At EcoHedge Ltd (“we”, “us”, or “our”) we are committed to protecting and respecting your privacy and Personal Data in compliance with the United Kingdom General Data Protection Regulation (“GDPR”), the Data Protection Act 2018 and all other mandatory laws and regulations of the United Kingdom.
This Privacy Policy explains how we collect, process and keep your data safe. The Privacy Policy will tell you about your privacy rights, how the law protects you, and inform our employees and staff members of all their obligations and protocols when processing data.
Who is Your Data Controller
EcoHedge Ltd is your Data Controller for your Personal Data. We are not obliged by the GDPR to appoint a data protection officer and have not voluntarily appointed one at this time. Therefore, any inquiries about your personal data should either be sent to us on email at [email protected] or sent in a letter to EcoHedge Ltd. 71-75 Shelton Street, Covent Garden, London, England, WC2H 9JQ.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Type of personal data we process
“Personal Data” means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store, delete different kinds of Personal Data about you which we have grouped together below. Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect and when we collect it from you:
We also collect use and share Aggregate Data such as emissions for specific industry verticals and product categories. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. 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 Policy.
We may also aggregate data to enable research or analysis so that we can better understand and serve you and others. For example, we may conduct research on your demographics and usage. Although this aggregated data may be based in part on Personal Data, it does not identify you personally. We may share this type of anonymous data with others, including service providers, our affiliates, agents and current and prospective business partners.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
The Legal Basis for processing your Personal Data
There are a number of justifiable reasons under the GDPR that allow the processing of Personal Data. We rely on:
How we use your Personal Data
We will only use your Personal Data when the law allows us to. Specifically, you will receive our newsletter or marketing and new content communications from us if you have consent to receiving those communications. From time to time we may make suggestions and recommendations to you about goods or services that may be of interest to you.
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.
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.
Disclosure of your personal data
We share your personal data with internal third partis, these are employees authorised by access who have access to your personal data under our instruction.
We may share your personal data with professional advisers including but not limited to lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services, regulators and other authorities only if it is necessary to do so.
We require third parties to implement adequate organisational and technical measures to ensure the security of your personal data.
Your rights
As per the Data Protection Laws in force, you have the following rights:
You can always withdraw the consent you gave at any time, if you do this we must stop processing your personal data. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.
If you would like to exercise one of your rights please contact us at [email protected] or send in a letter to EcoHedge Ltd. 71-75 Shelton Street, Covent Garden, London, England, WC2H 9JQ .
We may need to request specific information from you to help us confirm your identity and ensure you have the 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.
Security of your personal data
We are concerned with keeping your data secure and protecting it from inappropriate disclosure. We implement a variety of technical and organisational measures to protect and ensure the security of your Personal Data. Any Personal Data collected by us is only accessible by a limited number of employees who have special access authorisation, are specifically instructed by us, and are bound by obligations of confidentiality.
Your account information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or device and by signing off after you have finished accessing your account.
You can access information associated with your account by logging into your account you created with us.
Retention period
We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your Personal Data for a longer period than usual in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
Transfer of Personal Data outside the EEA
Wherever possible we do not transfer your personal data outside the European Economic Area (EEA). Although, some of our external third parties are based outside the European Economic Area (EEA).
Whenever we transfer your personal data out of the EEA, we ensure that an appropriate level of protection is afforded. In fact, we will only transfer your Personal Data to countries which have an adequate level of protection, as declared by the European Commission: Adequacy of the protection of personal data in non-EU countries. Or, in other cases, we rely on standard contractual clauses as approved by the EU Commission.
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