using your data.
Please read the following carefully to understand how our practices regarding your personal information and how we will treat it. If you do not agree with this Privacy Notice, please do not use the Website.
It is important that you read this Privacy Notice together with any other privacy notices or other policies we may provide. This Privacy Notice supplements the other notices and is not intended to override them.
Who we are & Contact Details
GHM is an online platform facilitating the connection between Business Owners and Advisors. When we talk about GHM, “we”, ‘’our’’ or ‘’us’’ in this policy, we are referring to Grey Hair Matters Limited , the company which provides the Platform and/or GHM Services.
For the purposes of the applicable data protection legislation Grey Hair Matters Limited , 91 Barrowgate Road ,W4 4QS (registered in England and Wales company number 111321123) is the Data Controller and is responsible for your personal data. This means that we determine the purposes and ways of the processing of your personal data.
If you have any general enquiries related to this Privacy Notice please email us here:privacy@greyhairmatters.co.uk This email address is monitored on a regular basis and we aim to respond to your query as soon as possible.
Changes to this Privacy Notice
We may modify this Privacy Notice at any time, however, if we make any material changes to it we will revise the date at the top of the notice and may provide you with notice either via a message on the Website or via sending you an email so that you have the opportunity to review the changes before they become effective.
Your Duty to Inform us of Changes
Members:
If you object to any of the changes, you have the opportunity to delete your account and any associated information. Once deleted your details will be non-recoverable. If you would like help with this, please email privacy@greyhairmatters.co.uk .
It is important that the personal data we hold about you is accurate and current. Please keep us informed should your personal data change during your relationship with us. You can do this at any time by logging into your account.
Registered Users:
Please contact us at privacy@greyhairmatters.co.uk if you i) object to any changes; or ii) need to inform us of any personal data changes during your relationship with us.
The Data we Collect about You
Personal data, or personal information, means any information about you from which you can be identified. It does not include data where the identity has been removed (anonymous data).
Data Collected By Us
We use different methods to collect data from and about you, including through:
Direct interactions. We collect information from you when you voluntarily submit information directly to us or via the Website. For Members this refers to personal data you provide when, for example; you create an account, complete a profile/post a project, or by corresponding with us via post, phone, email or live chat. For Registered Users, this refers to personal data you provide when you create an account on our the Website. For both Members and Registered Users, this will include Marketing and Communications Data.
Automated technologies or interactions. As you interact with the Website, we may automatically collect Technical and Usage Data (see note below)about your device, browsing actions and patterns. For example, we collect information which may include your IP address, the browser type, your location, language preferences device information and access times. We collect this personal data by using cookies, pixel tags and other similar tracking technologies. The sole purpose of passively collecting your information is to improve your experience when using the Website and/or GHM Services.
Cookies. We only use strictly necessary cookies. These cookies are required for the operation of the Website. Using cookies for this purpose is essential for the Website to work correctly. These cookies are required to enable you to navigate the Website and use its features and for system administration. They include, for example, cookies that enable you to log into secure areas of the Website. These cookies cannot be switched off as to do so, would impede the proper functioning of the Website. You can instruct your browser to refuse all cookies. However, if you do not accept cookies, you may not be able to use some of the GHM Services.
Data Collected by Third Parties
The 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 notices. When you leave our website, we encourage you to read the privacy policy of every website you visit.
We may receive personal data about you from third parties and public sources, for example, the provider that conducts background checks. In this instance we will comply with all necessary data protection obligations.
If you create or login to your account through social media (i.e. Facebook) we will have access to certain personal data from that site, such as your name and account information, in accordance with authorisation procedures determined by such social media site.
As part of your Membership, we may give you the ability to provide personal data in order to gain external references that can be added to your profile as part of your verification process. This involves you giving us the personal data of these external referees for this purpose. You hereby confirm that you have their consent to do this.
As part of your Membership you may have the ability to provide personal data to a third party provider who will carry out checks for any criminal convictions and offences. The third party will then provide us with that information.
As part of your Membership you can i) leave a review or give feedback on another Member; or ii) you can receive a review or feedback from another Member. This will involve the processing of your personal data. We would encourage you not to include any personal information when writing a review or giving feedback.
We do not actively process any Special Categories of Personal Data about you (this includes for example; details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).
Why we use your Personal Data and What Happens If you don’t provide us with it
We use your identification information, e.g. username and password, to verify your identity when you access and use our Services and to ensure the security of your personal information. This is so we can comply with our contractual obligations to you. We process your personal information to provide the Services you have requested. This is so we can comply with our contractual obligations to you. If you fail to provide personal data when required, we may not be able to provide you with GHM Services.
How we Process your Personal Data
We analyse information about how you use our Services to provide an improved experience for the users of all our Services. We may use your data for site analytics and surveys to improve our Services. it is in our legitimate interest to use the information provided to us for this purpose, so we can understand any issues with our Services and improve them.
We analyse your information to detect fraudulent activity, including but not limited to creating new accounts for banned users and posting fake feedback. It is our legitimate business interest to use the information provided to us for this purpose, so we can keep the service safe for all our users.
We may use your personal information when we communicate with you, for example if we are providing information about changes to our Terms & Conditions or if you contact us with questions. It is our legitimate interest that we are able to provide you with appropriate and personalised responses and provide you with notices about our Services.
We may use your personal information to create a profile about you, place you into marketing segments in order to better understand your preferences and to personalise the marketing messages we send you. It is in our legitimate interest to provide you with more relevant and interesting advertising messages. Where required, we will obtain your consent before sending you such marketing messages.
We may use your personal information to exercise our legal rights where it is necessary to do so, for example, to detect, prevent and respond to fraud claims, intellectual property infringement claims, violation of law or our Terms and Conditions.
We may process your personal information to carry out fraud prevention checks or comply with other legal or regulatory requirements, where this is explicitly required by law.
When you use our Services, we may use your personal information to improve your experience with GHM, such as providing interactive or personalised elements on our Services and providing you with content based on your interests.
The legal bases on which we rely in each instance where we collect and use your personal data, generally, are:
as necessary to fulfil and enforce our Terms and Conditions and any other contract we have with you;
consistent with your consent, which, for marketing emails you may revoke at any time by clicking the ‘Unsubscribe’ option at the bottom of our emails or by clicking 'Change contact preferences' on the Website; and
as necessary for our (or others’) legitimate interests, including our interests in providing safe Services on the Website, fraud detection, tailoring your experience on our the Websites, knowing how Members use the Website, keeping the Websites updated and relevant, developing GHM and informing our marketing strategy, and managing our relationships but only if these are not overridden by your interests, rights or freedoms.
The following sets out the type of personal data we collect, the purposes for doing so and the lawful basis for processing it.
| Purpose/Activity | Type of data | Lawful basis for processing |
|---|---|---|
| Visiting the Website | a) Technical Data b) Usage Data |
Legitimate interest |
| Creating an Account as a Registered User. | a) Identity Data b) Marketing and Communications Data c) Usage Data |
Legitimate interest |
| To register you as a Member. | a) Financial Data b) Identity Data c) Marketing and Communications Data |
Legitimate interest Performance of contract |
| To create a Business Owner/Advisor profile. | a) Identity Data b) Image Data c) Marketing and Communications Data d) Business Owner Profile Data e) Advisor Profile Data |
Performance of contract |
| For Members to complete the verification process. Please follow link for further information https:/www.greyhairmatters.co.uk/KYC & ID Verification/ | a) Identity Data b) Marketing and Communications Data c) Verification Data |
Performance of contract Legitimate interest |
| To facilitate Members communicating via the Website, including us sending you an email alert. | Any data you choose to share and receive via the messaging system on the Website | Performance of contract |
| To manage our relationship with you.. For example general enquiries such as how the service works, complaints and payment queries. | Any data you choose to share with us or request us to look at | Legitimate interest |
| Administer and protect the Website (including troubleshooting, fraud prevention, spam prevention, security incident prevention and correction, preventing other such harmful activity, data analysis, testing, system maintenance, support, reporting and hosting of data); and/or send you service and support messages such as updates, patches and security alerts. | a) Financial Data b) Identity Data c) Technical Data |
Legitimate interest |
To send you promotional messages, marketing, advertising and other such information we think may be of interest to you To operate the Website (including notifying you of any changes) and to optimise your user experience. |
a) Financial Data b) Identity Data c) Technical Data |
Consent Legitimate interest |
| To maintain and retain records in connection with legal claims and regulatory investigations; and for governance & compliance purposes. | a) Financial Data b) Identity Data |
Legal obligation necessity |
Please email privacy@greyhairmatters.co.uk if you need details about the specific legal basis we are relying on to process your personal data.
How Third Parties Process your Personal Data
In order to provide you with the Website and/or GHM Services, we may need to give your personal data to third parties who will process your data on our behalf, as set out in the table below.
For example, in order to process your payment for the Services we will need to give your Identity Data, Technical Data, and/or Usage Data (see note below) to Stripe Inc. our payment processing provider.
We require all third parties to respect the security of your personal data and to process 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.
To provide you with the best experience of GHM Services, we use third parties who automatically process your Usage Data on our behalf. Where possible, we will make sure this data is anonymised.
You can request for our full list of third parties who process your data by sending an email to privacy@greyhairmatters.co.uk For your information the following are some examples of how third parties process your personal data.
| Purpose/Activity | Type of data | Third Party data is given to | Lawful basis for processing |
|---|---|---|---|
| To enable us to process payment for GHM Services. | a) Financial Data b) Identity Data |
Stripe Payments (Europe) Ltd. 25-28 North Wall Quay, Dublin DO1 H104 |
Performance of contract |
| To carry out Member verifications. | a) Financial Data b) Identity Data c) Verification Data |
Amazon Web Services, Inc P.O. Box 81226 Seattle WA 98108-1226 |
Legal obligation necessity |
To provide cloud storage solutions. |
All data held on Grey Hair Matters’ systems and databases |
Amazon Web Services, Inc P.O. Box 81226 Seattle WA 98108-1226 |
Performance of contract |
| To provide data backup solutions | All data held on Grey Hair Matters databases |
Doe Taylor, 52 Upper Street, London N10QH | Performance of contract |
| To provide marketing and support services. | a) Marketing and Communications Data b) Verification Data c) Image Data |
Mailchimp/Rocket Science Group 675 Ponce De Leon Avenue, Northeast Suite, 5000 Atlanta GA 30308 USA |
Performance of contract |
| Platform traffic analysis system. | a) Identity Data b) Usage Data c) Technical Data |
Fathom Analytics, BOX 37058 Millstream PO, Victoria, British Colombia, V9B 0E8 | Legitimate interest |
| Cloud based video and photo management platform. | a) Image Data | Performance of contract | |
| Membership Service support system. | a) Identity Data b) Technical Data c) Usage Data d) Financial Data e) Verification Data f) Image Data |
Freshworks Inc., 2950 S. Delaware Street, San Mateo, California 94403 | Performance of contract |
Website visitor support |
a) Identity Data b) Technical Data c) Usage Data |
Tawk.to inc. 187 East Warm Springs Road, SB298, Las Vegas, NU, 89119 | Legitimate interest |
Rights In Relation to your Personal Data
You have rights under data protection laws in relation to your personal data, in particular under the General Data Protection Regulation (GDPR) you have the following rights:
To request access to your personal data (commonly known as a “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.
To request confirmation as to whether or not your personal data is being processed.
To request the correction of your personal data that you consider to be inaccurate. This enables you to have any incomplete or inaccurate data we hold about you corrected. However, we may need to verify your identity and the accuracy of the new data you provide to us.
To request erasure of your personal data. This enables you to ask us to delete or remove personal data, for example: i) where there is no good reason for us continuing to process it; ii) where you have successfully exercised your right to object to processing (see below); iii) where we may have processed your information unlawfully; iv) 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. These reasons will be notified to you at the time of your request.
To object to processing of your personal data. This enables you to object to the processing of your personal data if you feel it impacts on your fundamental rights and freedoms. For example, this can be where we are processing your personal data for direct marketing purposes. In some cases, we may have compelling legitimate grounds to process your information which can override your right to object.
To request restriction of processing your personal data. This gives you the option to ask us to suspend the processing of your personal data in the following scenarios: i) if you want us to establish the data’s accuracy; ii) where our use of the data is unlawful but you do not want us to erase it; iii) where you need us to hold the data, even if we no longer require it e.g. to establish or defend legal claims; or iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate ground to use it.
To request transfer of your personal data. If you request us to do so, we will provide to you, or a third party of your choice, your personal data in a 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 have used the information to perform a contract with you.
To withdraw consent to the processing of your data. If you request us to do so, we will no longer process your data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we will not be able to provide the Services for you. Also, we will advise you of this at the time you withdraw your consent.
To not have a decision made about you based solely on automated processing.
If you wish to exercise any of the rights set out above, in the first instance, please email us at privacy@greyhairmatters.co.uk using the Subject Access Request form.
We will respond to you within 30 days of receipt of your request. Occasionally it may take us longer than 30 days 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.
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 email privacy@greyhairmatters.co.uk in the first instance.
Marketing by us
We may use your personal 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 products, services and offers may be relevant for you.
You will receive marketing communications from us if you have not opted out of receiving that marketing.
Third Party Marketing
We do not share your personal data with third parties.
Unsubscribe from Marketing and Communications
You can ask us to stop sending you electronic messages (e.g. emails) at any time by (i) clicking the unsubscribe links on any electronic message sent to you or (ii) contact us using the details in the Contact us section of the Website with your request to unsubscribe from our database.
If you would like to continue only receiving emails relating to your account (i.e. not marketing emails) please contact us at privacy@greyhairmatters.co.uk.
Does my Data Go Outside the EEA ?
We will use third party service providers that are based outside the European Economic Area (EEA) and this will involve the transfer of your personal data outside the EEA. As a result, the transferred data may not be processed and protected in the same way as set out in this Privacy Policy. You need to be aware that if your information is transferred to a country outside the EEA, that country may not have adequate data protection laws or appropriate safeguards.
Our Members could be based outside the EEA. This means that if you communicate with another one of our Members, your personal data may be transferred outside the EEA. As a result, the transferred data may not be processed and protected in the same way as set out in this Privacy Policy. You need to be aware that if your information is transferred to a country outside the EEA, that country may not have adequate data protection laws or appropriate safeguards.
However, when we transfer your personal data out of the EEA, we endeavour to ensure that a similar degree of protection is afforded to it by implementing at least one of the following safeguards:
By transferring personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
Please email us at privacy@greyhairmatters.co.uk if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, altered or disclosed, used or accessed in an unauthorised way. 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 it. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. However, the transmission of data via the internet is not completely secure and we cannot guarantee that unauthorised parties will not be able to defeat those measures.
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.
Data Retention
We will only retain your personal data for as long as necessary to fulfil the purposes for which we collected, including for the purposes of satisfying any legal, accounting, or internal 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.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for compliance, governance, legal and/or regulatory purposes in which case we may use this information indefinitely without further notice to you.
Subject Access Request
If you have any queries regarding how your personal data is processed, you can submit a Subject Access Request. You will not have to pay a fee to access your personal data (or to exercise Your Legal 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 Information we 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 Your Legal Rights). This is a security measure to ensure that your personal data is not disclosed to any person who does not have the 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.
Processing you Data for Other Purposes
In the future we may decide to sell, transfer or merge parts or our business or our assets. Alternatively we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.
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 email us at privacy@greyhairmatters.co.uk
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.
Children
The Website and/or GHM Services are not intended for children under 18 and we do not knowingly collect data relating to anyone under the age of 21. If you learn that a child under the age of 18 or a member under the age of 21 has provided us with personal information without valid consent, please email at privacy@greyhairmatters.co.uk.
Notes:
Financial Data includes bank account and payment card details you provide, including expiry date. It also includes details about your payment history and/or services or products you have purchased from us.
Identity Data includes full name, title, marital status, date of birth and/or gender. It also includes billing address, home address, postal code, telephone numbers, email address, username, password.
Image Data Includes photographs of Business Owners and Advisors provided to GHM for KYC and ID Verification.
Technical Data includes internet protocol (IP) address, your login data, device type, device version, browser type and version, browser plug-ins types, time zone setting and location, traffic data, search criteria, weblogs and other communications data, operating system and platform and other technology on the devices you use to access the Website.
Usage Data includes information about how you use the Website and/or GHM Services such as the particular pages you interact with, how often you visit, how long you’re on the Website, surveys, the service you’re looking at and the emails you interact with.
Verification Data includes a copy of your passport, proof of address and results of criminal record checks.