This Privacy Notice tells you how Greensleeves UK Limited, (“Greensleeves”, “we” or “us”) process your personal data. It also describes your data protection rights, including a right to object to some of the processing which we carry out. More information about your rights, and how to exercise them, is set out in the Your Choices and Rights section. We also may provide you with additional information when we collect personal data, where we feel it would be helpful to provide relevant and timely information. This Privacy Notice applies to all Greensleeves franchisees and franchisee applicants. We are part of a group of companies owned by Dwyer Franchising LLC based in Texas, U.S.A which trades under the name ‘Neighborly’ (together, “The Neighborly Group”).
What Personal Data We Collect?
We collect and process the following types of personal data in connection with your role as one of our franchisees (or prospective franchisees).
- Contact & identification information
- Financial and credit check information
- Information concerning your performance, including in relation to customer feedback
- Any other information you submit to us, including during the course of any correspondence
On occasion, we also receive certain types of personal data from third party sources, such as those listed below:
- Details of certifications, training qualifications or results you have obtained from the relevant course provider.
- Membership details from professional organisations.
- Results of any requests for credit reports
- Third party recruitment or information sites, such as FranchiseDirect, Franchise Supermarket, Daltons Business and Businessesforsale
- Results of any checks from the Home Office Disclosure and Barring Service (DBS) necessary for certain customer requirements and to assess suitability as a franchisee.
Where requested, results of any psychometric testing conducted during the application process.
What data do we and our franchisees collect or hold
Personal data means any information which can be used to directly or indirectly identify you including by way of example, your name, date of birth, address, phone number, e-mail address and any device ID (such as your IP address), either by itself or when linked with other personal data.
We and our franchisees may collect, use, store and transfer different kinds of personal data about you, as categorised below:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us or our franchisees.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the website.
- Usage Data includes information about how you use the website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us, our franchisees and our third parties, and your communication preferences.
We also collect, use and share aggregated data such as statistical or demographic data, which cannot be used to identify you. For example, we may look at total statistics of the numbers of people visiting portions of our website or the number of enquiries we receive from different geographical regions.
Why We Collect, Use and Store this Personal Data
We collect, use and store your personal data for the reasons set out below.
- Where necessary for Greensleeves to enter into and perform its obligations under the Franchise Agreement.
- Assessing your candidacy for opening a franchise and negotiating any agreements with you.
- Providing you with access to our platforms and services, those of The Neighborly Group and other third party service providers (such as vendors who have signed up to ProTradeNet).
- Referring customers for your area to you if they first make contact with us.
- Monitoring and managing your provision of services to customers, including any disputes or complaints.
- To collect funds due to us under the Franchise Agreement.
- Where necessary to comply with a legal obligation.
- Carrying out anti-money laundering and other due diligence checks.
- Disclosures to law enforcement agencies or in connection with legal claims, health & safety compliance, regulatory, investigative and complaints purposes (including disclosure of such information in connection with legal process or litigation).
- Where necessary for Greensleeves’s legitimate interests, as listed below, and where our interests are not overridden by your data protection rights.
- Managing and developing our franchise network – for example, performance management, training and development, award recognition, franchisee surveys, marketing to franchisees and to encourage cooperation between existing and new franchisees (including but not limited to prospective franchisees being given the details of existing franchisees to discuss and evaluate the franchise proposition prior to signing a Franchise Agreement).
- Protecting our legitimate business interests and legal rights. This includes, but is not limited to, use in connection with legal claims, compliance, validating and facilitating trade appropriate accreditations, regulatory, auditing and investigative purposes and other ethics and compliance reporting requirements.
- Maintaining the security and integrity of our facilities, equipment and electronic platforms. This includes administering access rights, monitoring compliance with company protocols, and where permitted by local law and in accordance with relevant policies, for investigations.
- Assessing your suitability to opening and operating a franchise.
- Operation of any ethics or whistleblowing hotline which Neighborly may run now or in the future.
- To analyse and monitor the diversity of its franchise network in accordance with applicable laws.
- Where you have given consent. For example, we may ask for your permission to use your image in a company publication. Where we ask for consent, you are free to withhold or revoke it.
How We Share Your Personal Data
We share some of your personal data with other members of The Neighborly Group to administer and manage group functions, including making systems available to Group employees, to manage centralised systems and to assess your performance and the performance of Group companies. In particular, we share your personal data with Dwyer Franchising LLC, for the purposes of business planning and accounting, and monitoring and managing any customer disputes and complaints.
In relation to such personal data, Dwyer Franchising LLC will be the party responsible for it (the “data controller” in legal terms). If you have any questions in relation to Dwyer Franchising LLC’s data processing, or wish to exercise any of your choices and rights (as set out in the following section) in relation to such personal data, please contact: Jeff Meyers via [email protected].
Your personal data will also be shared with companies providing services under contract to Greensleeves, such as training providers, help desk providers, software and IT systems providers and other IT hosting and/or IT maintenance providers.
We are members of the British Franchise Association (“bfa”) and will share your personal data (Contact Information) and where they requested also franchise financial accounts, for the purposes of their assessing any application for upgraded membership we may make, periodic reviews and/or reaccreditation of our bfa membership, to identify the geographical scope of our franchise network, to determine our bfa subscription rates and to comply with the bfa’s legal obligations and its obligations to members. This information is shared with the bfa as it is in Greensleeves’s legitimate interests and where our interests are not overridden by your own data protection rights.
Your personal data will also be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the protection of our legitimate interests in compliance with applicable laws.
In the event that part of the Greensleeves business is sold or integrated with another business (in part or whole), 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/business unit.
Your Choices and Rights
You have the right to ask Greensleeves 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 or compelling interest). Where we have asked for your consent, you may withdraw consent at any time. If you ask to withdraw your consent to Greensleeves processing your data, this will not affect any processing which has already taken place at that time.
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 data protection authority in the country you reside, where you work or where we are located.
We will retain your personal data only for as long as we need it for Greensleeves’s legitimate interest in accordance with applicable law, to fulfil your franchise agreement or perform a service at your request, or to meet a legal requirement, after which we will take steps to delete your personal data or hold it in a form that no longer identifies you.
Your personal data will be processed in or accessed from the United States by The Neighborly Group. We and Dwyer Franchising LLC have entered into a specific contract approved by the European Commission which gives personal data the same protection that it has in the EU.
Some of the service providers to whom we share your personal data also access personal data in the United States and other countries that do not have equivalent data protection laws to the European Economic Area (“EEA“). Whenever we transfer your personal data out of 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 transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
If you want further information on the specific mechanism used by us when transferring your personal data out of the EEA, please get in touch using the details in the Contact Us section below.
Save as set out in the ‘How we share your data’ section above, the party responsible for your personal data (the “data controller” in legal terms) will be Greensleeves.
If you have questions about this Notice or wish to contact us for any reason in relation to our personal data processing, please contact us via [email protected].
Your Data Protection Responsibilities
As one of our franchisee, you may receive or access personal data relating to our customers, suppliers, business partners, other franchisees or Greensleeves personnel (including those of The Neighborly Group). As further detailed in the Franchise Agreement and the Manual, we expect you to comply at all times your own data protection obligations in respect of any personal data you receive or access whilst one of our franchisees.
Last updated: 20 February 2020