Privacy statement and Cookies Policy

Privacy Statement

How your personal information is used by Green Letterbox Company

Last updated October 2013

Your information will be held by Green Letterbox Limited (“us”, “we”, “Green Letterbox”).

Please read this Privacy Policy to understand how we use and protect the information that you provide to us through the “Website”. By accessing any part of this Website or providing any information to us you consent to the use and transfer of your information on the terms set out in this Privacy Statement and Cookies Policy.

We reserve the right to revise or supplement this Privacy Statement and Cookies Policy from time to time at our sole discretion and you agree to revisit this page regularly to ensure that you are familiar with the most current version. By continuing to access or use the Website you will be agreeing to any such changes.

If you are a customer or user of a Green Letterbox company, details of the information we collect and how we use it will also be set out in the terms and conditions of the product or service which you hold. In the event of a conflict between this Privacy Statement and Cookies Policy and the terms and conditions of your specific product or service, the terms and conditions of your specific product or service will take precedence.

Personal information that we collect and where we collect it from

We retain two types of information:

“Personal Data”

This is data that identifies you or can be used to identify or contact you and may include your [name, address, telephone number, email address, user IP addresses in circumstances where they have not been deleted, clipped or anonymised, telephone number, birth date and billing and credit card information]. Such information is only collected from you if you voluntarily submit it to us.

“Non-Personal Data”

Like most websites, we gather statistical and other analytical information collected on an aggregate basis of all visitors to the Website. This Non-Personal Data comprises information that cannot be used to identify or contact you, such as demographic information regarding, for example, user IP addresses where they have been clipped or anonymised, browser types and other anonymous statistical data involving the use of the Website.

We obtain such personal and non-personal data in various ways, including:

a. through your contact with Green Letterbox, for example in emails and letters, during telephone calls and conversations in head office, when registering for services, in customer surveys, when you participate in competitions and promotions, through Green Letterbox Websites;

b. from analysis of your payments and other transactions (such as the amount, frequency, location, payment due dates, minimum payment amounts, payoff amounts, origin and recipient); and

c. information Green Letterbox receives from or through other organisations (for example, card networks, credit reference agencies, insurance companies, retailers, social networks and fraud prevention agencies) whether in the course of providing products and services to you or otherwise.

We also monitor the manner in which you click through the Website so that we can improve your user experience. For example, we will know whether and when you accessed your account and viewed a particular bill, statement or correspondence. If you receive special offers or other materials through Green Letterbox, we may also know which pages and items you view or click on.

We do not knowingly collect information on children under the age of 18.

You must not give Green Letterbox personal information about someone else (such as a joint applicant) without first getting his or her consent for it to be used and disclosed in the ways described in this condition. This is because Green Letterbox will assume he or she has consented, and Green Letterbox reserves the right to ask for confirmation of consent. Where you do give Green Letterbox information about someone else, or someone else discloses a connection with you, that information may be taken into account with your other personal information.

We will not retain your personal information for longer than is necessary for the maintenance of your account, or for legal or regulatory requirements.

Domain name information that we collect is not used to personally identify you and instead is aggregated to measure the number of visits, average time spent on the Website, pages viewed etc. We use this information to measure the use of our Website and to improve its contents.

We may monitor or record phone calls with you in case we need to check we have carried out your instructions correctly, to resolve queries or issues, for regulatory purposes, to help improve our quality of service, and to help detect or prevent fraud or other crimes. Conversations may also be monitored for staff training purposes.

Using information on social networking sites

As part of our on-going commitment to understanding our customers better, we may research comments and opinions made public on social networking sites such as Twitter and Facebook.

Use of your Personal Data

Your personal data held by Green Letterbox may be stored and used for:

a. providing you with products and, services and notifying you about important changes or developments to the features and operation of those products and services;

b. updating, consolidating and improving the accuracy of our records;

c. crime detection, prevention and prosecution;

d. responding to your queries and complaints;

e. administering offers, competitions and promotions;

f. evaluating the effectiveness of marketing and for market research, training, statistical analysis and customer modelling (with the aim of improving services);

g. identifying products, services and offers which we or others believe may be of interest to you;

h. managing your relationship with Green Letterbox

Should you wish to obtain further information about how Green Letterbox uses your personal data please contact us at the details set out below.

If you have agreed, we may contact you about products, services and offers available from Green Letterbox, which we believe may interest you. You may notify us at any stage if you change your mind and no longer wish to receive direct marketing communications.

Green Letterbox may use automated decision-making systems when assessing your application, managing your borrowing and to detect fraud or money laundering.

Sensitive Personal Data

“Sensitive” personal data, as defined in the Data Protection Act 1988 and 2003 (the “DPA”) includes data relating to racial or ethnic origin, political opinions, religious beliefs, trade union membership, physical or mental health, sexual life, criminal proceedings and offences. When you apply for certain products or services, we may ask you for some “sensitive” information, but we will always ask for your explicit consent to collect such data. As a customer, there may also be times when you give us “sensitive” information. We will use it to provide the service you require and may share it with other parts of the group and our subcontractors to keep our records up to date.

Joint applicants

Sometimes, when you open a joint account or product, this may mean that your personal data will be shared with the other applicant. For example, correspondence, bills or transactions made by you will be seen by your joint account holder and vice versa.

How we check your identity

We may ask you to provide physical forms of identity verification when you open your account. Users during registration or submit notification of change the address, and they receive a new verification code to address they submitted.

Disclosure of Personal Data

Green Letterbox will treat your personal data as private and confidential, but may disclose it outside the Green Letterbox if:

a. required to complete the agreement entered into between you and Green Letterbox;

b. you consent;

c. necessary for Green Letterbox companies’ agents, advisors or others involved in running accounts and services for you or collecting what you owe Green Letterbox;

d. required by Department of Revenue, HM Revenue & Customs or other authorities;

e. required to comply with legal obligations; or

f. required by State authorities to investigate or prevent crime.

Undertaking Anti-Money Laundering Checks

To comply with Anti-Money Laundering Regulations, there are times when we need to confirm (or reconfirm) the name and address of our customers.

Credit and/or Debit Cards

If you use a credit or debit card to pay for bills, we will share transaction details with our secure payment providers (e.g. Realex, Visa or MasterCard).

Some transactions that you or an additional card holder makes on a card account may cause sensitive or confidential details to appear on your statement. By using your card to make such transactions you give us your explicit consent to process this information.

Sale of Business

Green Letterbox may in the future wish to sell, transfer or merge part or all of their business or assets, or any associated rights or interests, or to acquire a business or enter into a merger with it. If so, your personal information may be disclosed to a potential buyer, transferee, or merger partner or seller and their advisers so long as they agree to keep it confidential and to use it only to consider the possible transaction.

If the transaction, the buyers, transferee or merger partner may use or disclose your personal information in the same way as set out in this Privacy Statement and Cookies Policy.

Anonymised Reports

Data, reports or statistics created using your personal information may be shared amongst Green Letterbox and other companies or organisations outside the Green Letterbox group. We will only share these data, reports or statistics outside the group where they have been aggregated or anonymised so that they do not identify you as an individual.

Accessing and Updating your personal information

You may inform us of any changes in your personal data, and in accordance with our obligations under the DPA we will update or delete your personal data accordingly. To find out what personal data we hold on you or to have your personal data updated, amended or removed from our database, please email your request to us via the “Contact Us” section on the Website. Any such data subject requests may be subject to the prescribed fee.

How we may contact you

Using your mail address or email address for service contact

Making sure we deliver excellent customer service is very important to us and to do this various methods of communication may be used to keep you updated about your account. Most of the time we communicate by telephone or post, but we recognise that email is becoming a more popular process. If we decide to use email to contact you, we will only do this if we have ensured that using email will not put your information at risk, or, if you have requested we email you, that we have explained the risks of sending an “insecure” email and that you are happy to accept that risk.

In addition you may wish to choose a channel of communication that suits you when you need to contact us. If you need to email Green Letterbox, we recommend you check the Website to see if a secure email facility exists so that your email can be sent securely. If you send us emails in other ways, such as from your personal account, then remember that the message may not be secure and there is a risk that it could be intercepted. If you choose to send an “insecure” email, please keep the amount of confidential information you include to a minimum. With some of our products we offer a number of communication update services via SMS. If you have signed up to this service, we may send you text messages containing administrative information about your relationship with us. You can ask us to stop sending these messages at any time. Additionally, in extraordinary circumstances (such as natural disaster or civil unrest) we may also send you updates by text message or email when we consider it to be appropriate.

Cookies Policy

Using cookies

Green Letterbox is committed to protecting you and any data (anonymous or otherwise) that we collect about you online. This section tells you how we use cookies, why, and how this allows us to improve our service. It also tells you how you can manage what cookies are stored on your device.

By using our Website (through any device) you agree that this Cookies Policy applies to that use in addition to any other terms and conditions which may apply. We reserve the right to make changes to our Cookie Policy. Any such changes shall appear here and become effective immediately. Your continued use of our Websites is taken as meaning that you agree to any such changes.

What is a cookie?

Cookies are files containing small amounts of information which are downloaded to the device you use when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies do lots of different and useful jobs, such as remembering your preferences, and generally improving your online experience. There are different types of cookies. They all work in the same way, but have minor differences.

Session Cookies

Session cookies last only for the duration of your visit and are deleted when you close your browser. These facilitate various tasks such as allowing a website to identify that a user of a particular device is navigating from page to page, supporting website security or basic functionality. Many of the cookies we use are session cookies. For example, they help us to ensure the security of your Green Letterbox account session, and can also keep you signed in to Green Letterbox account while you move between pages or service your account.

Our session cookies used for security are designed to be very difficult to read, change, access or use except by us when you have an active Green Letterbox account session. They contain no personal information that can be used to identify an individual.

Persistent Cookies

Persistent cookies last after you have closed your browser, and allow a website to remember your actions and preferences. Sometimes persistent cookies are used by websites to provide targeted advertising based upon the browsing history of the device.

Green Letterbox uses persistent cookies in a number ways, for example, to remember your username for log in. We also use persistent cookies to allow us to analyse customer visits to the Website. These cookies help us to understand how customers arrive at and use the Website so we can improve the Green Letterbox service.

Strictly Necessary Cookies

These cookies are essential in order to enable you to move around the website and use its features, and ensuring the security of your online Green Letterbox account. Without these cookies services you have asked for, such as applying for products and managing your accounts, cannot be provided. These cookies don’t gather information about you for the purposes of marketing.

Performance Cookies

These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. [These cookies don’t collect information that identifies a visitor although they may collect the IP address of the device used to access the Website. All information these cookies collect is anonymous and is only used to improve how a website works, the user experience and to optimise our advertising. By using our Websites you agree that we can place these types of cookies on your device, however you can block these cookies using your browser settings.

Functionality Cookies

These cookies allow the Website to remember choices you make (such as your username). They may also be used to provide services you have requested such as watching a video. The information these cookies collect is anonymised (i.e. it does not contain your name, address, account details, etc.) and they do not track your browsing activity across other websites. By using our Websites you agree that we can place these types of cookies on your device, however you can block these cookies using your browser settings.

Targeting Cookies

These cookies collect several pieces of information about your browsing habits. They are usually placed by advertising networks. They remember that you have visited a website and this information is shared with other organisations such as media publishers. These organisations do this in order to provide you with targeted adverts more relevant to you and your interests. This type of advertising is called online behavioural advertising.

Additional Information

From time to time, we may embed external content from third party websites (e.g. Facebook, YouTube) within our Website. Additionally, we partner with third parties who provide services for us which you can navigate to and from our Website. These third parties may use cookies. You must read the Privacy Statements and Cookie Policies on those websites in order to determine how those websites use your personal data and cookies.

What if I don’t want to accept cookies?

If you wish to restrict or block the cookies which are set by any website – including Green Letterbox websites; you should do this through the browser settings for each browser you use, on each device you use to access the internet.

Please be aware that some of our services, for example the Green Letterbox account will not function if your browser does not accept cookies. However, you can allow cookies from specific websites by making them “trusted websites” in your internet browser.

Changes to Privacy Statement & Cookies Policy

We keep our Privacy Statement & Cookies Policy under regular review and we will reflect any updates on the Website. You are required to revisit this Privacy Statement & Cookies Policy in order to understand our use of your personal information and the use of cookies.

This Privacy Statement & Cookies Policy was last updated in October 2013