Privacy Policy
Privacy Policy for GreenPro, a trading name of Evergreen Energy Limited (‘Policy’)
- Who we are.
- How to contact GreenPro about your Personal Data?
- Scope of this Privacy Policy and changes.
- What are your rights?
- Withdrawing consent.
- Personal Data we collect about you.
- Sources of Personal Data.
- How we use your Personal Data.
- Storage of your Personal Data.
- Disclosure of your Personal Data.
- Change of Purpose.
- Contact.
- Complaints.
Who we are
- GreenPro is a trading name of Evergreen Energy Limited, a company registered in England and Wales under company number 07588438 and having its registered office at The Edge Business Centre, Clowes Street, Manchester, M3 5NA. (“GreenPro”, “We”, “our” and “us”)
- We are committed to protecting and respecting your privacy. We will only process or otherwise disclose your personal information as described in this Policy.
- We operate under a number of trading names which reflect the different services and products we have available to assist our customers. These include: GreenPro; Easy MCS; Easy PAS Plus; GreenPro Installer Toolkit; and GreenPro Health and Safety. When we refer to ‘GreenPro’ in this Policy we rare referring to each of these trading names collectively and individually.
- For the purpose of the UK GDPR and the Data Protection Act 2018, the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 and any supplementary, subsequent or secondary legislation and regulations, GreenPro is the data controller for your personal data, as set out in this Policy.
How to contact GreenPro about your Personal Data?
- Questions, comments, issues and requests regarding this privacy policy or your data are welcomed and should be addressed to [email protected]
- The Edge Business Centre, Clowes Street, Manchester, M3 5NA.
- Telephone: +44 (0) 161 768 5807
Scope of this Privacy Policy and changes
- This Policy aims to give you information on how we collect and process your personal data through your use of our websites (see 3.2), including any data you may provide when purchasing or receiving our services, when registering an account or profile on our websites; when your employer or main contractor is a customer of ours; when using our websites or when you communicate with us; when you sign up to any newsletter or email list; or when you enquire about our services or products. This policy also set out when we may communicate with you in relation to our services, products and business, as well as the data we need to process in order to provide our services and products.
- As with all our policies, we may revise and update this Policy from time to time, and any updates will be placed on
https://greenpro.co.uk/
https://www.easy-mcs.com/
https://www.easy-pasplus.com/
https://toolkit.greenpro.co.uk/
Please refer to these websites regularly to check any changes and updates to this Policy. - These websites are collectively and individually referred to throughout this document as “the Website”. The Website is not intended for children and we do not knowingly collect data relating to children.
What are your rights?
- GreenPro recognises that your personal data belongs to you and we don’t wish to use it in ways that you don’t want us to.
- You can control whether or not you receive marketing email by using the “opt-out” button at the bottom of the email. We will only send these to consumers and individuals with your consent or if you are an existing customer (see Marketing (8.2) below for more details)
- Please note that you have specific rights under data protection law in relation to the use of your data, including the ability to regulate and/or object to our use of your data.
- You have the right to object to our processing of your data in some circumstances, including where:
- Processing is based on legitimate interest;
- Processing is for the purpose of direct marketing;
- Processing involves automated decision-making and profiling.
- You can also exercise a variety of rights regarding our use of your data:
- You can ask us for a copy of the information we have about you (usually free of charge)
- You can request an explanation of decisions regarding the processing of your information.
- You can ask us to correct any incorrect data we have about you by emailing [email protected] or through communication with your point of contact at GreenPro. You may also be able to correct any data directly through your profile or account on our Website or App, if you have one.
- You can ask us to delete your data.
- You can ask for your data in a common, machine-readable format.
- You can object to any processing we do on the basis of legitimate interests or to any automated decision-making, for example when your employer shares your details with us.
- object to us processing your personal data for direct marketing purposes even if you have previously given consent. You can do this by emailing [email protected]
- 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 aim to respond to all legitimate requests within one month. Occasionally it could 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. - Links:
Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Withdrawing your consent
- Where we are processing your personal data based on your consent, you may change your mind and withdraw your consent at any time. You can withdraw your consent to receive marketing communications by clicking on the opt out/unsubscribe link in an email or by adjusting the push message settings for the mobile application. You can also withdraw your consent to receive marketing communications or any other consent you have previously provided to us by contacting us at [email protected] or advising a representative of GreenPro on the phone.
Personal Data we may collect from you
- We may collect and process the following personal data about you:
- name;
- address;
- email address;
- telephone number;
- business address
- business name
- account number
- job title
- information about any device you have used to access our Services or the websites, (such as your device’s make and model, device identifier, operating system, browser, MAC address or IP address);
- information about the pages or sections you have visited on the websites including the pages or sections you visited, the website or mobile application you were referred from, and when you visited or used them;
- information about the Services we provide to you (including for example, what we have provided to you, when and where and, if applicable, how much you paid);
- bank account details, payment card information, and information from credit reference agencies;
- your account login details and profile information when you register an account with us, including your user name and password;
- information you provide to us with when you contact us by phone, email, post, or when you communicate with us via social media;
- information about electronic communications you receive from us, including whether that communication has been opened and if you have clicked on any links within that communication;
- answers you provide when you respond to competitions, votes and surveys;
- your identity, public profile, follows and likes from a social network such as Facebook (this may include your employment or education information if you include it in your public profile);
- other personal data which you may disclose to us when you use our Services at any time.
Sensitive Data (known as Special Categories of Personal Data and includes details about 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). We do not usually collect this Sensitive Data about you and will obtain your explicit consent in the event we intend to.
- We may collect and process the following personal data about you:
Sources of personal data
- We will receive your personal data when you provide them to us yourself.
Direct interactions. You may give us your Profile, 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:
- purchase and receive our services and/or products;
- create an account for one of our services or Websites;
- purchase and use or install one of our products
- you enquire about or purchase services on behalf of your employer/business;
- enquire about or discuss our services and/or products;
- subscribe to our newsletter or mailing list;
- request marketing to be sent to you;
- respond to a survey or provide feedback.
- From your employer;
- From an Approved Organisation or other installer, who has installed, repaired or maintained our products at your home;
- From a family member when they have been appointed or notified to us as a point of contact;
- From banks, financial institutions and payment processing facilities;
- Credit Check providers, Companies House and any other agreed third party references;
- From our industry regulators and Government bodies;
- Technical Data from analytics providers such as Google based outside the EU;
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services;
- From our manufacturers, suppliers and subcontractors where they directly supply goods or services to you, so that we may control, oversee and manage the supply of these to you;
- Where we have engaged a sub-contractor to perform some of the services to you, they may collect some personal data whilst performing such services and this will be given to us (see also section 10 below Disclosure of your Information).
- We will receive your personal data when you provide them to us yourself.
Direct interactions. You may give us your Profile, 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:
How we use your Personal Data
- All personal data that we obtain about you will be used in accordance with current data protection law and this Privacy Policy. We will process your personal data as follows:
- As necessary, to meet our obligations under any contracts we are a party to (or your employer or main contractor is a party to), such as a contract to process an order from you for one or more of our Services or products including, where applicable, taking payment and carrying out support services and delivery.
- As necessary, to comply with a legal obligation, for the following purposes:
- Where you exercise your rights under data protection law and make requests.
- To report to our regulators.
- To provide and maintain tax and accounting records.
- Based on your consent, for the following purposes:
- To send you marketing communications (also see 8.2 Marketing).
- To refer to third party partners in relation to their goods and services.
- We may contact you for marketing purposes (see 8.2 Marketing).
- We may review and assess your use of our services in order to better understand our business and services, as well as develop new products.
- To set you up as the key user or administrator for your employer ;
- To contact you in relation the performance of services to you or your employer;
- To manage or accounts and tax reporting.
- To manage and support our CRM and business functions, supply chain and subcontractors.
- To operate and maintain our Website and portal, to provide updates and new versions and ensure their performance.
- To operate and maintain our apps and ensure their performance;
- To manage our supply chain when the supplier, logistics provider or other subcontractor directly delivers goods to, or performs services for, you;
- Marketing
- If you are an individual or consumer we will only market to you if you have provided your consent, have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
- We do contact and market to existing business customers and other organisations which we believe may be interested in our services and, as such, may contact you using your business contact information in order to discuss this with you or your employer. We rely on our legitimate business interests to do this.
- Nonetheless, we strive to provide you with choices regarding any marketing communication and you will be able to opt out of any communications. If you opt-out we operate a suppression list to ensure we can manage this process, which means we keep the minimal personal data necessary to ensure we do not contact you again.
- Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of service purchase or other transactions, or when we have another legal basis to process.
- We do not share your data for third party marketing without your consent.
Cloud-based CRM system Data Collected Name, Company name, geographic location, email address, job role, Contact No. Purpose for Collection To provide accurate Customer Relationship Management records for our Customer base and to ensure we are providing a high level of service to our customers through understanding their requirements.
To communicate with you about any issue that you raise with us or which follows from an interaction between us
Lawful Basis for Processing Contractual fulfilment / Legitimate Interest Retention Period Retain indefinitely whilst the Customer is in contract with GreenPro or 2 years post contract/consent Dial Pad and Chatra Platforms Data Collected Telephone number, Business Name, Customer Name Purpose for Collection To ensure that all calls are recorded for training and quality purposes. To ensure that we can deal with all Customers enquiries and ensure a high level or service
To communicate with you about any issue that you raise with us or which follows from an interaction between us
Lawful Basis for Processing Legitimate interest Retention Period 3 years Analytics tools - Google Analytics, Facebook Pixel, Hotjar Data Collected Name, Email Address, Contact number - provided through website forms or at trade shows or any other means. Purpose for Collection In order to be able to contact customers/potential customers who are interested in a product or service provided by GreenPro
Lawful Basis for Processing Consent Retention Period 6 months if a marketing mail is left unopened Stripe, Sage Pay Data Collected Primary account number (PAN), cardholder name, service code, expiration date, name, physical address, email address, telephone number, bank account details (for automatic renewal of 12 monthly subscriptions) Purpose for Collection To process purchase / service transactions for products and services with customers, and to ensure any transaction issues can be dealt with.
To fulfil purchase requests using payment cards
For accounting and taxation purposes
Documentation should any contractual legal claim arise
Lawful Basis for Processing Contractual performance / Statutory Obligation/ legitimate interest Retention Period Maximum 8 years from the date of the performance of the contract
8 years for VAT records from the performance of the contract
(Note: Full card information is never held in the system in line with PCI / DSS Compliance)
CloudFlare Data Collected Technical information, Name, Address, Contact information Purpose for Collection To protect our websites and infrastructure from cyber attack or other threats and to report and deal with any illegal acts
Lawful Basis for Processing Legitimate interest Retention Period Duration of use of service MailChimp Data Collected Name / Email Address / Phone Number Purpose for Collection We collect your name and email address to send you to information about updates relating to:
- Approved Organisation registration and account services;
- Contacting you in relation to service provision, our services and products, and account management, if you have provided contact details or a validated profile for an Approved Organisation or registered contractor;
- the Easy MCS and Easy Green Deal regulations. This will come in the form of a newsletter;
- Other business and customer management communications.
- Marketing and other communications as permitted in accordance with this Policy.
We collect your name, email address in order to maintain contact with you about your enquiry into our B2C Services
Lawful Basis for Processing Consent/legitimate interest Retention Period Whilst the customer, their employer or main contractor is an Approved Organisation or otherwise has a contract in place with GreenPro, Easy MCS/Green Deal or chooses to opt out of newsletters.
Not retained if individual rejects validation email as part of registration process for their employer or main contractor with GreenPro.
NOT completed funding calculator (didn’t click link) - Keep data for as long as re-targeting sequence lasts.
Opted in to send results but NOT booked an assessment - 18 Months
Opted in to send results but NOT booked an assessment - 18 Months
NOT Opted in to send results and NOT booked an assessment but completed funding calculator - 18 Months
Assessment Carried out and Data Collected and Stored in the Installer Toolkit - 7 Years
Website Contact Forms Data Collected Name / Email Address / Contact Number Purpose for Collection We collect your name, email and telephone number to provide you with your requested information about our products and services
Lawful Basis for Processing Consent Retention Period 2 Years, unless you, your employer or main contractor becomes a customer in which case it may be longer, in line with the above retention periods. With manufacturers, third party suppliers logistics providers and sub-contractors providing services and supplying products on our behalf. (specifically including iHasco)) Data Collected Name and identity data; address, email and contact data; information on products and services purchased. Information on the use and performance of your heating system. Purpose for Collection In order to manage the delivery of products to you (as well as returns, replacements, collections and refunds) and ensure contracted services are performed as agreed, products purchased are operating correctly, we may need to process personal data and share it with our supply chain. Lawful Basis for Processing Legitimate interest; Contract;
Consent
Retention Period Up to 8 years for VAT records from the performance of the contract. Or two years if on the basis of your consent.
- All personal data that we obtain about you will be used in accordance with current data protection law and this Privacy Policy. We will process your personal data as follows:
Storage of your Personal Data
- GreenPro is a UK based organisation whose offices are in the UK.
- Our Websites are hosted within the UK or the EEA.
- Our customer relationship management, marketing and accounting systems for all our businesses are UK and EEA based.
- We use a wide range of Cloud Service Providers (CSPs) as part of our processing environment. Unless we specifically state otherwise, we are, in respect of all these CSPs, the data controller.
- Unless we specifically state otherwise all of the CSPs that we use utilise UK or EEA-located processing facilities.
- Our payment processors and banking arrangements are based in the UK or EEA
- The data that we collect from you may be transferred to, and stored at, a destination outside the UK and European Economic Area (“EEA”). Whenever we transfer your personal data out of the UK and the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK Government (which is deemed to include the European Union post Brexit).
- Where we use certain service providers, we may use specific contracts approved by the UK Government which give personal data the same protection it has in UK as well as undertaking appropriate due diligence and risk assessment of that service provider and local laws.
- We may also transfer your data outside of UK without one of the above safeguards (9.2) on an occasional basis with your consent or to perform a contract with you.
- Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website. Any transmission is therefore at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
- GreenPro is a UK based organisation whose offices are in the UK.
Disclosure of your Personal Data
- We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in Section 736 of the UK Companies Act 1985.
- We may disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- If our business or substantially all of its assets is acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions and other agreements with you.
- To protect the rights, property, or safety of us, our customers, or others.
- If we need to disclose personal data to one of our sub-contractors and suppliers who may be providing the services or products directly to you, however, please note we ensure we have appropriate safeguards in place with these sub-contractors.
- To other third parties with your prior consent.
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 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.
Complaints
- Should you wish to discuss a complaint, please feel free to contact us using the details provided above. All complaints will be treated in a confidential manner.
- Should you feel unsatisfied with our handling of your data, or about any complaint that you have made to us about our handling of your data, you are entitled to escalate your complaint to a supervisory authority. For the United Kingdom, this is the Information Commissioner’s Office (ICO), who is also our lead supervisory authority. Its contact information can be found at https://ico.org.uk/global/contact-us/