Table of Contents
- Data Protection Officer and Data Controller
- Purpose of the Processing and the Legal Basis for the Processing
- What categories of personal data we collect, how we collect and use (process) it and for what purpose(s)
- Your Rights
- Questions, Concerns and Complaint with a Supervisory Authority
- Disclosure of Personal Data
- Direct Marketing including SMS Marketing
- Transferring personal data from the EU to the US
- Security of Personal Data
- Contacting Us
Our website, products and services are all directed to people who are at least 18 years old or older.
2. Data Controller, Data Controller’s Representative, Data Protection Officer
2.1 The Data Controller controlling the means of processing of your Personal Data and the purposes of such processing is:
Grenade (UK) Limited (trading as Grenade)
Registered in England with company number 06978658
Registered address: Grenade HQ, Bournville Place, Bournville, Birmingham, B30 2HP, United Kingdom
For UK and EU residents –Grenade (UK) Grenade HQ, Bournville Place, Bournville, Birmingham, B30 2HP, United Kingdom
For US residents - Grenade® (USA) LLC, 999 W Main Street, Suite 100, Boise, ID, 83702
2.2 Where one of the Grenade group companies is responsible for processing personal data outside the EU, Grenade (UK) Limited registered in England is its EU representative.
2.3 Grenade’s data protection officer can be contacted as follows: email@example.com
Tel: + 44 (0) 2477 170 100 and ask for the DPO.
2.4 Where Grenade products are sold to you by a third-party retailer, Grenade may collect such Personal Data as is necessary from that third party to complete your order, passes delivery details to Grenade’s third-party delivery contractor (for which Grenade is responsible) and such delivery Personal Data is destroyed within one month of completed delivery. In these circumstances, Grenade is a Data Processor acting upon the written instructions of the retailer with whom you contract, and it is that retailer which is the Data Controller in respect of your Personal Data. You should direct any queries directly to that retailer.
3. Purpose of the Processing and the Legal Basis for the Processing
We gather two types of information in the operation of this website and provision of services to you:
3.1. Personal Data:
We collect information from you when you:
- Contact Us on our site by filling out a form
- Complete an order on our website or at one of our pop-up shops
III. Create an account to collect Grenade® Loyalty Points
- Apply for a job or become a member of our team
- Contact us through our social media sites
- Contract with a third-party retailer for our products - please see paragraph 2.4 above
When registering with us in any of these ways or sending emails, submitting your CV, requesting newsletters / blogs or providing feedback, you may be asked to enter your: name, e-mail, address and/or telephone number information as appropriate. In order to compete delivery of an order, we shall require your mobile telephone number. This information will only be used by us in accordance with the terms herein, to enable us to contact you and discuss what services we can provide to you.
When you contact us, you will be asked clearly to tick consent to our processing of necessary categories of Personal Data, for each contractually agreed purpose we are to provide. Your consent will enable you to participate in features of the service and notify you about changes to the service.
The provision of your Personal Data is voluntary. If you do not provide us with the required Personal Data, however, we may not be able to provide you with the product/service you requested and will not be able to complete a delivery to you. Grenade requires this Personal Data in order to be able to complete its contractual obligations to you, for the purposes of: processing and administering your transactions, fulfilling your requests, orders and/or to provide other information you requested and to complete delivery of your order.
3.2. Non-Personal Data:
We may collect information about your visit to and use of this site, including sales data, traffic data and related site information. This information helps us to evaluate and improve our site and may also be used for investment analysis purposes. As Non-Personal Data does not personally identify you, we may use it for any purpose.
4. What Categories of Personal Data We collect; How We Collect and Use (process) it and for What Purpose(s)
4.3 What We Use Your Personal Data For
We collect information from you which may be used for the following listed purposes. This is not a definitive list and may change from time to time. Please confirm your consent when you register/place and order or contact us for the first time on the table then provided.
Process and administer your Personal Data and process transactions, fulfil your requests, orders and/or to provide other information you requested. (Where you have subscribed to a third-party distributor of our products and we are providing products to that third party, we do not have access to your Personal Data and that third party is responsible for your Personal Data as agreed between you.). Grenade requires this Personal Data in order to be able to complete its contractual obligations to you.
Complete delivery of your order. Grenade requires this Personal Data in order to be able to complete its contractual obligations to you.
Retain order details for repeat orders where you request us to do so
Send periodic emails and, where you opt in, SMS messages (Please see Direct Marketing below)
Notify you about important news or blogs concerning our products, industry updates, events, promotions and competitions, reports and other information. This includes Grenade® Special Offers and Exclusive Grenade® Content.
Match Personal Data with third party data. Also, we may keep track of what portions of the website users are visiting and other user statistics and aggregate this information to help us create a better experience for users of our website. This is all done in order to describe our products and services to prospective partners, advertisers, and other third parties, and for other lawful purposes.
Promote our products and services on our website and third-party partners’ websites
Provide you with information about products and services that you request from us or, where you have consented to be contacted, for such purposes which we feel may interest you
To respond to your enquiries or comments submitted through our website
To obtain your feedback
To permit applications for employment with us and related activities to such applications
In addition, in order to carry out our lawful activities and for legitimate purposes, we may collect and process your Personal Data to:
Allow you to use interactive features on our website
Retain a record of incoming and outgoing communications (e.g. email)
Protect the security and integrity of the website
Prevent and detect fraud or other prohibited or illegal activity
In response to a court order, request for cooperation from a law enforcement or other government agency
To establish or exercise legal rights
To bring or defend legal claims
For responsible corporate governance or as otherwise required or permitted by applicable laws and/or regulations
In circumstances in which we believe disclosure is appropriate in connection with fraud prevention and prevention of other illegal, or unlawful activity or any other activity which is or may be contrary to our legal and regulatory compliance obligations
To protect and defend the rights, property or safety of Grenade and/or other companies in the Grenade group, its/their investors and other clients, staff, and/or service providers.
We continually strive to improve our website offerings based on the information and feedback we receive from you. Your information helps us to respond more effectively to your requests and support your needs. Note: If at any time you would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email.
5. Your Rights in respect of your Personal Data:
This Privacy Notice is intended to provide you with information about what Personal Data Grenade® collects about you and how it is used. If you have any questions, please contact us at dpo.grenade.com.
If you wish to confirm that Grenade is processing your Personal Data, or to have access to the Personal Data Grenade® may have about you, please contact us at firstname.lastname@example.org.
You have various rights in respect of your Personal Data which can be summarised as follows:
- The right to be informed. Where Grenade intends to collect your Personal Data, you have a right to consent or object to such collection for the intended purposes. In respect of each intended purpose you will be asked to tick box to indicate your consent to each intended purpose for processing of your Personal Data.
- The right of access. You may request to receive a copy of any Personal Data held by us, which personally identifies you. We may in some circumstances charge an administration fee to cover the cost of carrying out your request. We may ask you to verify your identity and for more information about your request.
- The right to rectification. We will correct or erase inaccuracies in the information we hold about you when we learn of the inaccuracy.
- The right to erasure. Personal Data may be erased if we do not have a legitimate reason for retaining the information.
- The right to restrict processing;
- The right to data portability;
- The right to object;
- Rights in relation to automated decision making and profiling. Grenade does not carry out any automated decision making.
Please contact Grenade in writing with any requests and provide verification that you are who you say that you are.
You may withdraw your consent to your Personal Data being processed at any time (the opt out button is available next to the opt in button where you provided your consent and for SMS marketing see clause 7 below). However, if you withdraw consent, we may not be able to provide you with the product/service which you requested.
6. The Right to Lodge a Complaint with a Supervisory Authority
If you have a reason to complain about how your personal data has been controlled and processed by Grenade®, please in the first instance contact Grenade® and we shall endeavour to resolve your queries promptly. If you remain unsatisfied, you may lodge a complaint with:
Office of the Information Commissioner
Address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Phone: +44 303 123 1113 or 01625 545 745
Please copy any such communication to us so that we can work to resolve any outstanding issues promptly.
7. Disclosure of Personal Data
Your information, whether public or private, will not be sold, exchanged, transferred, or given to any other company for any reason whatsoever, without your consent, other than for the express purpose of delivering the product or service requested.
We may also disclose Personal Data in special cases when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating our Terms of Service, or may be causing injury to or interference with any of our rights or property, other users, or anyone else. We may disclose or access account information when we believe in good faith that the law requires it and for administrative and other purposes that we deem necessary to maintain, service, and improve our products and services.
8. Direct Marketing including SMS Marketing
General: On occasion, we engage third parties to mail information to you, including items about products you may have purchased, or material from an event sponsor. We have a legitimate interest in processing of Personal Data for direct marketing purposes. We may send postal marketing about a new product; you may opt-out of this at any time by following the instructions in the marketing communication itself or by contacting us through this website. In the context of a sale, we may have sought your consent for electronic marketing, but again you may opt out of this at any time.
SMS Marketing: We may market to you by SMS where you consent to this, i.e. our mobile message service (the "SMS Service"). If you consent to this then this is on the basis that you accept the terms in this clause (“Mobile Terms”). We may modify or cancel the SMS Service or any of its features without notice. To the extent permitted by applicable law, we may also modify the Mobile Terms at any time and your continued use of the Service following the effective date of any such changes shall constitute your acceptance of such changes. We do not charge for the SMS Service, but you are responsible for all charges and fees associated with text messaging imposed by your wireless provider. Message and data rates may apply.
For US/Canadian customers text the single keyword command STOP in reply to an SMS we send to you. For customers in the UK click the unsubscribe link in any text message to cancel the SMS Service at any time or text the single keyword command STOP in reply to an SMS we send to you. You will receive a one-time opt-out confirmation text message. If you have subscribed to other mobile message programs of ours and wish to cancel, except where applicable law requires otherwise, you will need to opt out separately from those programs by following the instructions provided in their respective mobile terms. For SMS Service support or assistance, text HELP to the number from which you received the text message or email email@example.com
We may change any short code or telephone number we use to operate the SMS Service at any time and will notify you of these changes. You acknowledge that any messages, including any STOP or HELP requests, you send to a short code or telephone number we have changed may not be received and we will not be responsible for honouring requests made in such messages. The wireless carriers supported by the Service are not liable for delayed or undelivered messages. You agree to provide us with a valid mobile number. To the extent permitted by applicable law, you agree that we will not be liable for failed, delayed, or misdirected delivery of any information sent through the SMS Service, any errors in such information, and/or any action you may or may not take in reliance on the information or SMS Service.
9. Transferring Personal Data to the US or EU
The personal information Grenade® collects from you is stored in one or more databases hosted by third parties located in the United Kingdom. These third parties do not use nor have access to your personal information for any purpose other than cloud storage and retrieval.
Grenade®’s email services are provided by Mailgun based in the United States. We are satisfied that they have appropriate technological and organisational measures in place to reflect the provisions of GDPR and, in the UK. UKGDPR. In addition, where distributors are based in the United States and you have contracted with that distributor, information we collect from you may be processed in the United States. The United States has not sought nor received a finding of “adequacy” from the European Union nor the UK under Article 45 of the GDPR and UKGDPR. Grenade relies on derogations for specific situations as set forth in Article 49 of the GDPR and UKGDPR. In particular, Grenade® collects and transfers to the U.S. Personal Data only: with your consent; to perform a contract with you; or to fulfil a compelling legitimate interest of Grenade® in a manner that does not outweigh your rights and freedoms. Grenade® endeavours to apply suitable safeguards to protect the privacy and security of your Personal Data and to use it only consistent with your relationship with Grenade and the practices described in this Privacy Notice. Grenade also minimizes the risk to your rights and freedoms by not collecting nor storing sensitive information about you.
10. Security of your Personal Data
To help protect the privacy of data and personally identifiable information you transmit through use of this site, we maintain physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your Personal Data to those employees who need to know that information to provide benefits or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees' privacy responsibilities.
11. Retention Period
We shall retain and store your Personal Data securely and for as long as necessary in order to fulfil our and our distributors’ (where applicable) contracts with you. Where we have been provided with your mobile telephone number in order to arrange delivery, that telephone number shall only be retained for a maximum of one calendar month after delivery. We shall then only retain other Personal Data for as long as necessary to comply with our legal obligations and legitimate interests under relevant law or where you have asked us to retain your details for repeat orders.
For more information on where and how long your Personal Data is stored, and for more information on your rights of erasure and portability, please contact the Grenade®’s data protection officer at firstname.lastname@example.org.
12. Terms of Service and Cookies
Please also visit our Terms of Service section establishing the use, disclaimers, and limitations of liability governing the use of our website.
In order to be able to offer you Klarna’s payment options, we will pass to Klarna certain aspects of your personal information, such as contact and order details, in order for Klarna to assess whether you qualify for their payment options and to tailor the payment options for you.
15. Contacting Us