Data Protection Policy & Terms of Use
Midori Sustainability Ltd
Last updated 08/04/2022
Definitions
Company
means Midori Sustainability Ltd, a registered Company.
GDPR
means the General Data Protection Regulation.
Responsible Person
means Kate Chapman.
Register of Systems
means a register of all systems or contexts in which personal data is processed by the Company.
1. Data protection principles
The Company is committed to processing data in accordance with its responsibilities under the GDPR.
Article 5 of the GDPR requires that personal data shall be:
processed lawfully, fairly and in a transparent manner in relation to individuals;
collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
kept in a form that permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to the implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”
2. General provisions
This policy applies to all personal data processed by the Company.
The Responsible Person shall take responsibility for the Company’s ongoing compliance with this policy.
This policy shall be reviewed at least annually.
The Company shall register with the Information Commissioner’s Office as an organisation that processes personal data.
3. Lawful, fair and transparent processing
To ensure its processing of data is lawful, fair and transparent, the Company shall maintain a Register of Systems.
The Register of Systems shall be reviewed at least annually.
Individuals have the right to access their personal data and any such requests made to the Company shall be dealt with in a timely manner.
4. Lawful purposes
All data processed by the Company must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information).
The Company shall note the appropriate lawful basis in the Register of Systems.
Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in the Company’s systems.
5. Data minimisation
The Company shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
[Add considerations relevant to the Company’s particular systems]
6. Accuracy
The Company shall take reasonable steps to ensure personal data is accurate.
Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.
[Add considerations relevant to the Company’s particular systems]
7. Archiving / removal
To ensure that personal data is kept for no longer than necessary, the Company shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
The archiving policy shall consider what data should/must be retained, for how long, and why.
8. Security
The Company shall ensure that personal data is stored securely using modern software that is kept up to date.
Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
When personal data is deleted this should be done safely such that the data is irrecoverable.
Appropriate backup and disaster recovery solutions shall be in place.
9. Breach of Security
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, the Company shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website).
Cookies
Our Cookies Policy forms part of, and is subject to our Terms of Use. Please NOTE: Read above to check our Privacy Policy.
1.2 As with other platforms, we use cookies and similar technologies to help us understand how people use our Platform so that we can continue to improve our Platform.
1.3 With this Cookies Policy, we want to provide you with clear and explicit information about the cookies and technologies we use on our Platform and your choices when it comes to these cookies and technologies.
1.4 If you Use our Platform without blocking or disabling cookies or opting out of other technologies, you are indicating your consent to our use of these cookies and other technologies and to our use (in accordance with this Cookies Policy and our Privacy Policy) of any data and personal data (i.e. data that identifies you, or from which you are identifiable) ("Data") that is yours that we collect using these cookies and technologies. If you do not consent to the use of these cookies and technologies, you will need to block or disable them using your browser settings, the opt-out links identified in this policy, or the settings within our Platform.
1.5 If you choose not to accept Cookies from us or our third parties, or if you accept Cookies but subsequently disable some or all of the Cookies through your browser settings, you won't have access to many features that make your experience with us more efficient and some of our Platform may not function properly.
WHAT ARE COOKIES?
2.1 A cookie is a text file placed on your computer or device when you visit a website by that website's server ("Cookie"). Only that server is able to retrieve or read the contents of that Cookie. Each Cookie is unique to your web browser and contains some anonymous information such as a unique identifier, the site name and some other digits and numbers.
2.2 Cookies can be “persistent” or “session” cookies. Cookies can 'remember' you either for the duration of your visit i.e. they are deleted as soon as you close your browser ("Session Cookie") or for a number of visits i.e. they remain on your computer when you have gone off-line ("Persistent Cookie").
2.3 Session and Persistent Cookies can be either first or third party Cookies. A first party Cookie will be placed on your computer or device by us and a third party Cookie will be placed on your computer or device by a different website (for example, we use Google Analytics to gather anonymised information which we analyse to monitor traffic to our Site).
2.4 To find out more about cookies, including how to see what cookies have been set and how to block and delete cookies, please visit the ICO website.
3. WHY WE USE COOKIES
3.1 We use Cookies to improve your experience of our Site.
3.2 Cookies do many things such as enabling you to navigate between pages efficiently, storing your preferences and making the interaction between you and our Site faster and easier. For example, Cookies enable you to remain logged into our Site – without Cookies, you would have to log into our Site each time you visited it.
3.3 Some websites also use Cookies to enable them to target their advertising or marketing messages based on your location and / or browsing habits.
4. TYPES OF COOKIES WE USE
4.1 We use the following types of Cookies: (a) Security: These Cookies allow us to promote security on our Site, (b) Analytics: We track Site traffic patterns so we can identify popular Site content and potential Site problems, (c) Site features: We measure how visitors use our Site so we can optimise the web pages and use of our Site, and (d) Advertising: We use non-identifiable information about you to show you advertising on our Site.
5. THIRD PARTY COOKIES
5.1 We may include advertising content (graphics, animations, video, etc.) in our broadcast advertising, which may contain Cookies placed by third parties. The placement and the use of Cookies by any such third parties will be subject to the privacy and/or cookies policies of those third parties.
5.2 These Cookies will help the third parties (while the Cookies are valid) to:
5.2.1 1. count the number of display advertising content delivered via our advertising; identify advertisements displayed; count the number of users who clicked on each ad, allowing them to calculate the amounts due and thereby establish statistics; and/or
5.2.2 2. recognise your device at any subsequent browsing of any other site or service on which these advertisers or third parties also place these Cookies and, if necessary, adapt these third party sites and services or advertisements they broadcast to your device.
5.3 Google Analytics
5.3.1 Google Analytics, a web analytics service provided by Google Inc., uses Cookies to gather information about how visitors use our Site.Google Analytics uses its own Cookies, to analyse the use of our Site on our behalf. The information generated by the Cookies about your use of our Site is transmitted to Google. This information is then used for the purpose of compiling statistical reports to enable us to measure and analyse the number of visits to our Site and its pages, the average time spent on our Site and the pages viewed.
5.3.2 For further information about Google Analytics please visit www.google.com/analytics and for details of Google Analytics’ Privacy Policy, please visit http://www.google.com/intl/en)ALL/privacypolicy.html.
5.3.3
5.4 Social buttons
5.4.1 These 'social buttons' are visible on our Site to allow you to share content via social networks, including (but not limited to) Facebook, Twitter, Instagram and Google Plus.Cookies are placed by these platforms on our Site, and allow them to collect information about your browsing.
5.5. These Cookies, emanating from our contracted supplies, test at our request the features of our Site and the performance of user navigation of our site.
6. SIMILAR TECHNOLOGIES
6.1 In addition to cookies, we also use the following standard Internet technologies in connection with your use of the Platform [NOTE: We have set out below these similar technologies by way of example only. Please find out and insert the type of similar technologies you use (or plan to use in the near future), what are they, what do they do, and why do you use them.]:
6.2 Clear GIFs
6.2.1 We use “clear GIFs”, sometimes known as “web bugs”, which are small image files that we embed into our email newsletters. These clear GIFs tell us whether you opened the newsletter, clicked on any of the content or forwarded the newsletter to someone else. This provides us with useful information regarding the effectiveness of our email newsletters, which we can use to ensure that we are delivering information that is relevant to our users.
7. YOUR CHOICES REGARDING COOKIES
7.1 We think it’s important that you are able to control the collection of personal data relating to your use of our Platform, and have therefore made sure that you can opt out of any personal data collection using cookies or other technologies as set out below. (Please note that you cannot opt out of our use of Flash cookies or HTML5 local storage as these are necessary for the technical operation of the platform. However, we do not use these technologies to collect any personal data.) When you sign up to our Site, we will ask you if you will accept Cookies from us or our third parties. If you choose not to accept Cookies from us or our third parties, or if you accept Cookies but subsequently disable some or all of the Cookies through your web browser settings, you won't have access to many features that make your experience more efficient and some of our Site will not function properly.
8. INSTRUCTIONS FOR MANAGING COOKIES
8.1 Introduction: If you have a different browser type or version, please refer to your browser's "Help" menu.
8.2 Internet Explorer 7, 8, and 9: Click on the Tools menu, and then select Internet Options. Click on the Privacy tab. Move the slider to choose your preferred settings. For more specialised cookie settings, click on Sites or Advanced.
8.3 Google Chrome: Click on the Chrome menu, and then select Settings. Click Show advanced settings. Click on Content settings to choose your preferred settings.
8.4 Mozilla Firefox 14, 15 and 16: Click on the Firefox button (or Tools menu), and then select Options. For Mac OS X users, click on the Firefox menu, and then select Preferences. Click on the Privacy panel to choose your preferred settings. For more specialised cookie settings, set 'Firefox will:' to 'Use custom settings for history.'
8.5 Safari 5.1 and Later (Mac OS X): Click on the Safari menu, and then select Preferences. Click on the Privacy tab to display cookie settings. Choose your preferred settings. For more specialised cookie settings, click on Details.
END OF POLICY.