Website of Green Letterbox Limited T/A Mail Metrics
Last revised August 2020
Green Letterbox Limited respects your privacy and is committed to protecting the personal data of our individual website visitors as well as the personal data entrusted to us by our commercial clients. Any processing of personal data conducted by us will be compliant with the General Data Protection Regulation 2018 (“the GDPR”).
Sections 1 – 9 of this Privacy Statement will inform you as to how we look after your personal data when you visit our Website (see below) (regardless of where you visit from) and tell you about your privacy rights and how the law protects you.
Section 10 of this Privacy Statement will provide an outline of our commitment to process any client data entrusted to us in a compliant and secure manner.
Reference in this document to “we”, “us”, “our”, and “ours” refers to Green Letterbox Limited, and its associated website Mail Metrics (www.MailMetrics.io). This Privacy Statement is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary in Section 11 below to understand the meaning of some of the terms used in this privacy notice.
Important information and who we are
Purpose of this Privacy Statement: The following sections of this privacy statement aim to give you information on how Green Letterbox Limited collects and processes your personal data through your use of our Website, including any data you may provide through our Website when you sign up to a newsletter we may publish, purchase a service or take part in a survey or competition. Our website is not intended for children and we do not seek or knowingly collect data relating to children. It is important that you read this Privacy Notice together with any other fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Under the terms of the GDPR, where you provide your personal data to us for the purposes mentioned above, Green Letterbox Limited is the data controller and responsible for your personal data. We are referred to as "we", "us" or "our" in this privacy statement on our Website. If you have any questions about this privacy notice, including any requests to exercise your legal rights as referred to in Section 9 below, please contact us using the details set out below.
Where you are a commercial client sharing data with Green Letterbox Ltd., please note that Green Letterbox is a Data Processor in the provision of such services. We refer you to Section 10 below to understand your rights and obligations under the GDPR where you engage our services to manage your company’s data.
Our full Contact details are:
Full name of legal entity: Green Letterbox Limited;
Company registration number is 524420 and
Our registered office and main trading address is at Persona Building, Clonshaugh Technology and Business Park, Dublin 17, D17X592, Ireland.
Email address: email@example.com
Our Website is: www.mailmetrics.com
Changes to the Privacy Statement. This version was created on the 24th July 2020 and complies with the General Data Protection Regulation.
Third-party links Our Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy notice of every website you visit.
The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymised data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
I. Identity Data includes (i) information about you that you give us whether verbally or in writing when you search for or ask for a product or service, purchase a product or service from us, or by filling in forms on our Website or by corresponding with us by phone, e-mail or otherwise and when you report a problem with the site. (ii) Identity & contact information such as name, copies of ID, contact details, online user identities (such as internet protocol addresses, cookie identifiers, email address, phone numbers) and (iii) CCTV images at our premises (but only for security reasons and to help prevent fraud or crime)
II. Contact Data includes billing address, delivery address, email address and telephone number.
III. Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
IV. 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 our Website.
V. Profile Data includes your username and password, purchases or orders made by you and your preferences.
VI. Usage Data includes information about how you use our Website, products and services or if you make a complaint about a product or service.
VII. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
VIII. Special Categories of Personal Data. Where personal data we collect from you is within article 9 of the GDPR, we will only process this personal data, where you have given your explicit consent.
IX. Information from your online activities with third parties where you have given us your consent (for example, by consenting to our use of certain cookies or other location tracking technologies).
X. Information which you have consented to us using. For example, if we have your agreement to allow us to contact you through certain channels to offer you relevant products and services.
XI. Information from online activities. We may collect information about your internet activity using technology known as cookies, which can often be controlled through internet browsers. We collect information about your internet browser settings or otherwise Internet Protocol (IP) and other relevant information to help us identify your geographic location when providing you with our services.
We also collect and use Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
How is your personal data collected
We use different methods to collect data from and about you including through:
I. Direct interactions. You may give us your Identity, Contact and/or Special Categories of Personal Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: - apply for our products or services; - create an account on our Site; - request marketing information or data to be sent to you; or - give us some feedback.
III. Third parties or publicly available sources. We may receive personal data about you from various third parties, and/or public sources as set out below: - Technical Data from the following parties: i. analytics providers such as Google based outside the EU.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
I. Where we need to perform the contract we are about to enter into or have entered into with you.
II. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
III. Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us as provided above.
Purposes for which we will use your personal data: When we ask for your consent, we will provide you with more information on how we will use your data in reliance on that consent, including in relation to third parties we would like your consent to share your data with. We have set out below, in a table format and below the table format, a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal basis we are relying on to process your personal data where more than one basis has been set out in the table below.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer
(a) Identity (b) Contact
Performance of a contract with you
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and our Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Identity (b) Contact (c) Technical
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
(a) Technical (b) Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about products or services that may be of interest to you
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile
Necessary for our legitimate interests (to develop our products/services and grow our business)
Purposes for which we will use your personal data (continued). Without prejudice to the foregoing and in order to provide our products and services to you and perform our contract with you, we use your information to:
I. manage and administer your accounts, or other products and services that we may provide you with.
II. contact you by post, phone, text message, email, fax, or other means, but not in a way contrary to your instructions to us or contrary to law.
III. recover fees you may owe us.
IV. manage and respond to a complaint or appeal.
V. protect our business, reputation, resources and equipment, manage network and information security (for example, developing, testing and auditing our website and other systems, dealing with accidental events or unlawful or malicious actions that compromise the availability, authenticity, integrity and confidentiality of stored or transmitted personal data, and the security of the related services) and prevent and detect fraud, dishonesty and other crimes (for example, to prevent someone trying to steal your identity)
VI. to comply with our legal and regulatory obligations
VII. complying with your information rights.
VIII. providing you with statutory and regulatory information and statements.
IX. complying with binding requests from regulatory bodies.
X. complying with binding production orders or search warrants, and orders relating to requests for mutual legal assistance in criminal matters received from law enforcement agencies/prosecutors.
XI. Complying with court orders arising in civil or criminal proceedings.
XII. Performing a task carried out in the public interest.
Where you have given us permission (which you can withdraw at any time) we may:
I. send electronic messages to you about product and service offers from our company and/or our selected and trusted partners.
III. use special categories of data, or sensitive data.
Marketing We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
Promotional offers from us: We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You may receive marketing communications from us if you have requested information from us or purchased products or services from us or if you provided us with your details when you registered for a promotion or registered for a survey and, in each case, you have not opted out of receiving that marketing.
Third-party marketing: We will get your express opt-in consent before we share your personal data with any company outside of our Company, for marketing purposes.
Opting out: You can ask us or third parties to stop sending you marketing messages at any time by logging into our Website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time as set out above. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product or service purchase, warranty registration, product or service experience.
Change of purpose We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at any of our contact details set out above. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
I. Internal Third Parties as set out in the Glossary.
II. External Third Parties as set out in the Glossary.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions and contractual obligations.
Whenever we transfer your personal data outside 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:
I. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
II. 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. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Please contact us as above if you want further information on the specific mechanism used by us if/when transferring your personal data to destinations outside of the EEA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. More particularly, the length of time we hold your data depends on many factors, such as regulatory rules and the type of product we have provided to you. Those factors include:
I. The regulatory rules contained in laws and regulations or set by authorities like the Revenue Commissioners and the Central Bank of Ireland.
II. The type of product or service that we have provided to you.
III. Whether you and us are in a legal or some other type of dispute with another person or each other.
IV. The type of data we hold about you.
V. Whether you or a regulatory authority asks us to keep it for a valid reason.
In some circumstances you can ask us to delete your data: see the right to erasure below for further information.
Your individual legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. The data subject rights are:
I. The right to be informed (Articles 12 - 14 of the GDPR).
II. The right to access information (Article 15 of the GDPR).
III. The right to rectification (Articles 16 & 19 of the GDPR).
IV. The right to erasure (Articles 17 & 19 of the GDPR).
V. The right to data portability (Article 20 of the GDPR).
VI. The right to object to processing of personal data (Article 21 of the GDPR).
VII. The right of restriction (Article 18 of the GDPR).
Further details regarding these rights can be viewed here. If you wish to exercise any of the rights set out above, please contact us at firstname.lastname@example.org or using any of the other contact details provided above.
No fee required: You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you: We may need to request specific information from you to help us confirm your identity and ensure your right to access your 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. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond: We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Processing of Client Data
Where our clients entrust the personal data of customers, patients or other Data Subjects to us, Mail Metrics undertakes to abide by the provisions of the General Data Protection Regulation in any processing of such data which we undertake.
While the contract terms will vary from engagement to engagement, they will generally cover the following commitments, outlined in the GDPR (Article 28):
We accept that our Client’s instructions for the contracted processing of Personal Data shall comply with relevant Data Protection Laws and Regulations. Our Client will have sole responsibility for the accuracy, quality, and legality of Personal Data which they entrust to us;
Further, we accept the primacy of our Client’s Lawful Basis for its processing of the personal data. We will process the data on the basis of, and within the parameters of, the contractual undertaking which we enter into with each Client;
Our personnel will not access, view or otherwise process any of the data that our Client entrusts to us unless instructed by the Client, via the Data Processor contract;
We will only process Personal Data on behalf of and in accordance with our Client’s documented instructions for the following purposes:
Processing in accordance with the Data Processor Agreement and applicable instructions; and
Processing to comply with other documented reasonable instructions provided by the Client (e.g., via email) where such instructions are consistent with the terms of the Data Processor Agreement.
Taking into account the nature of the Processing, Mail Metrics will assist our Client by providing appropriate technical and organizational measures, insofar as this is possible, for the fulfilment of the Client’s obligation to respond to a Data Subject Request under appropriate Data Protection Laws and Regulations.
Any Data Subject Requests received by us will be referred, in the first instance, to the Client as the Data Controller.
We may, from time to time, engage third-party Sub-processors in connection with the provision of the Services. Where this occurs, we will enter into a written agreement with each Sub-processor containing data protection obligations not less protective than those in the Client Agreement with respect to the protection of the Client’s data, based on the nature of the Services provided by such Sub-processor(s).
We will make available to the Client the current list of Sub-processors whom we engage for the Services identified.
We will maintain appropriate technical and organizational measures for the protection of the security, confidentiality and integrity of the Client data (including protection against unauthorized or unlawful Processing and against accidental or unlawful destruction, loss or alteration or damage, unauthorized disclosure of, or access to, the data).
On termination of the contractual engagement, we will return any personal data to our Client and will delete ant related data in accordance with the procedures and timeframes specified in the security, privacy and system architecture documentation relating to the engagement.
Glossary of Terms
I. Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
II. Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
III. Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
I. Internal Third Parties - Other companies in the Persona Group [acting as joint controllers or processors] and who are based in the EEA and provide IT and system administration services or print and fulfilment services.
II. External Third Parties - Service providers [acting as sub-processors] who provide IT and system administration services to us. - Professional advisers [acting as processors or joint controllers] including lawyers, bankers, auditors and insurers based in Ireland who provide us with consultancy, banking, legal, insurance and accounting services. - Regulators and other authorities [acting as processors or joint controllers] based in Ireland, who require reporting of processing activities in certain circumstances.
Your Legal Rights
You have the right to:
I. Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
II. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
III. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
IV. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
V. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
VI. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
VII. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Changes to this Privacy Statement: We may amend or update this privacy statement from time to time. Any changes will be communicated to you and to our Clients, will be made available on this page and, where appropriate, notified to you and our Clients by letter or e-mail. Please check back frequently to see any updates or changes to our privacy statement.