PRIVACY POLICY

EMF is committed to processing personal data in a transparent, fair and lawful manner in compliance with the Data Protection Act 2018, the UK GDPR and the Privacy and Electronic Communications Regulations, and to honouring the rights of data subjects. This policy explains how we process your personal data and your rights in relation to that data. If we make changes to this privacy policy that affect how we handle your data, it will be updated and made available on the Website.

OUR CONTACT DETAILS

Ellen MacArthur Foundation and Ellen MacArthur Foundation Trading Limited

The Sail Loft

42 Medina Rd

Cowes

Isle of Wight PO31 7BX

United Kingdom


Data Protection Officer: Jo Bootle

+44 (0) 1983 296463

privacy@ellenmacarthurfoundation.org


SCOPE OF THIS POLICY

This privacy policy applies when:

  • You use the website (“Website”) or other digital platforms of the Business Coalition for a Global Plastics Treaty (“Coalition”)
  • You contact us to request information from us or provide information to us in relation to the Coalition
  • You join our mailing list in relation to the Coalition


THE INFORMATION WE COLLECT

The type of personal data we typically collect includes your name, contact details such as email address, phone number and address, and your organisation and job title. When you use the Website or other digital platforms, we may collect your IP address, your actions on the Website and your marketing preferences (where they have been indicated).


HOW WE OBTAIN YOUR INFORMATION

We may collect your personal data from you directly, and/or indirectly from your organisation or other organisations we work with.


HOW WE USE YOUR INFORMATION

We use your personal data for different purposes, depending on the reason you have given it to us or we have otherwise collected it.

Website

If you use the Website, we may use your data to personalise and improve your experience of it. If you submit content to or register to receive information on the Website, we will use your data to process that content or registration and communicate with you about it.

We use cookies on the Website. Please refer to the Website Cookie Policy for more information.

Contacting us

If you contact us to request information from us or to provide information to us, we will process your data to respond to that request or process the information you have provided.

Mailing lists (email marketing)

If you sign up to receive information in relation to the Coalition, we will use your data to send you that information.

We actively monitor our email subscription lists to ensure they are up to date. We may use a third-party service provider to monitor these lists and to send you these emails.


OUR LEGAL BASES

Under the UK GDPR, we are required to have a legal basis to process your personal data. The legal bases we rely on are set out below.

Consent

If you provide your consent to us processing your data (for example, when you ask to receive information), we will rely on your consent as a legal basis. You are able to withdraw your consent at any time. You can do this by contacting our Data Protection Officer using the contact details listed above.

Legitimate interest

We may have a legitimate interest in processing your data. We will rely on this basis when there is not a contract between us and you or your organisation, and it is not appropriate for us to rely on your consent or another legal basis.

We will rely on having a legitimate interest provided that processing your data is necessary and your interests do not outweigh the legitimate interest. We will only process your data when you would reasonably expect for us to do so. This includes sending you information relevant to the Coalition, or sharing your data with third parties who are involved in our activities and third-party providers who support our operations, such as IT service providers or contractors.

Our legitimate interests include:

  • furthering our charitable objectives;
  • promoting the idea of a circular economy;
  • the broader societal benefits that a move towards a circular economy will create; and
  • the benefits of our work to those we interact with, including helping individuals learn about the circular economy, and supporting our stakeholders to implement the principles of a circular economy in their work.

Legal obligation

Where we are required to provide data to a third party by law, we will provide that data to that third party.

HOW WE MAY SHARE YOUR PERSONAL DATA

We may share your personal data with other members of our charitable group. Our charitable group includes our subsidiaries and any associated companies or charities, including those in the EEA, the United States, China and Brazil. Where necessary, your data will be added to our databases, and may be accessed by our staff worldwide. Where your data is used in other countries, we have taken steps to ensure that the information is appropriately protected.

We may also share personal data with selected third parties including our partners, agents, service providers and legal and professional advisors where it is necessary to do so as part of our relevant activities. When we share data with third parties, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality and security obligations. We may also share personal data with third parties if we are under a duty to disclose it in order to comply with any law or legal obligation (including to investigate or prevent crime), or to protect our rights, our property or the safety of others, or where you have consented to us doing so.

HOW WE STORE YOUR INFORMATION

Your information is stored securely on EMF’s internal systems and by third-party hosts who implement secure data storage procedures.

We will only hold your information for as long as necessary for the purposes for which it was collected, or if we are required to hold it for operational or legal purposes. We will periodically review the information we hold to determine whether it is still necessary for us to be holding it for those purposes. We may contact you to check whether you still want us to hold your information if we cannot establish whether we have heard from you in three years. If we do not hear from you after attempting to make contact with you, or we otherwise determine that we no longer need to hold it, we will dispose of your information securely by erasing it from our systems or putting it beyond use.

TRANSFERRING DATA OVERSEAS

Your personal data may be transferred to, stored at, and/or processed by people or organisations working in other countries outside of the UK. This includes transferring data to other members of our charitable group, and our partners, agents, service providers and legal and professional advisors. Any such transferral, storage or processing will be undertaken in accordance with the UK GDPR. We will take all steps reasonably necessary to ensure that your personal data is transferred, stored and processed securely.

YOUR DATA PROTECTION RIGHTS

Data subjects (people) about whom we hold personal data have the following rights under data protection law. You have different rights depending on the legal basis we have for using your data. If you have any questions about your rights in relation to your personal data, please contact our Data Protection Officer using the contact details listed above.

A right to be informed: you have a right to know how we use your data, and this is the purpose of this privacy policy.

A right of access: you have the right to ask us for copies of your personal information.

A right to rectification: you have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

A right to erasure: you have the right to ask us to erase your personal information in certain circumstances.

A right to restriction of processing: you have the right to ask us to restrict the processing of your personal information in certain circumstances.

A right to object to processing: you have the right to object to the processing of your personal information in certain circumstances.

A right to data portability: you have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

Where you have provided consent to our use of your data, you also have the unrestricted right to withdraw that consent at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where we have a legitimate reason for doing so.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

If you wish to make a request, please contact our Data Protection Officer using the contact details listed above.

HOW TO COMPLAIN

If you have any concerns about our use of your personal information, you can make a complaint to us via our Data Protection Officer using the contact details listed above.

You can also complain to the Information Commissioner’s Office (ICO) if you are unhappy with how we have used your data:

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk