Privacy Policy

The Trade Integrity Project (“TIP”, “we”, “us” or “our””) is committed to transparency in protecting the personal data and information of its users.

Please read this Privacy Policy (the “Policy”) for information and your rights on how TIP processes your personal data and information by the Open-Source Centre Limited, Company number 15670158 of registered office address: 167-169 Great Portland Street, London, England, W1W 5PF. This Privacy Policy describes our practices in connection with information that we collect through:

1. The website we operate, www.trade-integrity.org, and any other TIP-affiliated website from which you are accessing this Privacy Policy (the “Website”).
2. Our social media pages that we control (collectively, our “Social Media Pages”), from which you are accessing this Privacy Policy.
3. HTML-formatted email messages that we send to you that link to this Privacy Policy or other communications with you.

You acknowledge that through your continued use and access of the Website, you agree that you have read and understood this Policy and all terms and conditions that relate to the Website.

1. Interpretation

The following definitions and rules of interpretation apply in this policy.

1.1 Definitions:

Applicable Legislation: means all applicable laws, statutes, regulations and codes, including Data Protection Legislation, from time to time in force.

Pixel Tags: Pixel Tags and other similar technologies means the web beacons and clear Graphics Interchange Format (“GIF”).

Services: means the provision of information, Sub-Analysis services and data through our Website or any social media pages that we control, including HTML-formatted email messages, communications, and downloadable content and data through the Website.

User: means any user of the Website or the Services.

2. Important information, who we are and types of information we collect

2.1 Our Services are not designed for, or intentionally targeted at, children 13 years of age or younger. We do not intentionally collect or maintain data about anyone under the age of 13.

2.2 Personal data means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

1. Identity Data includes first name, last name, any previous names, username or similar identifier, marital status, title, date of birth and gender.
2. Contact Data includes email address and telephone numbers.
3. 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 this website.
4. Social Media Data includes details about social networks, platforms and linked accounts.
5. Usage Data includes information about how you interact with and use our Website and Services
6. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

2.3 We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Usage Data to calculate the percentage of users accessing a specific website feature to analyse general trends in how users are interacting with our website to help improve the website and our Services.

3. How is your personal data collected?

3.1 We use different methods to collect data from and about you including through:

1. Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

   1. subscribe to our service or publications;
   2. if you choose to attend or take part in a TIP-hosted event or workshops;
   3. request marketing to be sent to you; or
   4. give us feedback or contact us.
2. Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

3. Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

   1. Technical Data is collected from the following parties:

      • analytics providers such as Google based outside the UK;
      • advertising networks; or
      • search information providers.
   2. Identity and Contact Data is collected from publicly available sources such as Companies House and the Electoral Register based inside the UK.
   3. Social Media information is collected when you access the Website via a third-party service such as, but not limited to, Google, Microsoft, Facebook, Apple, RIM, or other app developer, app provider, wireless service provider, or device manufacture, where we receive information from that service provider. This includes your email address, name and data you supply to us in connection with your use of the Website or with respect to any personal data you disclose to other organisations through or in connection with our Services.

4. Legal basis for how we use your personal data

4.1 The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

1. Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
2. Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
3. Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
4. Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter or attend a TIP-hosted event.

5. Purposes for which we will use your personal data

5.1 We have set out below, in a table format, a description of the ways we may to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/Use

Providing the functionality of the Website and Services and fulfilling your requests

Purpose/Use

Purpose/Use

To administer and protect our business and the Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Purpose/Use

To deliver relevant Website content and online advertisements, third-party advertisements, including the use of Pixel Tags to you and measure or understand the effectiveness of the advertising we serve to you.

Purpose/Use

To use data analytics to improve our Website, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing.

Purpose/Use

To send you relevant marketing communications and make personalised suggestions and recommendations to you about goods or services that may be of interest to you based on your Contact Data.

Purpose/Use

To maintain appropriate business records and comply with all Applicable Laws and regulations.

5.2 We need to collect personal data in order to provide the Services to you. If you do not provide the information requested, we may not be able to provide the Services.

5.3 If you disclose any personal data relating to other people to TIP or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

6. Direct marketing

6.1 You will receive marketing communications from us if you have requested information from us or signed up to our newsletter for more information and if you have not opted out of receiving the marketing.

6.2 We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which, services and offers may be of interest to you so that we can then send you relevant marketing communications.

6.3 We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

6.4 You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us at contact@tradeintegrityproject.org.

6.5 If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes such as updates to our Terms of Service, checking that your contact details are correct.

7. Disclosures of your personal data

7.1 We may share your personal data where necessary with the parties set out below for the purposes set out in the table above.

1. Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Policy.
2. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our 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 our instructions.

8. Third-party advertising

8.1 On some of our Services, we may use third-party advertising companies to serve advertisements regarding services that may be of interest to you when you access and use the Services and other websites or online services.

8.2 You may receive advertisements based on information relating to your access to and use of the Services and other websites or online services on any of your devices, as well as on information received from third parties. These companies place or recognize a unique cookie on your browser (including through the use of pixel tags). They also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop. If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this Privacy Policy, please visit http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/#/.

9. International transfers

9.1 We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law.

9.2 Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:

1. We will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data, namely, EEA and where applicable, United States-based companies that have opted in to the EU-US Data Privacy Framework.
2. We may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the International Data Transfer Agreement. To obtain a copy of these contractual safeguards, please contact us at the contact details in paragraph 16.

10. Data security

10.1 We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit 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 our instructions, and they are subject to a duty of confidentiality.

10.2 Unless we request it, we ask that you do not send us, and you not disclose, any special category data (e.g. your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health or sexual orientation, on or through the Services or otherwise to us.

11. Data retention

11.1 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.

11.2 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.

11.3 In some circumstances you can ask us to delete your data: see paragraph 12 below for further information.

11.4 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.

12. Your legal rights

12.1 You have a number of rights under data protection laws in relation to your personal data.

12.2 You have the right to:

1. Request access to your personal data (commonly known as a “subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
3. Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we 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.
4. Object to processing of your personal data where we 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 our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
5. You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes.
6. Request the transfer of your personal data to you or to a third party. We 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 us to use or where we used the information to perform a contract with you.
7. Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 4 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

8. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:

   • If you want us to establish the data’s accuracy;
   • Where our use of the data is unlawful but you do not want us to erase it;
   • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
   • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
9. If you wish to exercise any of the rights set out above, please contact us on the Contact details outlined in paragraph 16.

Fees

Generally, you will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

14. Further information

We may need to request specific information from you to help us 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. We may also contact you to ask you for further information in relation to your request to speed up our response.

15. Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

16. Contact us

If you have any questions about this Policy or about the use of your personal data or you would like to exercise your privacy rights, please contact us in the following ways:

1. Email address: contact@tradeintegrityproject.org; and
2. Postal address: 167-169 Great Portland Street, London, England, W1W 5PF.

17. Complaints

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). We would, however, appreciate the opportunity to deal with your concerns before you approach the ICO so please contact us in the first instance.

18. Changes and updates

18.1 We keep our Policy under regular review. Any changes to this Policy will be indicated by the ‘last updated’ date at the top of this page. Any changes and updates will apply to you and your data immediately.

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