Privacy Policy

1. Introduction

1.1          Green Signals is a media production company that specialises in the production and publishing of podcasts, vlogs and films via popular and well-known platforms including, inter alia, YouTube, Spotify, Apple Podcasts and other podcast platforms that make use of our RSS feed.

1.2         We focus primarily on making programmes that are recognised as news, informed commentary and documentary. We aim to produce our programmes in an entertaining and enjoyable style. We do not undertake investigative journalism or anything that would be considered as such under the widely accepted meaning of investigative journalism.

1.3          Green Signals is committed to respecting and protecting your privacy and complying with Data Protection Legislation including the General Data Protection Regulation (GDPR) and the Data Protection Act 2018 (DPA).

1.4          This policy refers to the GDPR and unless otherwise explicitly expressed, the GDPR refers to the UKGDPR pursuant to the Data Protection Act 2018, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019.

1.5.        This policy describes the personal data about you that we process and the legal basis for processing. It also describes your rights as a data subject.

 

2. About Us

2.1          “Green Signals” (and “we”, “us”, or “our”) refers to Green Signals Productions Ltd (company number 15186670) with registered office at Hazelmere House, 262 Lichfield Road, Sutton Coldfield, Birmingham, B74 2UH.

2.2          Green Signals is the controller of all personal data processed about you by us during the provision of our services to you.

 

3. Privacy Officer

Green Signal’s Privacy Officer is:

Richard Bowker
c/o Hazelmere House
262 Lichfield Road
Sutton Coldfield
Birmingham
B74 2UH
(email) info@greensignals.org

 

4. How we obtain your personal data

4.1          Any personal data that you provide to us by:

• speaking to us in person;
• filling in forms on our website https://www.greensignals.org
• corresponding with us by telephone;
• corresponding with us by email;
• corresponding with us via WhatsApp; and
• corresponding with us by letter.

4.2          Personal data obtained from sources other than you

• Any comments you make via any of the platforms on which our content is published including YouTube, Spotify, Apple Podcasts, any other podcast platform that you interact with and which our content is published via our RSS feed;
• Any information you provide to us in the course of your membership via YouTube and Patreon; and
• Any interaction you have with any other third party site we may use from time to time such as, but not limited to, Etsy, Eventbrite and Printful.

 

5. The personal data that we process about you

5.1          We process the following personal data about you:

• Title
• First name
• Last name
• Home address
• Home telephone number
• Email address

5.2          If you receive emails from us and interact with them we collect:

• Time you received the email;
• time you opened the email;
• device you used to open the email;
• geographical location when you opened the email; and
• which parts of the email you interacted with.

5.3          If you use social media accounts which are registered using the same email address you have provided to us elsewhere our systems enable us to link your social media accounts to your account and so we will process:

• Links to any social media accounts that you use.

 

6. Purpose for the processing

We process your personal data to provide you with any service you have requested such as Membership or merchandise and / or events purchases as well as to be able to interact with you as would normally be expected on a YouTube or Spotify (et al) podcast show / channel such as via comment or email.

 

7. Lawful basis for processing

7.1         We process your personal data to provide you with any services you have requested. The lawful basis for processing your personal data in such circumstances is that it is necessary for the performance of our contract with you.

7.2          We also process your personal information for a number of legitimate interests. This may include video footage which includes members of the general public and which is an integral part of the films we produce.

We have carried out a Legitimate Interest Assessment in this regard in which we carefully and proportionately balance:

• Respecting personal privacy and compliance with Data Protection Legislation including the General Data Protection Regulation (GDPR) and the Data Protection Act 2018 (DPA); and
• The fact that as a production company producing and publishing content that is both newsworthy and topical, we are producing content that is in the public interest.

7.3          Taking into account your interests, rights and freedoms, legitimate interests which allow us to process your personal data also include:

• to manage our relationship with you, our business and third parties who provide services for us;
• to keep our records up to date and to provide you with marketing as allowed by law;
• for statistical research and analysis so that we can monitor and improve products, services, websites and apps, or develop new ones;
• to enforce or apply our website terms of use, our policy terms and conditions or other contracts, or to protect our rights, property or safety;
• to exercise our rights, to defend ourselves from claims and to keep to laws and regulations that apply to us and the third parties we work with.

 

8. Sharing your personal data

8.1          We will or may share your personal data with:

• Third parties where you have provided your explicit consent to the sharing for a specific purpose or service;
• people or organisations we have to, or are allowed to, share your personal information with by law (for example, for fraud-prevention); and
• the police and other law-enforcement agencies to help them perform their duties, or with others if we have to do this by law or under a court order.

 

9. Processing of your personal data by organisations (Controllers) contracted with by Green Signals

9.1          Green Signals contracts with a small number of external organisations who are categorised as Data Controllers in their own right. These include, inter alia, YouTube, Patreon, Mailchimp and Microsoft. We have to adhere to the contract Terms and Conditions provided to us by such organisations and we are not able to affect any changes to those terms and conditions. However, an important part of those terms and conditions is that they oblige any such service provider or similar organisation to be as equally committed to the care and privacy of your personal data as we are.

 

10. Processing of your personal data by organisations (Processors) employed by Green Signals

10.1      Green Signals contracts with a small number of external organisations who are categorised as Data Processors and who provide us with specialist services. We only employ organisations that comply with data protection legislation and who are as committed to the care and privacy of your personal data as we are.

10.3      The following categories of processors are currently used by Green Signals. We reserve the right, at our absolute discretion, to amend this list from time to time:

Category of Processor	Service Provided
IT Service Providers	We employ third party service providers to help manage our IT infrastructure. These companies have administrator access to those systems to enable their continuous and effective operation.   We have contracts in place with them and can revoke their access if needs be.
Web Services	We employ a specialist third party provider to help us with managing our website.  We have contracts in place with them and can revoke their access if needs be.
Finance System Providers	We utilise third party providers for accounting and bookkeeping software as well as services to help manage our financial and management accounts.

 

11. Profiling and automated decision-making

We do not perform any profiling based on personal data that has a legal or significant effect. We do not perform any automated decision-making involving personal data.

 

12. International Transfers

12.1      We will neither transfer nor process personal data outside the United Kingdom, nor will we permit personal data to be transferred or processed outside the United Kingdom, unless it is under one or more of the following conditions:

• the entity with which we are working is widely recognised as a business that operates in multiple territories other than the UK and with which Green Signals is required to comply with their terms and conditions. These include YouTube, Patreon Inc, Mailchimp and Microsoft;
• the transfer is made under the unaltered terms of the standard contractual clauses issued by the European Commission for such purposes;
• the transfer is made under the provision of UK binding corporate rules;
• the transfer is made in accordance with one of the exceptions set out in Data Protection Legislation; and
• the transfer is made under International Data Transfer Agreement (IDTA) which is a contract that regulates and protects transfers of personal data between countries and / or the International Data Transfer Addendum (Addendum) which is an addendum to the new standard contractual clauses issued by the European Commission.

 

13. Marketing and preferences

13.1      We can only use your personal data to send you marketing material if we have your consent or a legitimate interest as described above.

13.2      If you consent (opt-in) to receiving marketing materials from us, you can remove that consent (opt-out) at any time by either, clicking on the ‘unsubscribe’ link that appears in all marketing emails we send. If you don’t want to receive texts from us you can tell us by contacting us at any time. Otherwise, you can always contact us to update your contact preferences.

 

14. Your Rights

14.1       You have the following rights concerning your personal data:

Right of access	You have the right to obtain confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to that personal data.
Right to rectification	You have the right to oblige us to rectify inaccurate personal data concerning you. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed by providing a supplementary statement.
Right to erasure (right to be forgotten)	You have the right (under certain circumstances, but not all) to oblige us to erase personal data concerning you.
Right to restriction of processing	You have the right (under certain circumstances, but not all) to oblige us to restrict processing of your personal data. For example, you may request this if you are contesting the accuracy of personal data held about you.
Right to data portability	You have the right (under certain circumstances, but not all) to oblige us to provide you with the personal data about you which you have provided in a structured, commonly used and machine-readable format.
Right to withdraw consent	If the lawful basis for processing is consent, you have the right to withdraw that consent.
Right to object to direct marketing	Where your personal data are processed for direct marketing purposes, you have the right to object at any time to processing of your personal data for marketing, which includes profiling to the extent that it is related to such direct marketing.
Rights in relation to automated decision making and profiling	We do not perform any automated decision-making based on personal data that produces legal effects or similarly significantly affects you.

 

14.2       Your right to lodge a complaint with a supervisory authority

If you wish to exercise any of your rights concerning your personal data, you should contact us at the address shown above. If you are not satisfied with the response you receive you have the right to lodge a complaint with the supervisory authority.

In the United Kingdom this is:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

(t) 0303 123 1113
(e) casework@ico.org.uk