- At Earth Active we respect your rights in relation to your personal data.
This Notice sets out information about how we use, store and transfer personal data which we receive in connection with our services or otherwise.
We or us means Earth Active Ltd, a company registered in the UK under number 11468960, whose registered office address is at 2a High Street, Thames Ditton, England, KT7 0RY.
Full details are set out in the relevant sections of this Notice below, but in brief:
- we are a data controller in relation to the personal data that we hold. That means we determine how we will use and look after it;
- we normally receive your personal data from you, but sometimes from a third party (for instance, from your employer or a referrer);
- we use your personal data to deliver our services, conduct our business, keep appropriate records and meet our legal obligations;
- we only provide your personal data to third parties for our business purposes or as permitted by law. We don’t share your data with third party advertisers;
- we store personal data for specified periods;
- you have legal rights in relation to your personal data which you can exercise on request;
- you can contact us to enquire about any of the contents of this Notice.
- Personal Data we Collect
In this Section we have set out the kinds of personal data that we may collect, use, store and transfer. We have grouped that data together into different categories based on subject matter, and based on the kinds of individuals to whom they relate.
Data relating to almost everyone we deal with: e.g. clients, website users, enquirers, suppliers
- We may process information contained in or relating to any enquiry or communication that you send to us or that we send to you (correspondence data). This could for example include correspondence from our clients or suppliers, enquiries from journalists, or any other correspondence. The correspondence data may include the communication content and metadata associated with the communication, as well as any contact details you may provide to us such as your name, email address, phone number, job title, address or social media username.
- If we have some commercial relationship with you or with your employer or anyone with whom you and we have a mutual business relationship (for example, a supply or purchase relationship) then we may handle your contact details (name, job title, email address, postal address, telephone number), any related communications, and any related documents (such as contracts, POs and invoices, proposals, our work outputs and matter files and so on). We call all of this business data, and we process it for the purposes of administering our commercial relationship with you, your employer, or our mutual business partners.
- Data relating to website users
- We may process data about your use of our website (usage data), which we obtain through our analytics tracking systems. The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use.
- Personal data we obtain from others
- Your personal data may be provided to us by someone other than you. For example, if we do business with you then your contact details will normally have been provided through your employer, or we might be introduced to you in correspondence by a mutual acquaintance or another user of our services. Normally this data will be correspondence data or business data.
- Our purposes and legal bases of processing
- We have set out below, in table format, a description of all the ways we may use your personal data. We’re also required by law to identify the legal basis on which we handle personal data. These legal bases are set out in Article 6 of the General Data Protection Regulation (GDPR). When we process personal data on the basis of our legitimate interests then we also need to identify those legitimate interests and have done so below.
- Note that we may process your personal data on more than one legal basis depending on the specific purpose for which we are using your data.
Type of Data
|Purpose/Activity||Legal Basis for Processing|
|Correspondence Data||To communicate with you. If you have indicated your interest in our services then we may also process correspondence data to provide you with occasional news about our services and marketing communications (although you will be free to unsubscribe at any time).|
Our legitimate interests (Art 6.1(f) GDPR), namely in properly administering our business and communications, developing our relationships with interested parties and addressing concerns and queries.
Where correspondence data relates to marketing, our legitimate interests in developing our business.
Where correspondence relates to any contract or potential contract with you, then our legal basis may be for the performance of a contract with you, or to take steps at your request prior to entering into a contract with you (Art 6.1(b) GDPR).
|Business data||Administering our commercial relationship with those with whom we do business.|
Performance of a contract with you (if you are a provider to us).
Our legitimate interests, namely in properly administering our business and communications, and developing commercial relationships.
Analyzing the use of, and improving, our site and services, security monitoring and fraud detection and to ensure our website is presented in the most effective manner.
|Our legitimate interests, namely in delivering and improving our website and ensuring its security.|
|Any personal data|
For the purposes of legal compliance (e.g. maintaining tax records)
|Compliance with our legal obligations (Art 6.1(c) GDPR)|
Any personal data
For the purposes of bringing and defending legal claims
|Our legitimate interests, namely being able to conduct and defend legal claims to preserve our rights and those of others.|
Any personal data
Record-keeping and hosting, back-up and restoration of our systems.
|Our legitimate interests, namely ensuring the resilience of our IT systems and the integrity and recoverability of our data.|
- Providing your personal data to others
- Our advisors. We may disclose your personal data to our insurers and/or professional advisers to take professional advice and manage legal disputes.
- Disclosures designated by you. We may disclose your personal data to third parties designated by you (so, for example, other suppliers with whom we are working in connection with our work for you).
- Our service providers. We may disclose personal data to our service providers or subcontractors in connection with the uses we’ve described above. For example, we may disclose:
- any personal data in our possession to suppliers which host the servers on which our data is stored, or to freelance staff whose duties involve handling the relevant personal data;
- business data to our subcontractors;
- correspondence data to providers of email or email marketing services;
- usage data to providers of analytics services.
- We do not allow our data processors to use your personal data for their own purposes. We only permit them to use your personal data for specified purposes, in accordance with our instructions and applicable law.
- Compliance. We may also disclose your personal data where necessary to comply with law.
- International transfers of your personal data
Some of the third parties to whom we may transfer your personal data, discussed above, may be located outside the EEA or may transfer your personal data to their own service providers located outside the EEA. If so, then we will ensure that transfers by our appointed data processors will only be made lawfully (e.g. to countries in respect of which the European Commission has made an "adequacy decision”, or with appropriate safeguards such as the use of standard clauses approved by the European Commission). You may contact us if you would like further information about these safeguards.
- Data security
We have put in place appropriate security measures to protect your personal data. We also have procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where required by law.
- Retaining and deleting personal data
- We comply with our legal obligations in relation to the retention and deletion of personal data, and in particular ensure that personal data that we process is not kept for longer than is necessary for the relevant purposes.
- We may retain your personal data longer than set out above where necessary to comply with law or in connection with any legal claim.
- Your rights
- You have rights under data protection law – they are complex, and subject to exemptions, and you can read guidance from the Information Commissioner’s Office at ico.gov.uk for a fuller explanation of your rights. In summary, though:
- the right to access: you have the right to confirmation as to whether or not we process your personal data and, where we do, to access to the personal data, together with certain additional information;
- the right to rectification: you have the right to have any inaccurate or incomplete personal data about you rectified or completed;
- the right to erasure: in some circumstances you have the right to the erasure of your personal data (for example, if the personal data are no longer needed for the purposes for which they were processed or if the processing is for direct marketing purposes);
- the right to restrict processing: you have the right to restrict the processing of your personal data to limit its use. Where processing has been restricted, we may continue to store your personal data and will observe the restrictions on processing except to the extent permitted by law;
- the right to object to processing: you have the right to object to our processing of your personal data on the basis of legitimate interests (discussed above) or for direct marketing purposes and if you do so we will stop processing your personal data except to the extent permitted by law;
- the right to complain to a supervisory authority: if you consider that our processing of your personal data is unlawful, you have a legal right to lodge a complaint with the ICO.
- A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
- Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
- Cookies do not typically contain any information that personally identifies a user (except for IP addresses in some cases), but personal information that we store about you may be linked to the information stored in and obtained from cookies.
- We may use any of these kinds of cookies:
- Strictly Necessary Cookies: these cookies are essential to provide you with services available through our website and to enable you to use some of its features.
- Functionality Cookies: These cookies allow our website to remember choices you make when you use our website.
- Analytical/Performance Cookies: These cookies are used to collect information about traffic to our website and how users use our website. We use this information to help operate our website more efficiently and to gather broad insights about users of our website (such as location, bounce rate and so on).
- Google Analytics: Our website use Google Analytics (an analytical/performance cookie) to help analyse how users use our websites, collecting standard internet log information and visitor behaviour information in an anonymised form from which no user is identifiable. This information is transmitted to Google and processed to compile statistical reports on activity on our websites. These reports allow us to optimise our user experience. Google provide a browser add-on for users who wish to prevent their data from being used by Google Analytics. Further information is available at https://tools.google.com/dlpage/gaoptout/.
- You can choose which cookies are set or rejected through a pop-up which will appear on our website when you first visit. Strictly Necessary Cookies cannot be rejected.
- Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can obtain up-to-date information about blocking and deleting cookies via the support pages made available by your browser operator.
- Third Parties
Our website may contain links to third party websites and refer to third party service providers and other entities. If you follow a link to any third party website or deal with any third party referred to on our websites, then they may have their own privacy and cookie policies, and we are not responsible for their use of any personal data which you may provide to them.
We may update this Notice from time to time by publishing a new version on our website. You should check occasionally to ensure you are happy with any changes to this Notice, although we may notify you of significant changes to this Notice using the contact details you have given us.
- Data protection registration
We are registered as a data controller with the UK Information Commissioner's Office. Our data protection registration number is ZA495002.
- Contact Us
If you have any questions, comments or requests regarding this Privacy Notice or our use of any personal data, you can contact us at:
2a High Street, Thames Ditton, England, KT7 0RY email: email@example.com