1.1. We are committed to safeguarding the privacy of our website visitors, service users, individual customers and customer personnel, suppliers and potential suppliers (and their personnel) and job applicants.
1.2. This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
1.3. In this policy, “we”, “us” and “our” refer to Environmental Social Governance Solutions Limited. For more information about us, see Section 12.
2.1. This document was created using a template from Docular ().
3. The personal data that we collect
3.1. In this Section 3 we have set out the general categories of personal data that we process.
3.2. We may process data enabling us to get in touch with you (““). The contact data may include your name, email address, telephone number, postal address and/or social media account identifiers. The source of the contact data is you and/or your employer.
3.3. We may process information contained in or relating to any communication that you send to us or that we send to you (““). The communication data may include the communication content and metadata associated with the communication.
3.4. We may process data about your use of our website and services (““). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system.
4. Purposes of processing and legal bases
4.1. In this Section 4, we have set out the purposes for which we may process personal data and the legal bases of the processing.
4.2. Operations– We may process your personal data for the purposes of operating our website, the processing and fulfilment of orders, providing our services, supplying our goods, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business.
4.3. Relationships and communications – We may process contact data, account data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, fax and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, individual customers and customer personnel, the maintenance of relationships, and the proper administration of our website, services and business.
4.4. Research and analysis– We may process usage data and/or transaction data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.
4.5. Record keeping– We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
4.6. Security– We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.
4.7. I – We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
4.8. Legal claims – We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
4.9. Legal compliance and vital interests – We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
4.10. Direct marketing – We may process contact data for the purposes of creating, targeting and sending direct marketing communications by email, SMS, post and making contact by telephone for marketing-related purposes (including sending our newsletter). The legal basis for this processing is our legitimate interests, namely promoting our business and communicating marketing messages and offers to our website visitors and service users (with the exception of our newsletter for which the legal basis is consent).
5. Providing your personal data to others
5.1. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks or obtaining professional advice.
5.2. Your personal data will be stored on the servers of our hosting service providers including Microsoft. We also use Mailchimp to send our newsletter and other marketing communications.
5.3. We may disclose contact data to our other suppliers or subcontractors insofar as reasonably necessary for the provision of our services.
5.4. In addition to the specific disclosures of personal data set out in this Section 5, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
6. International transfers of your personal data
6.1. In this Section 6, we provide information about the circumstances in which your personal data may be transferred to a third country under UK and/or EU data protection law.
6.2. We may transfer your personal data from the European Economic Area (EEA) to the UK and process that personal data in the UK for the purposes set out in this policy, and may permit our suppliers and subcontractors to do so, during any period with respect to which the UK is not treated as a third country under EU data protection law or benefits from an adequacy decision under EU data protection law; and we may transfer your personal data from the UK to the EEA and process that personal data in the EEA for the purposes set out in this policy, and may permit our suppliers and subcontractors to do so, during any period with respect to which EEA states are not treated as third countries under UK data protection law or benefit from adequacy regulations under UK data protection law.
6.3. Like most businesses we use software to support our operations. For example, we use Microsoft as our email provider and Mailchimp to send our newsletters. Your personal data may therefore be transferred out of the UK and EEA as Microsoft and Mailchimp as well as other players in the software industry store some of their data in the USA.
6.4. Whenever we transfer your personal data out of the UK and EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
a. 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.
b. 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.
7. Retaining and deleting personal data
7.1. This Section 7 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
7.2. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
7.3. Notwithstanding the other provisions of this Section 7, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
8.1. 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.
8.2. 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.
9. Your rights
9.1. In this Section 9, we have listed the rights that you have under data protection law.
9.2. Your principal rights under data protection law are:
a. – you can ask for copies of your personal data;
b. – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
c. – you can ask us to erase your personal data;
d. – you can ask us to restrict the processing of your personal data;
e. – you can object to the processing of your personal data;
f. – you can ask that we transfer your personal data to another organisation or to you;
g. – you can complain about our processing of your personal data; and
h. – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
9.4. You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.
10. About cookies
10.1. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
10.2. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
10.3. Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
11.1. We may update this policy from time to time by publishing a new version on our website.
11.2. You should check this page occasionally to ensure you are happy with any changes to this policy.
11.3. We may notify you of significant changes to this policy by email.
12. Our details
12.1. This website is owned and operated by Environmental Social Governance Solutions Limited.
12.2. We are registered in England and Wales under registration number 07411930, and our registered office is at Office 2, Tweed House, Park Lane, Swanley, Kent, BR8 8DT, United Kingdom.
12.3. You can contact us:
a. by post, to the postal address given above;
b. using our website contact form;
c. by telephone, on the contact number published on our website; or
d. by email, using the email address published on our website.