Customer Privacy Policy
Rhea Projects is a company registered in England
Overview
Maintaining the security of the data is a priority at Rhea, and we are committed to respecting privacy rights. We pledge to handle the data fairly and legally at all times. Rhea is also dedicated to being transparent about what data we collect about you and how we use it.
This policy applies however customers engage with us and provides you with information about:
how we use your data;
what personal data we collect;
how we ensure your privacy is maintained; and
your legal rights relating to your personal data.
How we use your data
General
Rhea (and trusted partners acting on our behalf) use your personal data:
to provide goods and services to you;
to make a tailored website available to you;
to verify your identity;
for crime and fraud prevention, detection and related purposes;
to safeguard our colleagues, contractors and workers in our supply chain, including in relation to the risk of modern slavery and exploitation.
to contact you customers about promotional offers and products and services which we think may be of interest
for promotional and marketing purposes and to tailor and personalise products and services;
to train and manage our people and develop products and services;
for customer insight and market research purposes - to better understand customer needs;
to administer any competitions or prize draws customers enter;
to enable Rhea to manage customer service interactions
where we have a legal right or duty to use or disclose your information (for example in relation to an investigation by a public authority or in a legal dispute).
Rhea Customers
Promotional communications
Rhea use your personal data to send promotional messages by email, text and other electronic communication channels (with your consent) and may send you postal mail to update you on the latest scheme offers.
Rhea aims to update you about products & services which are of interest and relevance to individuals
Customers have the right to opt out of receiving promotional communications at any time, by:
changing marketing preferences
making use of the simple “unsubscribe” link in emails or the “STOP” number for texts; and/or
contacting Rhea via the contact channels set out in this Policy.
On-line activity
If customers contact Rhea on-line, we may collect data directly from them, as well as analysing browsing and purchasing activity, and responses to marketing communications. The results of this analysis, together with other demographic data, allows Rhea to ensure that we contact customers with information on products and offers that are relevant to them. To do so, we use software and other technology (automated processing).
Digital Advertising
If you visit our website, you may be served personalised advertisements for Rhea products and services whilst using other websites (including social media platforms). Any advertisements customers see will relate to products you have viewed whilst browsing our websites on your computer or other devices, or which we believe are of interest to customers.
These advertisements are provided by Rhea via our partners using ‘cookies’ and similar technologies placed on computers or other devices (see further information on the use of cookies in our Cookie Policy). You can reject all (non-essential) cookies at any time - see below for further information.
Protecting customers and colleagues and preventing crime
Rhea is committed to protecting its customers when they’re dealing with us. We will not tolerate abuse of colleagues or customers and we strive to prevent, deter and detect crime. We actively support the police and law enforcement agencies in taking robust action against offenders.
Our incident database
To achieve these purposes, it is necessary to collect personal data of customers and colleagues, including via CCTV cameras if appropriate. Where suspicious or criminal activity occurs, we will record this alongside footage, images and information about suspects or data. This personal data is used for the purposes of prevention and detection of crime and the apprehension and prosecution of offenders and, in particular, to:
undertake monitoring of offenders;
identify and disrupt the activity of organised criminal gangs and networks if there is potential for threats;
recover the value of goods stolen via legal proceedings; and/or
report offenders to the police and support prosecutions.
Sharing data with third parties
Our service providers and suppliers
In order to make certain services available we may need to share personal data with some of our service partners. These include IT, delivery and marketing service providers and fraud prevention and identification partners.
Rhea only allows its service providers to handle your personal data when we have confirmed that they apply appropriate data protection and security controls. We also impose contractual obligations on service providers relating to data protection and security, which mean they can only use your data to provide services to Rhea and for no other purposes.
Other third parties
Aside from our service providers, Rhea will not disclose your personal data to any third party, except as
set out below. We will never sell or rent our customer data to other organisations for marketing purposes.
We may share your data with:
our carefully selected partners who provide Rhea branded products and services for direct marketing purposes if we have your consent to do so;
credit reference agencies, banks and payment card issuers (such as Visa, Mastercard and American Express) for payment and related purposes if appropriate;
Third party marketing partners, including Google, Meta (which owns Facebook and Instagram) or TikTok to deliver advertising to customers if you are using Google or registered with one or more of those social media platforms (see further information on Social Media platforms and Search Engines below).
governmental bodies, regulators, police and other law enforcement agencies, courts/tribunals, professional advisers and insurers where we are required to do so:
to comply with our legal obligations;
to exercise our legal rights (for example in court cases);
for the prevention, detection, investigation of crime or prosecution of offenders; and
to safeguard and protect our employees, customers or other individuals.
Social Media Platforms and Search Engines: Facebook, Instagram, TikTok and Google
If you have an account with a Meta platform (such as Facebook or Instagram) or TikTok, or use Google, and accept cookies on our website, your personal data, including purchasing and browsing activity, will be shared with them. ‘Meta’ includes Meta Platforms, Inc (a US company) and other Meta Group companies. ‘TikTok’ includes TikTok Information Technologies UK Limited, in the UK, and TikTok Technology Limited, in Ireland. Google includes Google LLC (a US company) and Google Ireland Limited. This data is shared so the social media companies or search engines can serve tailored and personalised advertisements to you (including relevant Rhea products and services) when you are using their platforms and apps.
For certain data processing activities, Meta TikTok or Google will be acting as a data controller using data solely for their own purposes. In some circumstances, Meta and/or TikTok will be acting as joint data controller with Rhea.
Further information on how these organisations- handle your personal data, including the legal basis for data processing and how you can exercise your data subject rights against them, is set out in their Privacy Policies at the links below:
Meta | Privacy Centre | Manage your privacy on Facebook, Instagram and Messenger | Facebook Privacy.
TikTok Privacy Policy.
As required under data privacy laws, Rhea will enter into agreements with Meta and TikTok which determine the parties’ respective responsibilities for compliance with the obligations under the UK General Data Protection Regulation (UK GDPR) relating to the joint processing. These agreements are referred to as the Controller Addendum, for Meta and the Joint Controller Terms, for TikTok.
We have agreed that Rhea is responsible for providing data subjects with the information set out above, and that, Meta and / or TikTok respectively are responsible for enabling data subjects’ rights under Articles 15-20 of the UK GDPR with regard to the personal data stored by Meta and/or TikTok after the joint processing.
Mergers and Takeovers
If a separate business acquires all or part of our business or its assets, for example in the context of a merger or takeover, we may need to disclose your personal data to that company, so they can continue to provide services to you. In this situation, your data will only be used by the other business for the purposes set out in this Policy.
In certain circumstances, it is possible that your personal data could be transferred to a company with whom we’re discussing selling or transferring all or part of the Rhea business, but only where strictly necessary for the evaluation of the transaction. If this happens, the data will be kept secure and confidential and will be deleted if the business sale does not go ahead.
International transfers
To deliver products and services to customers, it may in the future be necessary for Rhea to transfer your data outside of the UK to jurisdictions which have less stringent data protection laws to protect personal data. This will typically occur if we use overseas service providers as business needs develop and digital work is increasingly carried out trans globally.
If this happens, we will ensure that the transfer will comply with data protection law and all personal data will be secure. Our standard practice is to use ‘standard contractual clauses’ which have been officially approved for such purposes.
How long do we keep your data?
We will not retain your data for longer than necessary for the purposes set out in this Policy. Different retention periods apply for different types of data, however the longest we will normally hold any personal data is 7 years.
What personal data do we collect?
Rhea may collect the following information about you:
your name, age/date of birth and gender;
your contact details: postal address including billing and delivery addresses, telephone numbers (including mobile numbers) and e-mail address;
purchases and orders made by you;
your on-line browsing activities on Rhea website;
your password(s) if the service develops individual accounts;
Pictures and other images and where appropriate information about property details
when you make a purchase or place an order with us, your payment card details;
your communication and marketing preferences if appropriate;
your interests, preferences, feedback and survey responses;
your location;
your correspondence and communications with Rhea; and
other publicly available personal data, including any which you have shared via a public platform (such as a Twitter feed or public Facebook page).
Our website is not intended for children, and we do not knowingly collect data relating to children.
This list is not exhaustive, and, in specific instances, we may need to collect additional data for the purposes set out in this Policy. This may include sensitive categories of personal data, as outlined in further in the section below entitled ‘Legal basis for using data’.
Some of the above personal data is collected directly, for example when you send an email to our customer services team. Other personal data is collected indirectly, for example your browsing activity. We may also collect personal data from third parties who have your consent to pass your details to us, or from publicly available sources.
Personal data we receive from third parties
Local Authority
The Local Authorities will share with us details of related to income and confirmation of Council Tax details.
How we protect your data
Our controls
Rhea is committed to keeping your personal data safe and secure.
Our security measures include Need Blue Rock to confirm this or reinforce with anything they write
encryption of data;
regular cyber security assessments of all service providers who may handle your personal data;
regular scenario planning and crisis management exercises to ensure we are ready to respond to cyber security attacks and data security incidents;
daily penetration testing of systems;
security controls which protect the entire Rhea IT infrastructure from external attack and unauthorised access; and
internal policies setting out our data security approach and training for employees.
What you can do to help protect your data
Rhea will never ask you to confirm or provide any passwords or bank account or credit card details via email. If customers receive an email claiming to be from Rhea asking you to do so, then they should ignore it and not respond.
If customers are using a computing device in a public location, we recommend that they always log out and close the website browser when they complete an online session.
In addition, we recommend that customers take the following security measures to enhance their online safety both in relation to Rheaand more generally:
keep passwords private. Remember, anybody who knows your password may access customer accounts;
when creating a password, use at least 8 characters. A combination of letters and numbers is best. Do not use dictionary words, name, email address, or other personal data that can be easily obtained. We also recommend that customers frequently change their password.
avoid using the same password for multiple online accounts.
Your rights
Customer data protection rights
Customers have the following rights:
The right to ask for a copy of personal data that Rhea hold about them
(the right of access);
The right to request that we delete personal data held on you
; where we no longer have a valid reason to retain it (the right of erasure or to be forgotten);
The right to ask us to update and correct any out-of-date or incorrect personal data that we hold about them
(the right of rectification);
The right to opt out of any marketing communications that we may send customers and to object to Rhea using / holding personal data if we have no legitimate reasons to do so
(the right to object);
The right (in certain circumstances) to ask us to 'restrict processing of data', which means that we would need to secure and retain the data for customer benefit but not otherwise use it (the right to restrict processing); and
The right (in certain circumstances) to ask us to supply customers with some of the personal data we hold about them in a structured machine-readable format and/or to provide a copy of the data in such a format to another organisation
(the right to data portability).
If customers wish to exercise any of the above rights, please contact us using the Rhea contact details.
Legal basis for using data
Rhea are required to set out the legal basis for our 'processing' of personal data.
General
Generally, Rhea collects and uses customers' personal data because it is necessary for:
the pursuit of our legitimate interests (as set out below);
the purposes of complying with our duties and exercising our rights under a contract for the sale of goods to a customer, in particular our contractors; or
complying with our legal obligations.
In general, we only rely on consent as a legal basis for processing personal data in relation to sending direct marketing communications to customers via email or text message.
Customers have the right to withdraw consent at any time. Where consent is the only legal basis for processing, we will cease to process data after consent is withdrawn.
Our legitimate interests
The main legal basis for processing customer data, is that it is necessary for the legitimate interests of Rhea, including:
contractors and Rhea selling and supplying goods and services to our customers;
protecting customers, employees and other individuals and maintaining their safety, health and welfare;
promoting, marketing and advertising our products and services;
sending promotional communications which are relevant and tailored to individual customers
understanding our customers' behaviour, activities, preferences, and needs;
improving existing products and services and developing new products and services;
complying with our legal and regulatory obligations;
preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies;
handling customer contacts, queries, complaints or disputes;
managing insurance claims;
protecting Rhea, its employees and customers, by taking appropriate legal action against third parties who have committed criminal acts, infringed our rights or failed to comply with legal duties owed to Rhea or others;
effectively handling any legal claims or regulatory investigations or enforcement actions taken against Rhea;
fulfilling our duties to our customers, colleagues, shareholders and other stakeholders; and
managing corporate transactions, including selling or transferring any parts of our business to third parties, acquiring new businesses, entering into mergers or undertaking corporate restructuring activity.
Sensitive types of information
In exceptional circumstances, Rhea may need to hold and/or use the following types of personal information about a customer:
race or ethnicity
political, religious or philosophical beliefs
trade union membership
health data
genetic or biometric data
sex life or sexual orientation
criminal convictions or criminal offences
These categories of personal data are subject to additional legal safeguards under data protection legislation, and Rhea are required to set out the legal basis for processing this data. The legal bases which we are likely to rely on, and which are set out in detail in applicable data protection laws, are that:
we have obtained consent (including explicit consent where required) for the processing and/or
the processing is necessary:
for preventing or detecting unlawful activities or protecting the public from dishonesty, malpractice and/or other improper actions
in connection with customer legal rights or duties relating to employment, social security, welfare or protection;
for legal disputes and claims;
for protecting the vital interests of individuals;
for assisting certain regulators; and/or
the personal data has been made public by the individual it relates to.
Data Protection Officer and DP Regulators
Our Data Protection Officer helps us to ensure we protect the personal data of our customers (and others) and comply with data protection legislation.
If you have any questions about how Rhea uses your personal data that are not answered here, or if you want to exercise your rights regarding your personal data, please contact our Data Protection Officer's team by:
Phone:
Email:
Data Protection Regulators
You have the right to lodge a complaint with the relevant data protection regulator, as follows:
For Residents: this is the Information Commissioner's Office. Further information, including contact details, is available at https://ico.org.uk
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