Privacy Policy

Privacy Policy

SupplyESChange respects your privacy and is committed to protecting your personal data. 

This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or interact with us as a customer, potential customer or a person interested in SupplyESChange issues. This privacy notice will tell you about your privacy rights and how the law protects you. 

1. Important information and who we are 

Purpose of this privacy notice 

This privacy notice aims to give you information on how SupplyESChange collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase a product or service or take part in a survey. 

This website is not intended for children and we do not knowingly collect data relating to children. 

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them. 

Who we are: 

We, SupplyESChange Ltd UK are a London based UK registered consulting firm and initiative, advising and advocating in the areas of Supply Chain social compliance (modern slavery eradication and good labour conditions) and sustainability. Our website address is: http://supplyeschange.com. 

We believe in conducting Business Ethically, and the purpose of this business and our website is to support the delivery of improved supply chain labour and environmental conditions. To achieve those results, we wish to facilitate discussion on challenges businesses face and to share guidance to overcome those challenges. Answering some of your questions and supporting your efforts via our occasional email Insight Updates, and discussion sections of this website may be best achieved through allowing you easier login, which requires some collection of personal data, and/or your joining our enewsletter list. 

We are committed to maintaining the privacy of your data, and will not sell it to third parties. 

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us: 

Full name of legal entity: SupplyESChange Limited 

Email address: info@SupplyESChange.com 

Postal address: 27 Old Gloucester St, London, WC1N 3AX, United Kingdom 

Telephone number: +44 7557359598 

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. 

Changes to the privacy notice and your duty to inform us of changes 

This is version created/ last updated November 2018. 

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. 

Third-party links 

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit. 


2. What personal data we collect and why we collect it 

Contact forms

SupplyESChange will use the information you provide on our Contact form to be in touch with you and to provide updates and marketing. Please tick the box marked 'Email' to indicate you are happy for us to do this in accordance with our Data Use Policy. Without this tick, we won't be able to send the latest insights on emerging supply chain labour and environmental risks and how business manage them! 

We don’t sell your data

We take data privacy very seriously, and will always treat your information with respect, and will not sell it to third parties. 

Removing yourself from our email list 

You can change your mind about receiving our emails at any time, just click the unsubscribe link at the bottom of any message you receive from us, or contact us at info@supplyeschange.com . 

What data we Collect

Personal data, or personal information, 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 and transfer different kinds of personal data about you such as: 

  • Identity Data includes first name, last name, username or similar identifier, title and gender, public social accounts such as Twitter and LinkedIn. 

  • Contact Data includes billing address, delivery address, email address and telephone numbers. 

  • Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. 

  • Profile Data includes purchases or orders made by you, your interests, preferences, feedback and survey responses. 

Usage Data includes information about how you use our website, products and services. 

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. 

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. 

Aggregated Data may be derived from your personal data but we understand that it is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. 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 notice.

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. 

If you fail to provide personal data: Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time. 


3. How is your personal data collected? 

We use different methods to collect data from and about you, including through: 

Direct interactions. You may give us your Identity and Contact by filling in forms, providing a business card or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • subscribe to our publications or newsletters; 

  • subscribe to our Courses; 

  • provide us your business card at an event or when we meet; 

  • request marketing or information to be sent to you; 

  • enter a competition, promotion or survey; or 

  • give us some feedback. 

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details. 

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below: 

  • Technical Data from the following parties: 

    • (a) analytics providers [such as Google based outside the EU]; 

    • Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU, as well as websites such as LinkedIn and Google. images on the website. 

4. How we use your personal data 

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: 

  • Where we need to perform the contract we are about to enter into or have entered into with you. 

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Inline with legal norms, this would include our emailing you our updates unless you ask to be removed from our email newsletter list. 

  • Where we need to comply with a legal or regulatory obligation. 

  • Where you have provided your consent. 

Purposes for which we will use your personal data:

We have set out below, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. 

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below. 

Purpose/Activity. Type of data. Lawful basis for processing including basis of legitimate interest:

To register your company as a new customer or a member of Engaging Stakeholders and to deliver services under a contract with you

  1. Identity 

  2. Contact 

  3. Interview notes of employees, contractors and other stakeholders Performance of a contract with your company 

To manage our relationship with you which will include: 

  1. Notifying you about changes to our terms or privacy policy 

  2. Asking you to leave a review or take a survey 

  3. Sending you newsletters 

  4. Sending you invitations to events

  5. Contact 

  6. Profile 

  7. Marketing and Communications

(b) Necessary to comply with a legal obligation 

(c) Necessary for our legitimate interests (to keep our records updated and to study your interest and views on SupplyESChange issues and/or our products) 

(d) Consent provided by you if you are an individual or partnership and not a corporate subscriber, in which case we are not relying on legitimate interest under (b) 

To enable you to partake in a prize draw, competition or complete a survey:

  1. Identity 

  2. Contact 

  3. Profile 

  4. Usage 

  5. Marketing and Communications

Administration:

  1. Performance of a contract with you 

  2. Necessary for our legitimate interests (to study customers’ interest and views on SupplyESChange issues and/or our services) 

  3. Consent provided by you if you are an individual or partnership and not a corporate subscriber, in which case we are not relying on legitimate interest under (b) 

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data):

  1.  Identity. Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise). 

  2.  Contact. Necessary to comply with a legal obligation. 

  3.  Technical. To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you:

a.  Identity 

b. Contact 

c. Profile 

d. Usage 

e. Marketing and Communications 

  1. Technical. Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy). 

      To use data analytics to improve our website, products/services, marketing, customer relationships and experiences.

  1.  Usage. Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).

      To make suggestions and recommendations to you about goods or services that may be of interest to you:

a.  Identity 

b. Contact 

c. Technical 

d. Usage 

  1.  Profile. Necessary for our legitimate interests (to develop our products/services and grow our business) 

  1. Marketing 

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You can access your preferences dashboard from a link in every email that we send. 

Promotional offers from us 

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services, events and offers may be relevant for you (we call this marketing). 

You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing. 

  1. Third-party marketing 

We will not share your personal data with any company outside the SupplyESChange group of companies for marketing purposes. 

  1. Cookies 

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy page. 

  1. Change of purpose 

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. 

f 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. 

  1. Disclosures of your personal data 

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above. 

  1. Internal Third Parties as set out in the Glossary. 

  2. External Third Parties as set out in the Glossary. 

Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice. 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. 

  1.  International transfers 

We share your personal data within the SupplyESChange Group. This will involve transferring your data outside the European Economic Area (EEA). 

Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. 

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: 

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. For further details, see European Commission: Model contracts for the transfer of personal data to third countries. 

Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield. 

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA. 

  1.  Data security 

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. 

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. 

  1. Data retention 

How long will you use my personal data for? 

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. 

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us. 

In some circumstances you can ask us to delete your data: see Request erasure below for further information. 

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. 

  1.  Your legal rights 

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights: 

 - Request access to your personal data. 

 - Request correction of your personal data. 

 - Request erasure of your personal data. 

 - Object to processing of your personal data. 

 - Request restriction of processing your personal data. 

 - Request transfer of your personal data. 

 - Right to withdraw consent. 


If you wish to exercise any of the rights set out above, please contact us. 

No fee usually required: You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. 

What we may need from you: We may need to request specific information from you to help us confirm your identity and ensure your 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. 

Time limit to respond: We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

LAWFUL BASIS 

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us. 

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. 

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to. 

Consent means you have consented to the processing activity. 

THIRD PARTIES 

Internal Third Parties 

Other companies acting as joint controllers or processors and who provide administration services and consultancy services. 

External Third Parties 

Service providers acting as processors based in the United Kingdom and the US who provide IT and system administration services. 

Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom or the US who provide consultancy, banking, legal, insurance and accounting services. 

HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances. 

Commercial partners, such as Globescan who we may work with on surveys. 

YOUR LEGAL RIGHTS 

You have the right to: 

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. 

  •  Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. 

  •  Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. 

  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. 

  •  Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 

  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. 

  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. 

Cookies Policy

This website uses cookies 

Cookies are small text files that can be used by websites to make a user’s experience more efficient. 

We use cookies to personalise content and ads, to provide social media features and to analyse our traffic. We also share information about your use of our site with our social media, and analytics partners who may combine it with other information that you’ve provided to them or that they’ve collected from your use of their services. You consent to our cookies if you continue to use our website. 

You may refuse the use of cookies by selecting the appropriate settings on your browser, or by contacting the provider in question (see table below). Furthermore you can at any time change or withdraw your consent from the Cookie Declaration on our website by contacting us at privacy@supplyeschange.com. However please note that if you do this you may not be able to use the full functionality of this website. 

Learn more about who we are, how you can contact us and how we process personal data in our Privacy Policy. 

Cookie types in use on this website 

Statistics 

Statistic cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously. 

Marketing 

Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third party advertisers. 

Cookies in use on this website 

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This website uses AddThis, a social sharing service provided by Oracle America, Inc. (“Oracle”) . AddThis uses “cookies” to help us analyse how visitors are sharing the website content. 

To opt out of Add This please click here. 


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This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies” to help us analyse how visitors use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. 

View the Google privacy policy. 

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