Privacy Policy

Last updated: MAY 2021

1. What does this notice cover?

This notice describes how Greenstone Research Ltd ("Greenstone Research", "we", "us" or "our") processes your personal data. It also describes your data protection rights, including a right to object to some of the processing which Greenstone Research carries out. More information about your rights, and how to exercise them, is set out in the "Your choices and rights" section.

This notice applies to the following groups of individuals whose data we process:

• users of the Greenstone Research website
• clients (including client employees and shareholders)
• business contacts,
• policy makers, politicians (including Members of Parliament and the House of Lords; Members of the Scottish Parliament, Welsh Assembly and Northern Irish Assembly; Members of the European Commission, Council and Parliament; Elected Representatives in Regional and Local Government; as well as electoral candidates), civil servants, journalists, social media influencers, PR representatives and industry stakeholders – referred to below as “advisory contacts”;

We may also provide you with additional information when we collect personal data, where we feel it would be helpful to provide relevant and timely information.

2. What personal data we collect

We collect the following information about you when you visit our website, engage our services or otherwise contact us:

• information to identify you – such as your name, date of birth, home address and contact details;
• information related to the browser or device you use to access our website;
• payment information, including billing address, where you engage our services;
• your marketing preferences including any consents you have given us;
• the content of communications you send us; and

We collect most of this information from you directly when you engage our services of otherwise interact with us online or in person. We also obtain the following information about you as a result of our use of cookies. More information on this is set out in our Cookies section below.

We may also collect information about you, either directly from you or from publicly available sources, particularly where you are an advisory contact. This information could include:

• information about your role and appointments;
• your political opinions and professional affiliations, where you have made this public; and
• details of your public statements and associated press coverage.

3. Why we collect, use and store this personal data

We collect, use and store your personal data for the reasons set out below:

• To fulfil a contract, or take steps linked to a contract, that we have with you. This includes:
  • taking payments;
  • communicating with you;
  • providing client support; and
  • providing the relevant support and services under your contract with us.

• As required to conduct our business and pursue our legitimate interests, in particular:
  • we will use your information to provide the services you have requested, and respond to any correspondence you send us;
  • we monitor use of our website and use your information to help us monitor, improve and protect our services;
  • we will process data of advisory contacts to develop and maintain our awareness of the regulatory and industry landscape, to understand what advisory contacts are saying about us and our clients, to create and publish content about current affairs and to provide services to our clients, including advisory, analysis, campaigning and engagement services;
  • we will use your information to send you direct marketing in relation to our relevant services. This may include invitations to events we think you may be interested in;
  • we use information you provide as well as information which we have collected about you to investigate any complaints received from you, or from others, about our website or about our services;
  • we will use data in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation); and
  • we use data of some individuals to invite them to take part in market research.

• Where you give us consent:
  • where we are obliged to obtain your consent, we will send you direct marketing in relation to our relevant services. This may include invitations to events we think you may be interested in.]
  • we place cookies and use similar technologies in accordance with our Cookies section below and the information provided to you when those technologies are used
  • on other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time.

• For purposes which are required by law:
  • In response to requests by government or law enforcement authorities conducting an investigation.

Where we process sensitive data, such as information relating to your political opinions or certain professional affiliations, we are required to have an additional legal basis. We will only process this data do where you have made this public, or otherwise given us your explicit consent.

Withdrawing consent or otherwise objecting to direct marketing

Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests.  You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by following the instructions in the communication where this is an electronic message, or by contacting us using the details set out below.

4. Information about our use of cookies

What are cookies?

A cookie is a very small text document, which often includes an anonymous unique identifier. Cookies are created when your browser loads a particular website. The website sends information to the browser which then creates a text file. Every time the user goes back to the same website, the browser retrieves and sends this file to the website's server. Find out more about the use of cookies on www.allaboutcookies.org.

We also use other forms of technology which serve a similar purpose to cookies and which allow us to monitor and improve our website. When we talk about cookies, this term includes these similar technologies.

What cookies do we use and what information to they collect?

• Required cookies: these cookies are required to enable core functionality. If you disable these cookies certain parts of the website will not function for you.
• Analytics cookies: these cookies help us improve or optimise the experience we provide. They allow us to measure how visitors interact with our website and we use this information to improve the user experience and performance of our platforms. These cookies are used to collect technical information such as the number of pages visited, which parts of our website are clicked on and the length of time between clicks. For example, we use Google Analytics to better understand how customers use the Site. If you don’t want Google Analytics to be used in your browser, you can install this Google add-on: https://tools.google.com/dlpage/gaoptout?hl=en_GB.

Third parties

Your use of our website may result in some cookies being stored that are not controlled by us. This may occur when the part of the website you are visiting makes use of a third-party analytics or marketing automation/management tool or includes content displayed from a third party website. You should review the privacy and cookie policies of these services to find out how these third parties use cookies and whether your cookie data will be transferred to a third country.

How do you manage these technologies?

If you want to delete any cookies that are already on your device, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies.

We keep information collected from cookies for a maximum of 6 months.

5. How we share your personal data

Where you are an advisory contact, your data may be included as part of published content on our website where this relates to your public role and statements, or may be shared with our clients as part of our services as described above. If you are a client or client employee, we may share your details with advisory contacts as part of services requested by you or your employer.

Personal data will also be shared with third party service providers, such as IT service providers, who will process it on our behalf for the purposes identified above.

In the event that Greenstone Research is sold or integrated with another business, your details may be disclosed to our advisers and any prospective purchaser's adviser and will be passed to the new owners of the business.

We do not routinely transfer personal data to countries outside of the UK. In the event that personal data is transferred outside of the UK to an organisation in a country which is not considered adequate as determined by applicable data protection laws, we will take steps to ensure your personal information is adequately protected (e.g. by way EU Commission approved Standard Contractual Clauses or a vendor's Processor Binding Corporate Rules or by relying on  such other data transfer mechanisms as available under applicable data protection laws). A copy of the relevant mechanism can be obtained for your review on request by using the contact details below.

6. Your choices and rights

You have the right to ask us for a copy of your personal data; to correct, delete or restrict processing of your personal data; and to obtain the personal data you provide in a structured, machine readable format. In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement).

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep. If you have unresolved concerns, you have the right to complain to the Information Commissioner’s Office.

7. How long we retain your personal data

We take steps to ensure that we process data only for as long as it is necessary for the identified purposes. For example:

Where we process data relating to advisory contacts, we will do so until they no longer work in a role in the public eye that is relevant to our services, and their historic positions and statements are no longer relevant to our services or wider industry understanding.

Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data so that we can respect your request in future.

Where we process personal data for site security purposes, we retain it for 24 months.

Where we process personal data in connection with performing a contract, we keep the data for 6 years from our client’s last interaction with us.   

8. Updates to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

9. Contact us

The data controller for your personal data will be Greenstone Research Limited.

If you have questions about this privacy notice or wish to contact us for any reason in relation to our personal data processing, please contact us at [email protected]