policy

Policies

Privacy Statement

This is the Privacy Statement of D4H in relation to data collected and processed by D4H on its own behalf acting as a Data Controller in the provision of its Services such as this marketing website. This does not apply to Personal Data in our software where the Customer is the Data Controller which is covered by our individual service agreements with customers.

(A) This Policy

This policy explains how we process personal data and is issuedby each of the Controller and Processor entities which are part of the group ofcompanies headed by EcoOnline AS (“Group Companies” as defined at Section R)(together, “EcoOnline”, “we”, “us” and “our”) andis addressed to individuals outside our organisation with whom we interact,including visitors to our Sites, users of our Applications (Section R), otherusers of our services, personnel of corporate customers and vendors, applicantsfor employment and visitors to our premises (together, “you”). Someinteractions on our Sites may be supported by automated or AI-assistedtechnologies designed to improve response times and user experience. In somecases responses may be generated or assisted by automated systems. Definedterms used in this policy are explained in Section R below.

This policy may be amended or updated from time to time toreflect changes in our practices with respect to the Processing of PersonalData, or changes in applicable law. We encourage you to read this policycarefully, and to regularly check this page to review any changes we might makein accordance with the terms of this policy.

(B) Collection of Personal Data

We collect or obtain Personal Data: when data is provided to us(e.g., where you contact us); in the course of our relationship with you (e.g.,if you make a purchase); when you make Personal Data public (e.g., if you makea public post about us on social media); when you download, install, or use anyof our Apps; when you visit our Sites; when you register to use any of ourSites, Apps, or services; or when you interact with any third-party content oradvertising on a Site. We may also receive Personal Data about you from thirdparties (e.g., law enforcement authorities, screening providers, businesspartners). If you choose not to provide certain personal information, wemay be unable to respond to your request or provide our services to you.

EcoOnline as Data Controller

Collection of Personal Data: We collect or obtain Personal Dataabout you from the following sources:

Data provided to us:

We obtain Personal Data when data is provided to us (e.g.,where you contact us via email or telephone, or by any other means, or when youprovide us with your business card, or when you submit a jobapplication).

In some circumstances, we may collect personal informationabout you from third parties (rather than directly from you). This may include,for example, where your details are provided to us by a partner, reseller,employer, or another organisation.

Where we collect your personal information in this way, we willtake reasonable steps to ensure you are informed, including:

that we have collected your information;
the purpose for which we have collected it;
the types of organisations or persons we may share it with;
the identity and contact details of EcoOnline as the organisation collecting and holding your information; and
your rights to request access to, or correction of, your personal information.

Data we obtain in person:

We obtain Personal Data during meetings, at trade shows, duringvisits from sales or marketing representatives, or at events we attend.

Collaborations:

We obtain Personal Data when you collaborate with us inresearch or in an advisory/consultancy capacity.

Relationship data:

We collect or obtain Personal Data in the ordinary course ofour relationship with you (e.g., we provide a service to you, or to youremployer).

Data you make public:

We collect or obtain Personal Data that you manifestly chooseto make public, including via social media (e.g., we may collect informationfrom your social media profile(s), if you make a public post about us).

App data:

We collect or obtain Personal Data when you download or use anyof our Apps.

Site data:

We collect or obtain Personal Data when you visit any of ourSites or use any features or resources available on or through a Site.

Website chat and conversational interaction data:

We collect or obtain Personal Data when you interact with chator AI-assisted messaging tools made available on or through our Sites. This mayinclude information you voluntarily provide during the interaction, such asyour name, email address, company information, and the content of messagesexchanged during the conversation.

In some cases we may combine this information with dataobtained from third-party sources or publicly available business information inorder to better understand organisations visiting our website and personaliseinteractions.

Where you provide contact details during a chat interaction, wemay use those details to respond to your enquiry, provide requestedinformation, and follow up on your request in accordance with this policy.Conversations may be recorded or stored for quality assurance, training,service improvement, and to help us respond to enquiries.

Registration details:

We collect or obtain Personal Data when you use, or register touse, any of our Sites, Apps, or services.

Content and advertising information

If you interact with any third-party content or advertising ona Site (including third-party plugins and cookies) we receive Personal Datafrom the relevant third-party provider of that content or advertising.

Third-party information:

We collect or obtain Personal Data from third parties whoprovide it to us (e.g., law enforcement authorities; screening providers,business partners).

EcoOnline as Data Processor

Collection of Personal Data: We collect or obtain Personal Dataabout you from the following sources:

Registration details:

We collect or obtain Personal Data when you use, or register touse, any of our Sites, Apps, or services.

App data:

We collect or obtain Personal Data when you download or use anyof our products and applications.

Site data:

We collect or obtain Personal Data when you visit any of ourSites or use any features or resources available on or through a Site.

(C) Creation of Personal Data

We create Personal Data about you (e.g., records of yourinteractions with us).

We also create Personal Data about you in certaincircumstances, such as details of your past interactions with us. We may alsocombine Personal Data from any of our Sites, Apps, or services, including wherethat data is collected from different devices.

(D) Categories of Personal Data we Process

We Process: your personal details (e.g., your name);demographic data (e.g., your age); your contact details (e.g., your address);records of your consents; purchase details; payment details (e.g., your billingaddress); information about our Sites and Apps (e.g., the type of device youare using); details of your employer (where relevant); information about yourinteractions with our content or advertising; and any views or opinions youprovide to us.

EcoOnline as Data Controller

We may Process the following categories of Personal Data aboutyou:

Personal details: given name(s); preferred name; and photograph.
Demographic information: gender; date of birth / age; nationality; salutation; title; and language preferences.
Contact details: correspondence address; shipping address; telephone number; email address; details of Personal Assistants, where applicable; messenger app details; online messaging details; and social media details.
Expertise: records of your expertise, professional history, practising details and qualification details, information about your experience, participation in meetings, seminars, advisory boards and conferences, information about your professional relationship with other individuals or institutions, language abilities and other professional skills;
Consent records: records of any consents you have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent).
Purchase details: records of purchases and prices; consignee name, address, contact telephone number and email address;
Payment details: invoice records; payment records; billing address; payment method; bank account number or credit card number; cardholder or account holder name; card or account security details; card ‘valid from’ date; card expiry date; BACS details; SWIFT details; IBAN details; payment amount; payment date; and records of cheques.
Data relating to our Sites and Apps: device type; operating system; browser type; browser settings; IP address; language settings; dates and times of connecting to a Site; App usage statistics; App settings; dates and times of connecting to an App; location data, and other technical communications information (some of which may constitute Personal Data); username; password; security login details; usage data; aggregate statistical information.
Employer details: where you interact with us in your capacity as an employee of a third-party, the name, address, telephone number and email address of your employer, to the extent relevant.
Content and advertising data: records of your interactions with our online advertising and content, records of advertising and content displayed on pages displayed to you, and any interaction you may have had with such content or advertising (e.g., mouse hover, mouse clicks, any forms you complete in whole or in part) and any touchscreen interactions.
Chat and conversation data: records of conversations and interactions with our website chat, messaging, support, or AI-assisted tools, including the content of messages, contact details shared during the interaction, and associated follow-up records.
Organisation and enrichment data: information relating to the organisation you represent or may be associated with, such as company name, industry, approximate location, or other business information obtained from publicly available sources or third-party data providers.
Views and opinions: any views and opinions that you choose to send to us, or publicly post about us on social media platforms.

EcoOnline as Data Processor

The category of Personal Data we may Process about you willdepend upon the nature of your interaction with us. It may include any of thefollowing:

Name, email address, address, phone number, personnel number,age, office location, company/department, job title, overview of personnelactions regarding registered incidents, workplace accidents and illnesses, IPaddress, device type, OS version, app version, usage history, metadata, SSN (ifexposure module is used), contract data, connection data, grades and evaluationreports, text, audio, video, or image files, metadata, uploaded documentation,certificates.

(E) Sensitive Personal Data

As a Data Controller, EcoOnline Processes Sensitive PersonalData in a very limited number of situations, most typically in relation to ourAnti-Bribery and Corruption, and Trade Controls screening procedures. Ourscreening activities might reveal information about our corporate clients’executives’ and people in management or board positions’ criminal records(e.g., if they have been put on international sanctions lists or have beenmentioned by the press).

As a Data Processor, EcoOnline Processes Sensitive PersonalData also only in a very limited number of situations, typically in relation toparticular modules within our EHS offering.

In general, where we need to Process Sensitive Personal Datafor a legitimate purpose, we do so in accordance with applicable law.

As a Data Processor, we generally only Process SensitivePersonal Data in relation to particular modules of our EHS offering. As a DataController, and where it becomes necessary to Process your Sensitive PersonalData for any reason, we rely on one of the following legal bases:

Compliance with applicable law: We may Process your Sensitive Personal Data where the Processing is required or permitted by applicable law (e.g., to comply with our diversity reporting obligations);
Detection and prevention of crime: We may Process your Sensitive Personal Data where the Processing is necessary for the detection or prevention of crime (e.g., the prevention of fraud);
Establishment, exercise or defence of legal claims: We may Process your Sensitive Personal Data where the Processing is necessary for the establishment, exercise or defence of legal claims; or
Consent: We may Process your Sensitive Personal Data where we have, in accordance with applicable law, obtained your express consent prior to Processing your Sensitive Personal Data (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

If you provide Sensitive Personal Data to us, you must ensurethat it is lawful for you to disclose such data to us, and you must ensure avalid legal basis applies to the Processing of that Sensitive PersonalData.

(F) Purposes of Processing and legal bases forProcessing

Summary – Purposes of Processing and legal bases for Processing

We Process Personal Data for the following purposes: providingour Sites, Apps, and services to you; compliance checks; operating ourbusiness; communicating with you; managing our IT systems; health and safety;financial management; conducting surveys; ensuring the security of our premisesand systems; conducting investigations where necessary; compliance withapplicable law; improving our Sites, Apps, and services; fraud prevention;establishment, exercise and defence of legal claims; and recruitment and jobapplications.

EcoOnline as Data Controller

The purposes for which we Process Personal Data, subject toapplicable law, and the legal bases on which we perform such Processing, are asfollows:

Processing Activity

Legal basis for Processing

Provision of Sites, Apps, and services: providing our Sites, Apps,or services; providing promotional items upon request; and communicating withyou in relation to those Sites, Apps, or services.

The Processing is necessary in connection with anycontract that you have entered into with us, or to take steps prior toentering into a contract with us; or · We have alegitimate interest in carrying out the Processing for the purpose ofproviding our Sites, Apps, or services (to the extent that such legitimateinterest is not overridden by your interests, fundamental rights, or freedoms);or · We have obtained your prior consent to theProcessing (this legal basis is only used in relation to Processing that isentirely voluntary – it is not used for Processing that is necessary orobligatory in any way).

Operating our business: operating andmanaging our Sites, our Apps, and our services; providing content to you;displaying advertising and other information to you; communicating andinteracting with you via our Sites, our Apps, or our services; and notifyingyou of changes to any of our Sites, our Apps, or our services.

The Processing is necessary in connection with anycontract that you have entered into with us, or to take steps prior toentering into a contract with us; or

·We have a legitimate interest in carrying outthe Processing for the purpose of providing our Sites, our Apps, or ourservices to you (to the extent that such legitimate interest is not overriddenby your interests, fundamental rights, or freedoms); or

·We have obtained your prior consent to theProcessing (this legal basis is only used in relation to Processing that isentirely voluntary – it is not used for Processing that is necessary orobligatory in any way).

Improving our Sites, Apps, and services: identifying issueswith our Sites, our Apps, or our services; planning improvements to our Sites,our Apps, or our services; and creating new Sites, our Apps, or services.

We have a legitimate interest in carrying outthe Processing for the purpose of improving our Sites, our Apps, or ourservices (to the extent that such legitimate interest is not overridden by yourinterests, fundamental rights, or freedoms); or

We have obtained your prior consent to theProcessing (this legal basis is only used in relation to Processing that isentirely voluntary – it is not used for Processing that is necessary orobligatory in any way).

Communications and marketing: communicating with you viaany means (including via email, telephone, text message, social media, post orin person) to provide news items and other information in which you may beinterested, subject always to obtaining your prior opt-in consent to the extentrequired under applicable law; maintaining and updating your contactinformation where appropriate; and obtaining your prior, opt-in consent whererequired.

The Processing is necessary in connection with any contractthat you have entered into with us, or to take steps prior to entering into acontract with us; or

We have a legitimate interest in carrying out the Processingfor the purpose of contacting you, subject always to compliance with applicablelaw (to the extent that such legitimate interest is not overridden by yourinterests, fundamental rights, or freedoms); or

We have obtained your prior consent to the Processing (thislegal basis is only used in relation to Processing that is entirely voluntary –it is not used for Processing that is necessary or obligatory in any way).

Website chat, conversational support, and enquiryhandling:providing chat functionality on our Sites; responding to enquiries submittedthrough chat or AI-assisted messaging tools; storing and reviewingconversations for quality assurance, training, service improvement, and servicecontinuity; and using contact details provided during such interactions tofollow up on requests, provide requested information, and send relevantinformation about our products or services in accordance with applicable lawand your marketing preferences.

The Processing is necessary to take steps prior to enteringinto a contract with you; or
We have a legitimate interest in carrying out the Processing for the purpose ofoperating and improving our Sites, handling enquiries, and communicating withyou effectively (to the extent that such legitimate interest is not overriddenby your interests, fundamental rights, or freedoms); or
We have obtained your prior consent to the Processing where required byapplicable law. We may also use organisational or enrichment informationobtained from third-party sources to personalise website interactions andprovide more relevant information about our services.

Management of IT systems: management andoperation of our communications, IT and security systems; and audits (includingsecurity audits) and monitoring of such systems.

The Processing is necessary for compliance with a legalobligation; or

We have a legitimate interest in carrying outthe Processing for the purpose of managing and maintaining our communicationsand IT systems (to the extent that such legitimate interest is not overriddenby your interests, fundamental rights, or freedoms).

Health and safety: health and safetyassessments and record keeping; providing a safe and secure environment at ourpremises; and compliance with related legal obligations.

The Processing is necessary for compliance with a legalobligation; or

We have a legitimate interest in carrying outthe Processing for the purpose of ensuring a safe environment at our premises(to the extent that such legitimate interest is not overridden by yourinterests, fundamental rights, or freedoms); or

The Processing is necessary to protect the vitalinterests of any individual.

Financial management: sales; finance;corporate audit; and vendor management.

We have a legitimate interest in carrying outthe Processing for the purpose of managing and operating the financial affairsof our business (to the extent that such legitimate interest is not overriddenby your interests, fundamental rights, or freedoms); or

Surveys: engaging with you for the purposes ofobtaining your views on our Sites, our Apps, or our services.

We have a legitimate interest in carrying outthe Processing for the purpose of conducting surveys, satisfaction reports andmarket research (to the extent that such legitimate interest is not overriddenby your interests, fundamental rights, or freedoms); or

Security: physical security of our premises (includingrecords of visits to our premises); CCTV recordings; and electronic security(including login records and access details).

The Processing is necessary for compliance with a legalobligation; or

We have a legitimate interest in carrying outthe Processing for the purpose of ensuring the physical and electronic securityof our business and our premises (to the extent that such legitimate interestis not overridden by your interests, fundamental rights, or freedoms).

Recruitment and job applications: recruitment activities;advertising of positions; interview activities; analysis of suitability for therelevant position; records of hiring decisions; offer details; and acceptancedetails.

The Processing is necessary for compliance with a legalobligation (especially in respect of applicable employment law); or

We have a legitimate interest in carrying outthe Processing for the purpose of recruitment activities and handling jobapplications (to the extent that such legitimate interest is not overridden byyour interests, fundamental rights, or freedoms); or

Investigations: detecting, investigating andpreventing breaches of policy, and criminal offences, in accordance withapplicable law.

The Processing is necessary for compliance with a legalobligation; or

We have a legitimate interest in carrying outthe Processing for the purpose of detecting, and protecting against, breachesof our policies and applicable laws (to the extent that such legitimateinterest is not overridden by your interests, fundamental rights, or freedoms).

Legal compliance: compliance with our legal andregulatory obligations under applicable law

The Processing is necessary for compliance with a legalobligation.

Compliance checks: confirming and verifyingyour identity; and screening against government and/or law enforcement agencysanctions lists and other legal restrictions.

We have a legitimate interest in carrying outthe Processing for the purpose of fulfilling our regulatory and complianceobligations and to ensure our counterparties are within acceptable risk (to theextent that such legitimate interest is not overridden by your interests, fundamentalrights, or freedoms).

Fraud prevention: Detecting, preventing andinvestigating fraud.

The Processing is necessary for compliance with a legalobligation (especially in respect of applicable employment law); or

We have a legitimate interest in carrying outthe Processing for the purpose of detecting, and protecting against, fraud (tothe extent that such legitimate interest is not overridden by your interests,fundamental rights, or freedoms).

Establishment, exercise and defence of legalclaims: managementof legal claims; establishment of facts and claims, including collection,review and production of documents, facts, evidence and witness statements;exercise and defence of legal rights and claims, including formal legalproceedings.

The Processing is necessary for compliance with a legalobligation;

We have a legitimate interest in carrying outthe Processing for the purpose of establishing, exercising or defending ourlegal rights (to the extent that such legitimate interest is not overridden byyour interests, fundamental rights, or freedoms); or

The Processing is necessary for the establishment,exercise or defence of legal claims.

Improving sales and marketing activities: record conversations withsuspects, prospects, and clients.

EcoOnline as Data Processor

EcoOnline as Data Processor does not have its own legal basisfor processing personal data in the provision of products and services to ourclients (the Data Controllers). For the provision of products and services toour clients, we process the personal data only on the documented instructionsof the relevant client.

(G) Disclosure of Personal Data to third parties

Summary – Disclosure of Personal Data to third parties

We disclose Personal Data to: legal and regulatory authorities;our external advisors; our Processors; any party as necessary in connectionwith legal proceedings; any party as necessary for investigating, detecting orpreventing criminal offences; any purchaser of our business; and anythird-party providers of advertising, plugins or content used on our Sites orour Apps.

We disclose Personal Data to other entities within theEcoOnline group, for legitimate business purposes and the operation of ourSites, Apps, or services to you, in accordance with applicable law.

In addition, EcoOnline may also disclose personal data to:

you and, where appropriate, your appointed representatives;
legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;
accountants, auditors, consultants, lawyers and other outside professional advisors to EcoOnline, subject to binding contractual obligations of confidentiality;
any relevant party, regulatory body, governmental authority, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal claims;
any relevant party, regulatory body, governmental authority, law enforcement agency or court, for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties; and
any relevant third-party acquirer(s) or successor(s) in title, in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation).

If we engage a third-party Processor to Process your PersonalData, the Processor will be subject to binding contractual obligations to: (i)only Process the Personal Data in accordance with our prior writteninstructions; and (ii) use measures to protect the confidentiality and securityof the Personal Data; together with any additional requirements underapplicable law.

We may also share Personal Data with trusted third-partyservice providers that support website functionality, hosting, analytics,customer communications, marketing operations, embedded content, andaccount-based marketing activities. These providers process Personal Data onour behalf and are required by contract to protect it and use it only inaccordance with applicable data protection laws and our instructions.

Please find the list of Processors and Subprocessors engaged byEcoOnline here: Sub-processors | EcoOnline.

In some cases, we may share information with authorisedpartners who assist us in responding to enquiries or providing our services,including local partners who may contact you in relation to your enquiry. Wherethis occurs, those partners may receive your information from us rather thandirectly from you.

(H) Profiling

We do not carry out automated decision-making that produceslegal or similarly significant effects. However, we may use limited profilingor analytics (for example, to personalise website interactions orcommunications), in accordance with applicable law.

(I) International transfer of Personal Data

We transfer Personal Data to recipients in other countries.Where we transfer Personal Data from the United Kingdom and/or the EEA to arecipient outside the United Kingdom/EEA that is not in an AdequateJurisdiction, we do so on the basis of an International Data Transfer Agreementor Standard Contractual Clauses.

Because of the international nature of our business, wetransfer Personal Data within the EcoOnline group, and to third parties asnoted in Section (G) above, in connection with the purposes set out in thispolicy. For this reason, we transfer Personal Data to other countries that mayhave different laws and data protection compliance requirements to those thatapply in the country in which you are located.

If an exemption or derogation applies (e.g., where a transferis necessary to establish, exercise or defend a legal claim) we may rely onthat exemption or derogation, as appropriate. Where no exemption or derogationapplies, and we transfer your Personal Data from the United Kingdom or the EEAto recipients located outside the United Kingdom/EEA who are not in AdequateJurisdictions, we do so on the basis of an International Data TransferAgreement or Standard Contractual Clauses. You are entitled to request a copyof our International Data Transfer Agreement and Standard Contractual Clausesusing the contact details provided in Section (Q) below.

Please note that when you transfer any Personal Data directlyto an EcoOnline entity established outside the United Kingdom and the EEA, weare not responsible for that transfer of your Personal Data. We willnevertheless Process your Personal Data, from the point at which we receivethose data, in accordance with the provisions of this policy.

(J) Data security

We implement appropriate technical and organizational securitymeasures to protect your Personal Data. Please ensure that any Personal Datathat you send to us is sent securely.

We have implemented appropriate technical and organizationalsecurity measures designed to protect your Personal Data against accidental orunlawful destruction, loss, alteration, unauthorized disclosure, unauthorizedaccess, and other unlawful or unauthorized forms of Processing, in accordancewith applicable law.

Because the internet is an open system, the transmission ofinformation via the internet is not completely secure. Although we willimplement all reasonable measures to protect your Personal Data, we cannotguarantee the security of your data transmitted to us using the internet – anysuch transmission is at your own risk, and you are responsible for ensuringthat any Personal Data that you send to us is sent securely. Personal Data thatyou send to us is sent securely.

(K) Data accuracy

We take every reasonable step to ensure that your Personal Datais kept accurate and up-to-date and is erased or rectified if we become awareof inaccuracies.

We take every reasonable step to ensure that:

your Personal Data that we Process is accurate and, where necessary, kept up to date; and
any of your Personal Data that we Process that is inaccurate (having regard to the purposes for which it is Processed) is erased or rectified without delay.

From time to time, we may ask you to confirm the accuracy ofyour Personal Data.

As a Data Processor, we support our clients in updatingpersonal data in our systems and applications when requested either manuallyor, where possible, through automated means such as synchronization.

(L) Data minimization

We take every reasonable step to limit the volume of yourPersonal Data that we Process to what is necessary.

We take every reasonable step to ensure that your Personal Datathat we Process is limited to the Personal Data reasonably necessary inconnection with the purposes set out in this policy.

(M) Data retention

We retain personal data only for as long as necessary for thepurposes described in this policy, unless a longer retention period is requiredor permitted by law.

We take every reasonable step to ensure that your Personal Datais only Processed for the minimum period necessary for the purposes set out inthis policy. The criteria for determining the duration for which we will retainyour Personal Data is as follows:

1) we will retain Personal Data in a form thatpermits identification only for as long as:

your Personal Data is necessary in connection with the lawful purposes set out in this policy, for which we have a valid legal basis (e.g., where your personal data is included in a contract between us and your employer, and we have a legitimate interest in processing that data for the purposes of operating our business and fulfilling our obligations under that contract; or where we have a legal obligation to retain your Personal Data),
we maintain an ongoing relationship with you (e.g., where you are a user of our services, or you are lawfully included in our mailing list and have not unsubscribed); or

Plus:

2) the duration of:

any applicable limitation period under applicable law (i.e., any period during which any person could bring a legal claim against us in connection with your Personal Data, or to which your Personal Data is relevant); and
an additional twelve (12) month period following the end of such applicable limitation period (so that, if a person brings a claim at the end of the limitation period, we are still afforded a reasonable amount of time in which to identify any Personal Data that is relevant to that claim),

and:

2) in addition, if any relevant legal claims arebrought, we continue to Process Personal Data for such additional periods asare necessary in connection with that claim.

During the periods noted in paragraphs (2)(a) and (2)(b) above,we will restrict our Processing of your Personal Data to storage of, andmaintaining the security of, that data, except to the extent that that dataneeds to be reviewed in connection with any legal claim, or any obligationunder applicable law.

Once the periods in paragraphs (1), (2) and (3) above, each tothe extent applicable, have concluded, we will either:

permanently delete or destroy the relevant Personal Data; or
anonymize the relevant Personal Data.

(N) Your legal rights

Subject to applicable law, you may have a number of rights,including: the right not to provide your Personal Data to us; the right ofaccess to your Personal Data; the right to request rectification ofinaccuracies; the right to request the erasure, or restriction of Processing,of your Personal Data; the right to object to the Processing of your PersonalData; the right to have your Personal Data transferred to another Controller;the right to withdraw consent; and the right to lodge complaints with Data ProtectionAuthorities. In some cases it will be necessary to provide evidence of youridentity before we can give effect to these rights.

Subject to applicable law, you may have the following rightsregarding the Processing of your Relevant Personal Data:

the right not to provide your Personal Data to us (however, please note that we will be unable to provide you with the full benefit of our Sites, Apps, or services, if you do not provide us with your Personal Data – e.g., we might not be able to process your requests without the necessary details);
the right to request access to, or copies of, your Relevant Personal Data, together with information regarding the nature, Processing and disclosure of that Relevant Personal Data;
the right to request rectification of any inaccuracies in your Relevant Personal Data;
the right to request, on legitimate grounds:
- erasure of your Relevant Personal Data; or
- restriction of Processing of your Relevant Personal Data;
the right to have certain Relevant Personal Data transferred to another Controller, in a structured, commonly used and machine-readable format, to the extent applicable;
where we Process your Relevant Personal Data on the basis of your consent, the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the Processing of your Personal Data in reliance upon any other available legal bases); and
the right to lodge complaints regarding the Processing of your Relevant Personal Data with a Data Protection Authority (in particular, the Information Commissioner’s Office in the United Kingdom and the Data Protection Authority of the EU Member State in which you live, or in which you work, or in which the alleged infringement occurred, each if applicable).

Subject to applicable law, you may also have the followingadditional rights regarding the Processing of your Relevant Personal Data:

the right to object, on grounds relating to your particular situation, to the Processing of your Relevant Personal Data by us or on our behalf, where such processing is based on Articles 6(1)(e) (public interest) or 6(1)(f) (legitimate interests) of the GDPR; and
the right to object to the Processing of your Relevant Personal Data by us or on our behalf for direct marketing purposes.

This does not affect your statutory rights.

To exercise one or more of these rights, or to ask a questionabout these rights or any other provision of this Notice, or about ourProcessing of your Personal Data, please use the contact details provided inSection (Q) below. Please note that:

in some cases it will be necessary to provide evidence of your identity before we can give effect to these rights; and
where your request requires the establishment of additional facts (e.g., a determination of whether any Processing is non-compliant with applicable law) we will investigate your request reasonably promptly, before deciding what action to take.

Additional rights for US residents
If you are a resident of certain US states, you may have additional rightsunder applicable law, including:

the right to request disclosure of categories and sources of personal information we collect;
the right to request deletion of personal information;
the right to opt out of the sale or sharing of personal information (we do not sell personal information in the traditional sense, however, certain sharing for advertising or analytics purposes may be considered ‘sharing’ under applicable law);
the right to limit the use of certain sensitive personal information, where applicable; and
the right not to be discriminated against for exercising your rights.

(O) Cookies and similar technologies

We Process Personal Data by using Cookies and similartechnologies. For more information, please see our Cookie Policy.

We use cookies and similar technologies to support websitefunctionality, analyse usage of our Sites, improve user experience, measure theeffectiveness of our content and communications, and help us understandengagement from visitors and organisations interested in our services. This mayinclude the use of analytics tools, embedded content providers, andaccount-based marketing technologies, subject to obtaining your consent whererequired under applicable law. Where required, we will obtain your consent beforeplacing non-essential cookies or similar technologies on your device.

Some technologies may allow us to understand engagement fromorganisations visiting our Sites or combine website interaction data withbusiness information obtained from third-party providers in order to improvethe relevance of content and communications.

When you visit a Site we will typically place Cookies onto yourdevice, or read Cookies already on your device, subject always to obtainingyour consent, where required, in accordance with applicable law. We use Cookiesto record information about your device, your browser and, in some cases, yourpreferences and browsing habits. We Process Personal Data through Cookies andsimilar technologies, in accordance with our Cookie Policy here: Cookie Policy | EcoOnline.

(P) Direct marketing

We Process Personal Data to contact you with informationregarding Sites, Apps, or services that may be of interest to you. You mayunsubscribe for free at any time.

We Process Personal Data to contact you via email, telephone,direct mail, or other communication formats to provide you with informationregarding Sites, Apps, or services that may be of interest to you.

We also Process Personal Data for the purposes of displayingcontent tailored to your use of our Sites, Apps, or services. This may includeusing information collected through website forms, chat interactions,cookie-based technologies, or account-based marketing tools to better tailorcommunications and content, subject always to applicable law and consentrequirements where relevant.

If we provide Sites, Apps, or services to you, we may send ordisplay information to you regarding our Sites, Apps, or services, upcomingpromotions and other information that may be of interest to you, including byusing the contact details that you have provided to us, or any otherappropriate means, subject always to obtaining your prior opt-in consent to theextent required under applicable law.

You may unsubscribe from our promotional email list at any timeby simply clicking on the unsubscribe link included in every promotionalelectronic communication we send. Please note that it may take up to 2 weeks toprocess your unsubscribe request during which time you may continue to receivecommunications from us. After you unsubscribe, we will not send you furtherpromotional emails, but in some circumstances, we will continue to contact youto the extent necessary for the purposes of any Sites, Apps, or services youhave requested.

(Q) Contact Details

In relation to any queries arising out of this privacy policy,please contact EcoOnline’s Data Protection Officer: dpo@ecoonline.com.

(R) Definitions

“App/Applications” means any application made available by us (including where we make such applications available via third-party stores or marketplaces, or by any other means), including:

Applications / Developers

Almego, InCaseIT, Biome, Chemical Manager, Crisis Management,Ecometrica, eCompliance, Environment Health & Safety (EHS), ePermits,FieldID, Info Exchange (IEX), Klara, Learning Manager, Mango, Munio, SafetyIntelligence, Simple Compliance, StaySafe, Sypol.

“Adequate Jurisdiction” means a jurisdiction that has been formally designated by the United Kingdom and/or the European Commission (as applicable) as providing an adequate level of protection for Personal Data.
“Cookie” means a small file that is placed on your device when you visit a website (including our Sites). In this policy, a reference to a “Cookie” includes analogous technologies such as web beacons and clear GIFs.
“Controller” means the entity that decides how and why Personal Data is Processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws.
“Data Protection Authority” means an independent public authority that is legally tasked with overseeing compliance with applicable data protection laws.
“EEA” means the European Economic Area.
“GDPR” means the General Data Protection Regulation (EU) 2016/679.
“Group Companies” means any direct or indirect subsidiary or any direct or indirect holding company or any such subsidiary of any such holding company or any such holding company of such subsidiary, “subsidiary” and “holding company” having the meanings defined in Section 1159 of the Companies Act 2006 as amended from time to time, including:

Group Companies

EcoOnline AS, EcoOnline AB, EcoOnline OY, EcoOnline ApS,EcoOnline AS Limited, Nordic Port AB, EcoOnline GmbH, EcoOnline UK Limited,EcoOnline North America, Alcumus LLC, Mango Software Limited, Mango Limited.

“International Data Transfer Agreement” means the agreement issued by the Information Commissioner under section 119A(1) of the Data Protection Act 2018.
“Personal Data” means information that is about any individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.
“Process”, “Processing” or “Processed” means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
“Processor” means any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller).
“Profiling” means any form of automated Processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
“Relevant Personal Data” means Personal Data in respect of which we are the Controller.
“Sensitive Personal Data” means Personal Data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, national identification number, or any other information that is deemed to be sensitive under applicable law.
“Standard Contractual Clauses” means template transfer clauses adopted by the European Commission or adopted by a Data Protection Authority and approved by the European Commission.
“Site” means any website operated, or maintained, by us or on our behalf.

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