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DATA PRIVACY POLICY

1. PURPOSE AND SCOPE

1.1 This privacy policy provides information about how the Science Based Targets initiative Ltd, SBTi Services Ltd and their affiliates (“SBTi”) collect and uses your personal data through your use of the SBTi website, portals and other channels e.g social media platforms, online surveys.

2. CONTROLLER AND DATA PROTECTION MANAGER

2.1 This privacy policy applies to data processing by the SBTi, of the address:

• First Floor, 10 Queen Street Place, London, England, EC4R 1BE

2.2 The SBTi have appointed a Data Privacy Manager (DPM) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the SBTi DPM (Section 10).

3. TYPES OF PERSONAL DATA COLLECTED BY THE SBTI

3.1 Personal data means any information about an individual from which that person can be identified.

3.2 The SBTi may collect, use, store and transfer different kinds of personal data about you which is categorized as follows:

• 3.2.1 Identity Data includes first name, last name, any previous names, username or similar identifier, marital status, title, date of birth and gender.
• 3.2.2 Contact Data includes billing address, delivery address, email address and telephone numbers.
• 3.2.3 Financial Data includes bank account and payment card details.
• 3.2.4 Transaction Data includes details about payments to and from you and other details of products and services you have purchased from the SBTi.
• 3.2.5 Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access the SBTi
• 3.2.6 Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• 3.2.7 Usage Data includes information about how you interact with and use the SBTi website, products and services.
• 3.2.8 Marketing and Communications Data includes your preferences in receiving marketing from the SBTi and SBTi third parties and your communication preferences.

4. HOW YOUR PERSONAL DATA IS COLLECTED

4.1 The SBTi use different methods to collect data from and about you including through:

4.1.1 Your interactions with the SBTi. You may give the SBTi your personal data by filling in online forms or by corresponding with the SBTi by post, phone, email or otherwise. This includes, but is not limited to, personal data you provide when you:

• apply for SBTi products or services;
• interact with the SBTi Portal
• subscribe to any services or publications;
• request marketing to be sent to you;
• respond to a consultation or call for evidence; or
• provide feedback or contact the SBTi.

4.1.2 Automated technologies or interactions. As you interact with the website or portal, the SBTi will automatically collect Technical Data about your equipment, browsing actions and patterns. The SBTi collects this personal data by using cookies, server logs and other similar technologies.

5. BASIS FOR USE OF YOUR PERSONAL DATA

5.1 GDPR requires the SBTi to have a legal basis for collecting and using your personal data. The SBTi rely on one or more of the following legal bases:

5.1.1 Consent. The SBTi relies on consent where it has obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

5.1.2 Performance of a contract with you. Where the SBTi needs your personal data to perform the contract the SBTi are about to enter into or have entered into with you.

5.1.3 Legitimate interests. The SBTi may use your personal data where it is necessary to conduct SBTi business and pursue legitimate interests, for example to prevent fraud and enable the SBTi to give you the best and most secure customer experience. The SBTi will consider and balance any potential impact on you and your rights (both positive and negative) before processing your personal data for the SBTi legitimate interests. The SBTi will not use your personal data for activities where SBTi interests are overridden by the impact on you (unless the SBTi have your consent or are otherwise required or permitted to by law).

5.1.4 Legal obligation. The SBTi may use your personal data where it is necessary for compliance with a legal obligation. The SBTi will identify the relevant legal obligation when the SBTi relies on this legal basis.

6. DISCLOSURES OF PERSONAL DATA

6.1 The SBTi will only share your personal information with third parties if:

• you have given express consent;
• disclosure is required to assert, exercise or defend legal claims and there is no reason to assume that you have an overriding legitimate interest in not disclosing your data;
• disclosure is a legal obligation; or
• legally permissible and required for the performance or settlement of contractual relationships with you.

6.2 The SBTi’s legitimate interest follows from the data collection purposes listed above. The SBTi will never use the collected data for the purpose of drawing conclusions about you.

6.3 The SBTi uses cookies and analysis services when visiting the SBTi website.

6.4 The SBTi requires all third parties to respect the security of your personal data and to treat it in accordance with the law. The SBTi do not allow SBTi 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 SBTi instructions.

7. DATA SECURITY

7.1 The SBTi have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.

7.2 The SBTi limits 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 SBTi instructions and are subject to a duty of confidentiality.

7.3 The SBTi have put in place procedures to deal with any suspected personal data breach and will notify you and/or any applicable regulator of a breach where the SBTi are legally required to do so.

8. DATA RETENTION

8.1 The SBTi will only retain your personal data for as long as reasonably necessary to fulfill the purposes the SBTi collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

8.2 The SBTi may retain your personal data for a longer period in the event of a complaint or if the SBTi reasonably believe there is a prospect of litigation in respect to the SBTi’s relationship with you.

8.3 To determine the appropriate retention period for personal data, the SBTi consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which the SBTi process your personal data and whether this purpose can be achieved through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

8.4 By law the SBTi has to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for a period after they cease being customers.

9. YOUR LEGAL RIGHTS

9.1 You have a number of rights under data protection laws (Data Protection Act 2018 (DPA 2018) and UK GDPR) in relation to your personal data. You have the right to:

• Request access to your personal data (commonly known as a "subject access request"). A subject access request enables you to receive a copy of the personal data the SBTi holds about you and to check that the SBTi are lawfully processing it.
• Request correction of the personal data that the SBTi holds about you. This enables you to have any incomplete or inaccurate data the SBTi holds about you corrected, though the SBTi may need to verify the accuracy of the new data you provide.
• Request erasure of your personal data in certain circumstances (commonly known as the “right to be forgotten)”. This enables you to ask the SBTi to delete or remove personal data where there is no good reason for the SBTi continuing to process it. You also have the right to ask the SBTi to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where the SBTi may have processed your information unlawfully or where the SBTi are required to erase your personal data to comply with local law. Note, however, that the SBTi 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 the SBTi are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on SBTi legitimate interests). In some cases, the SBTi may demonstrate compelling legitimate grounds to process your information which override your right to object.
• Object any time to the processing of your personal data for direct marketing purposes.
• Request the transfer of your personal data to you or to a third party. The SBTi 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 the SBTi to use or where the SBTi used the information to perform a contract with you.
• Withdraw consent at any time where the SBTi are relying on consent to process your personal data. However, this withdrawal will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, the SBTi may not be able to provide certain products or services to you. The SBTi will advise you if this is the case at the time you withdraw your consent.
• Request restriction of processing of your personal data. This enables you to ask the SBTi to suspend the processing of your personal data in one of the following scenarios:
  • If you want the SBTi to establish the data's accuracy;
  • Where the SBTi’s use of the data is unlawful but you do not want the SBTi to erase it;
  • Where you need the SBTi to hold the data even if the SBTi no longer require the data as you need it to establish, exercise or defend legal claims; or
  • You have objected to the SBTi’s use of your data but the SBTi need to verify whether there are overriding legitimate grounds to use it.

9.2 You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, in special circumstances where there is an unfounded, unnecessarily repetitive or extremely excessive request to access your personal data, the SBTi may charge a reasonable fee. Alternatively, the SBTi could refuse to comply with your request in these circumstances.

9.3 The SBTi may need to request specific information from you to 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. The SBTi may also contact you to ask you for further information in relation to your request to speed up the response.

9.4 The SBTi will try to respond to all legitimate requests within one month of the initial submission. Occasionally it could take longer than a month if your request is particularly complex or you have made a number of requests. In this case, the SBTi will notify you of the specific reason(s) for the delay and keep you updated.

10. CONTACT DETAILS

10.1 If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact the SBTi DPM.

• DPM Email address: SBTI-DPM@sciencebasedtargets.org
• Postal address: First Floor, 10 Queen Street Place, London, England, EC4R 1BE

11. COMPLAINTS

11.1 You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk).

11.2 In order to seek to resolve your concerns before you approach the ICO, please contact the SBTi in the first instance.

12. DUTY TO INFORM THE SBTI OF CHANGES

12.1 It is important that the personal data the SBTi holds about you is accurate and current. Please keep the SBTi informed if your personal data changes during your relationship with the SBTi, for example a new address or email address.

13. THIRD PARTY LINKS

13.1 The SBTi 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. The SBTi do not control these third-party websites and are not responsible for their privacy statements. When you leave the SBTi website, the SBTi encourages you to read the privacy policy of every website you visit.

14. POLICY REVIEW

14.1 This policy will be reviewed a year after being signed, or if there are changes to the applicable laws, whichever comes sooner.

INFORMATION ABOUT OUR USE OF COOKIES

Our website uses cookies to distinguish you from other users of our website. Cookies help us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

This cookie policy describes the cookies we use and explains why we use cookies and how we deal with the information collected. Cookies enable the site to function properly. If you disable the use of cookies you may not experience the full functionality of our website.

This cookie policy (together with our privacy policy) sets out the basis on which any personal information that we collect from you, or that you provide to us, when using this site will be processed. Please read the following carefully to understand how we use cookies.

What are Cookies

Cookies are small text files that are designed to store information on your computer. A cookie file is created when you use our website and is processed by the software of your computer. The resulting text file is placed on your computer and it is accessed by your web browser when you visit the website that originally created the cookie.

For your reference, we set out below the wording we use in our cookie banner:

“We use cookies to improve your experience on our site. By continuing to use our site you accept our use of cookies. Please see our cookie policy and privacy policy for details.”

Types of Cookies

The cookies described below are used to improve our website and do not contain any personal information that would allow us to identify you (such as your name or other contact details).

These are the cookies that may be used during your visit to the website:

Session cookies: these are stored temporarily during a browsing session and are deleted from your device when the browser is closed . They are used to ensure your visit to our website is as smooth as possible and allow us to identify your computer as you use the website.

Persistent cookies: these are saved on your computer for a fixed period (usually one year or more ) and are not deleted when the browser is closed. These help us remember you as a visitor each time you use the same computer to visit the website.

Analytics cookies: these allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to continuously improve the way our website works, for example, by ensuring that users can find what they are looking for easily.

Targeting cookies: these record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our advertisement more relevant to your interests. We may share this information with third parties (like Twitter and LinkedIn) for this purpose.

You can find more information about individual cookies we use and the purposes for which we use them in the table below: