Ethical Screening is the trading name of Ethical & Environmental Screening Services Ltd. which is registered in England & Wales, with the company number 3633308, and our registered office is at Formal House, 60 St. George's Place, Cheltenham, GL50 3PN.
1. INCORPORATION OF PRIVACY POLICY
1.1 Ethical & Environmental Screening Services t/a Ethical Screening ('Company') is committed to ensuring that your privacy is protected and the Company is compliant with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. Where services are accessed by individuals in the European Economic Area (EEA), we are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to such access.
1.2 This privacy policy ('Privacy Policy') explains how the Company uses the information the Company collects about you when you use the Company's website http://www.ethicalscreening.co.uk ('Website'), online services through the Ethical Screening Portal https://app.ethicalscreening.co.uk and/or utilizing any of the Company's products or services (all collectively as 'Services') set out in the Website and the procedures that the Company has in place to safeguard your privacy. This website is not intended for children and we do not knowingly collect data relating to children.
1.3 If you do not agree with the terms and conditions set out in this Privacy Policy, do not continue to use the Services and/or this Website.
2. INFORMATION THE COMPANY COLLECTS AND HOW THE COMPANY USES IT
2.1 When you visit the Website, the Ethical Screening Portal, or obtain any Products or Services offered on the Website, the Company may collect the following personal data about you, depending on the particular activities carried out:
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your name, postal address, e-mail address, telephone number
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details of any information, feedback or other matters you give us by phone, email, post or via social media
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your account details, such as username and login details
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your activities on, and use of, the Website and Ethical Screening Portal
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your personal or professional interests
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your ethical, environmental and social preferences
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your contact history
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information about how you use our website and technology systems
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your responses to surveys, competitions and promotions
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FCA registration number (for specific Services)
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information about the Services we provide to you
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such other relevant information which the Company deems necessary to process and fulfil your order in respect of the Services. This shall include:
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verifying your professional credentials before permitting access to certain Services;
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providing you with user names and access codes to the Ethical Screening Portal; and
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transmitting in a secure manner to third parties to assist the Company to provide you with the Services requested by you and to maintain the support services of the Company.
2.2 If you do not provide personal data we ask for where it is indicated to be 'required' at the point of collection, it may delay or prevent us from providing services to you.
3. HOW YOUR PERSONAL DATA ARE COLLECTED
3.1 We collect personal data from you:
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Directly, when you enter or send us information, such as when you:
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register with us;
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send us electronically or by post completed questionnaires containing your ethical, environmental and social preferences;
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contact us (including via email);
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send us feedback;
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access products or services via our website;
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post material to our website; and
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complete customer surveys or participate in competitions via our website.
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Indirectly, such as your browsing activity while on our website; we will usually collect information indirectly using the technologies explained in the 'Use of Cookies and Other Information Gathering Technologies' section below.
4. HOW AND WHY WE USE YOUR PERSONAL DATA
4.1 Under data protection law, we can only use your personal data if we have a proper reason, e.g.:
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where you have given consent;
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to comply with our legal and regulatory obligations;
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for the performance of a contract with you or to take steps at your request before entering into a contract; or
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for our legitimate interests or those of a third party.
4.2 A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see 'Other Terms and Contact Details' below).
4.3 The table below explains what we use your personal data for and why.
What we use your personal data for
Our reasons (legal basis)
Create and manage your account with us
To perform our contract with you or to take steps at your request before entering into a contract
Or
For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service to you at the best price
Providing products and/or services to you
To perform our contract with you or to take steps at your request before entering into a contract
Conducting checks to identify you and verify your identity or to help prevent and detect fraud against you or us
To comply with our legal and regulatory obligations
OR
For our legitimate interests or those of a third party, i.e., to minimise fraud that could be damaging for you and/or us
To enforce legal rights or defend or undertake legal proceedings
Depending on the circumstances:
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in other cases, for our legitimate interests or those of a third party, i.e., to protect our business, interests and rights or those of others
Customise our website and its content to your particular preferences based on a record of your selected preferences or on your use of our website
Depending on the circumstances:
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where we are not required to obtain your consent and do not do so, for our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service to you at the best price
Retaining and evaluating information on your recent visits to our website and how you move around different sections of our website for analytics purposes. This helps us to understand how people use our website so that we can make it more intuitive or to check our website is working as intended
Depending on the circumstances:
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where we are not required to obtain your consent and do not do so, for our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service to you at the best price
Communications with you not related to marketing, including about changes to our terms or policies or changes to our products or services or other important notices
Depending on the circumstances:
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in other cases, for our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service to you at the best price
Protecting the security of systems and data
To comply with our legal and regulatory obligations
We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests or those of a third party, i.e., to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us
Statistical analysis to help us manage our business, e.g., in relation to our financial performance, customer base, product range or other efficiency measures
For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service to you at the best price
Updating and enhancing customer records
Depending on the circumstances:
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to comply with our legal and regulatory obligations
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where neither of the above apply, for our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our customers about existing orders and new products
Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, e.g., to record and demonstrate evidence of your consents where relevant
To comply with our legal and regulatory obligations
Marketing our services to existing and former customers
For our legitimate interests or those of a third party, i.e., to promote our business to existing and former customers
See 'Marketing' below for further information
External audits and quality checks, e.g., for the audit of our accounts
For our legitimate interests or a those of a third party, i.e., to maintain our accreditations so we can demonstrate we operate at the highest standards
To share your personal data with third parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency. In such cases information will be anonymised where possible and only shared where necessary
Depending on the circumstances:
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in other cases, for our legitimate interests or those of a third party, i.e., to protect, realise or grow the value in our business and assets
4.4 Certain personal data we collect is treated as a special category to which additional protections apply under data protection law such as personal data revealing ethical, environmental and social preferences, political opinions, religious beliefs, or philosophical beliefs.
4.5 Where we process such special category personal data, we will also ensure we are permitted to do so under data protection laws.
4.6 Subject to the terms and conditions of this Privacy Policy, the Company protects all personal and financial data from being disclosed to any third parties except when required by law. In addition, the Company may use your information to assist in the prevention of unlawful activities e.g. money laundering or activities which threaten the Company's Website or is adverse to your or the Company's interest.
4.7 The Company may also use aggregate information and statistics, (but, which will not contain your identifying information) for the purposes of monitoring your usage of the Website in order to help the Company develop the Website and the Services offered by the Company. The Company may provide such aggregate information to third parties.
5. MARKETING
5.1 We may use your personal data to send you updates (by email, telephone or post) about our products and/or services, including exclusive offers, promotions or new products and/or services, and about special features on our website.
5.2 We have a legitimate interest in using your personal data for marketing purposes (see above 'How and why we use your personal data'). This means we do not usually need your consent to send you marketing information. However, where consent is needed, we will ask for this separately and clearly.
5.3 You have the right to opt out of receiving marketing communications at any time by:
5.4 We may ask you to confirm or update your marketing preferences if you ask us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.
5.5 We will always treat your personal data with the utmost respect and never share it with other organisations outside of our company for marketing purposes unless we have your explicit consent to do so.
5.6 For more information on your right to object at any time to your personal data being used for marketing purposes, see 'Your rights' below.
6. WHO WE SHARE YOUR PERSONAL DATA WITH
6.1 We routinely share personal data with:
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third parties we use to help deliver our products and/or services to you, e.g., investment managers; and
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other third parties we use to help us run our business, e.g., website hosts and website analytics providers.
6.2 We only allow those organisations to handle your personal data if we are satisfied that they take appropriate measures to protect your personal data. Where appropriate to the relationship with those organisations, we also impose contractual obligations on them to ensure they can only use your personal data to provide services to us and to you.
6.3 We or the third parties mentioned above may occasionally also need to share personal data with:
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external auditors, e.g. in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations;
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professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations
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law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations
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other parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency - usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations
6.4 If you would like more information about who we share our data with and why, please contact us (see 'Other Terms and Contact Details' below).
6.5 Subject to the other provisions of this Privacy Policy and such other provisions specified on the Website, the Company will not provide your information to other companies or organisations without your consent.
7. HOW LONG YOUR PERSONAL DATA WILL BE KEPT
7.1 We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
7.2 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, regulatory, tax, accounting or other requirements.
7.3 By law we have to keep basic information about our customers (including contact, identity, financial and transaction data) for six years after they cease being customers for tax purposes.
7.4 In some circumstances you can ask us to delete your data: see 'Your rights' below for further information.
7.5 In some circumstances we will 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.
7.6 Following the end of the of the relevant retention period, we will delete or anonymise your personal data.
8. TRANSFERRING YOUR PERSONAL DATA OUT OF THE UK
8.1 Your personal data are stored at our registered office and/or on servers or at data centres based in the UK, and are subject to UK data protection laws. We do not transfer personal data outside the UK.
8.2 Any changes made which result in the transfer your personal data outside the UK or the EEA will be notified to you in accordance with paragraph 14.3 in 'Other Terms and Contact Details' below.
9. USE OF COOKIES AND OTHER INFORMATION GATHERING TECHNOLOGIES
9.1 Ethical Screening's website uses cookies, which are small pieces of data sent from a website and stored on users' computers by their web browser, while they are browsing. To view or change your personal cookie settings, please go to our Manage Website Cookies page.
9.2 We use the non-persistent ASP.NET_SessionId cookie to establish a unique session for each user of our website. This makes our website usable by enabling basic functions like page navigation, and maintaining users' access to the databases when they log in. This session cookie lasts only for the duration of the users visit, and no personal data are obtained. To read more about ASP.NET cookies visit the Microsoft Developer Network website. Without this particular cookie our website cannot function properly and it cannot be disabled. If you do not consent to the use of this cookie, you should not use this website.
9.3 We use Google Analytics to analyse and create reports about the use of our website to help us improve the user experience by, for example, tracking which pages are the most popular. Google Analytics generates information by means of persistent cookies. The analytics cookies used by our website are:
9.3.1 _ga registers a unique ID that is used to generate statistical data on how visitors use our website and expires after 2 years.
9.3.2 _gid registers a unique ID that is used to generate statistical data on how visitors use our website and expires after 24 hours.
9.3.3 _gat is used by Google Analytics to throttle request rate and expires after 10 minutes.
9.3.4 collect is a non-persistent cookie used by Google Analytics to collect data about the visitor's device and behaviour and track the them across devices and marketing channels. This is a session cookie and lasts only for the duration of the users visit.
Google Analytics' privacy policy is available here. To read more about analytics cookies visit the Google Analytics developer website.
9.4 In addition to the cookie control features on this website, most browsers also allow you to block cookies and your internet browser's help files will give you instructions on how to do this. If you do block all cookies, you will not be able to use all the features on our website, such as logging into the databases, and the functionality of many other websites will be impaired.
9.5 You can also delete cookies already stored on your computer - please refer to your internet browser's help files for instructions on how to do this. Deleting cookies may impair the functionality of many websites.
9.6 Please note that links to external websites may lead to sites using cookies over which the Company has no control.
10. YOUR RIGHTS
10.1 You generally have the following rights, which you can usually exercise free of charge:
Access to a copy of your personal data
The right to be provided with a copy of your personal data
Correction (also known as rectification)
The right to require us to correct any mistakes in your personal data
Erasure (also known as the right to be forgotten)
The right to require us to delete your personal data - in certain situations
The right to require us to restrict use of your personal data in certain circumstances, e.g., if you contest the accuracy of the data
The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party - in certain situations
The right to object:
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at any time to your personal data being used for direct marketing (including profiling)
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in certain other situations to our continued use of your personal data, e.g., where we use your personal data for our legitimate interests.
Not to be subject to decisions without human involvement
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
We do not make any such decisions based on data collected by our website.
10.2 For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see 'Other Terms and Contact Details' below). You may also find it helpful to refer to the guidance from the UK's Information Commissioner on your rights under the UK GDPR.
10.3 If you would like to exercise any of those rights, please contact us - see below: 'Other Terms and Contact Details'. When contacting us please:
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provide enough information to identify yourself and any additional identity information we may reasonably request from you; and
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let us know which right(s) you want to exercise and the information to which your request relates.
11. PROTECTING YOUR INFORMATION
11.1 The internet is not a secure medium. However, the Company has put in place various security procedures and strict policy rules to safeguard and protect your information from unauthorised and unlawful access and use. These security procedures and policy which are of the highest standards are continuously improved.
11.2 We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it.
11.3 We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
11.4 Notwithstanding the above, it should be appreciated that no system is entirely fool-proof and you should be careful when you reveal any confidential information to any third party.
12. SALE OF THE COMPANY
12.1 If the Company and/or this part of its business is sold or integrated with another business, your details may be disclosed to the Company's advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the Company.
13. UPDATING YOUR DETAILS
13.1 If any of the information that you have provided to the Company changes, for example if you change your e-mail address, name or payment details or if you wish to cancel your order, please let the Company know the correct details by sending an e-mail to enquiries@ethicalscreening.com
14. OTHER TERMS AND CONTACT DETAILS
14.1 Owing to the global nature of the Internet infrastructure, the information you provide may be transferred in transit to countries outside the United Kingdom that do not have similar protections in place regarding your data and its use as set out in this Privacy Policy. However, the Company has taken the steps outlined above to try to improve the security of your information. By using the Website, you consent to these transfers.
14.2 The Company supplies links to other websites. If you click on a link, you are not protected by this Privacy Policy and you are advised to read the privacy policy of the other website as they may differ from this Privacy Policy.
14.3 The Company reserves the right to amend this Privacy Policy from time to time as it deems necessary. In such event, the Company will post such changes on the Website.
14.4 You have the right at any time to ask the Company not to process your personal data for marketing purposes.
14.5 You have the right to request details of personal information which the Company holds about you under the Data Protection Act 2018. A small fee may be payable. If you want a copy of information held on you, please email enquiries@ethicalscreening.com
14.6 The Company welcomes your views about the Website and its privacy policy. If you would like to contact the Company with any requests, queries or comments please send an e-mail to enquiries@ethicalscreening.com
14.7 You have the right to lodge a complaint with:
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the Information Commissioner in the UK, and; or
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if relevant, a relevant data protection supervisory authority in the EEA state of your habitual residence, place of work or of an alleged infringement of data protection laws in the EEA
The UK's Information Commissioner may be contacted at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.