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Privacy Policy


So Greene - Privacy Policy


Background 


On occasions, So Greene Ltd may have reason collects professional personal data (e.g. businessrelated information) in order to support the activities of our organisation and have carried out assessments of the legal basis for processing this data.

So Greene Ltd concluded that collecting this data is necessary on the grounds of contractual and legal obligations together with our legitimate interests for the use of client data, to support membership activities and/or to deliver related commercial services.

So Greene Ltd Ltd have in place the appropriate systems and security controls to ensure that we protect your data and to prevent it from being used, lost, altered, disclosed or otherwise accessed in an unauthorised way.

This Privacy Policy sets out the basis on which any personal data we collect from you, or that which you may have provided to us directly, will be processed. By using So Greene Ltd’s systems and/or services. All parties agree to the practices described in this privacy policy.

This policy is in conjunction with So Greene Ltd’s Data Protection Policy and, in most cases, is aimed towards the induvial rather than a third-party customer. 


How So Greene Ltd uses personal data 


So Greene Ltd will only use personal data in accordance with the law. Most commonly, So Greene Ltd will use personal data in the following circumstances:

Where it needs to perform the contract that is about to be entered into, or have entered into with an induvial.

Where it is necessary for So Greene Ltd’s legitimate interests (or those of a third party) and the interests and fundamental rights do not override the interests of the induvial.

Where So Greene Ltd need to comply with a legal or regulatory obligation.


Data Security


So Greene Ltd has put in place appropriate security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, So Greene Ltd limit access to personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process personal data on So Greene Ltd’s instructions and they are subject to a duty of confidentiality.

So Greene Ltd has also put in place procedures to deal with any suspected personal data breach and will notify the applicable regulator of a breach where legally required to do so.


Data Retention


So Greene Ltd will only retain personal data for as long as necessary to fulfil the purposes it was collected for, including for the purposes of satisfying any legal, accounting or reporting requirements.

To determine the appropriate retention period for personal data, So Greene Ltd considers the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of personal data, the purposes for which it will process personal data and whether it can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of personal data are available on request from the Privacy Policy Champion. 


Rights 


Under data protection laws, all induvial have the right to: 

Request access to their personal data.

Request correction of their personal data that is held.

Request erasure of their personal data.

Object to processing of their personal data.

Request restriction of processing of their personal data.

Request the transfer of their personal data to a third party.

Any induvial that wishes to exercise any of the rights set out above must contact So Greene Ltd directly and in writing.

Before processing any request, So Greene Ltd may need to request specific information to help us confirm identity and ensure the right to access 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. So Greene Ltd may also contact the individual for further information in relation to the request to speed up it’s response.

So Greene Ltd try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if the request is particularly complex or if several requests have been made.

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