Privacy Policy

(A) This Policy

This policy explains how we process personal data and is issued by each of the Controller and Processor entities which are part of the group of companies headed by EcoOnline AS (“Group Companies” as defined at Section R) (together, “EcoOnline”, “we”, “us” and “our”) and is addressed to individuals outside our organisation with whom we interact, including visitors to our Sites, users of our Applications (Section R), other users of our services, personnel of corporate customers and vendors, applicants for employment and visitors to our premises (together, “you”). Defined terms used in this policy are explained in Section R below. 

This policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law. We encourage you to read this policy carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this policy. 

(B) Collection of Personal Data

We collect or obtain Personal Data: when data is provided to us (e.g., where you contact us); in the course of our relationship with you (e.g., if you make a purchase); when you make Personal Data public (e.g., if you make a public post about us on social media); when you download, install, or use any of our Apps; when you visit our Sites; when you register to use any of our Sites, Apps, or services; or when you interact with any third-party content or advertising on a Site. We may also receive Personal Data about you from third parties (e.g., law enforcement authorities, screening providers, business partners). 

EcoOnline as Data Controller 

Collection of Personal Data: We collect or obtain Personal Data about you from the following sources: 

EcoOnline as Data Processor

Collection of Personal Data: We collect or obtain Personal Data about you from the following sources: 

(C) Creation of Personal Data

We create Personal Data about you (e.g., records of your interactions with us). 

We also create Personal Data about you in certain circumstances, such as details of your past interactions with us. We may also combine Personal Data from any of our Sites, Apps, or services, including where that data is collected from different devices.

(D) Categories of Personal Data we Process

We Process: your personal details (e.g., your name); demographic data (e.g., your age); your contact details (e.g., your address); records of your consents; purchase details; payment details (e.g., your billing address); information about our Sites and Apps (e.g., the type of device you are using); details of your employer (where relevant); information about your interactions with our content or advertising; and any views or opinions you provide to us. 

EcoOnline as Data Controller

We may Process the following categories of Personal Data about you: 

• Personal details: given name(s); preferred name; and photograph.
• Demographic information: gender; date of birth / age; nationality; salutation; title; and language preferences.
• Contact details: correspondence address; shipping address; telephone number; email address; details of Personal Assistants, where applicable; messenger app details; online messaging details; and social media details.
• Expertise: records of your expertise, professional history, practising details and qualification details, information about your experience, participation in meetings, seminars, advisory boards and conferences, information about your professional relationship with other individuals or institutions, language abilities and other professional skills;
• Consent records: records of any consents you have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent).
• Purchase details: records of purchases and prices; consignee name, address, contact telephone number and email address;
• Payment details: invoice records; payment records; billing address; payment method; bank account number or credit card number; cardholder or account holder name; card or account security details; card ‘valid from’ date; card expiry date; BACS details; SWIFT details; IBAN details; payment amount; payment date; and records of cheques. 
• Data relating to our Sites and Apps: device type; operating system; browser type; browser settings; IP address; language settings; dates and times of connecting to a Site; App usage statistics; App settings; dates and times of connecting to an App; location data, and other technical communications information (some of which may constitute Personal Data); username; password; security login details; usage data; aggregate statistical information.
• Employer details: where you interact with us in your capacity as an employee of a third-party, the name, address, telephone number and email address of your employer, to the extent relevant.
• Content and advertising data: records of your interactions with our online advertising and content, records of advertising and content displayed on pages displayed to you, and any interaction you may have had with such content or advertising (e.g., mouse hover, mouse clicks, any forms you complete in whole or in part) and any touchscreen interactions.
• Views and opinions: any views and opinions that you choose to send to us, or publicly post about us on social media platforms.

EcoOnline as Data Processor

The category of Personal Data we may Process about you will depend upon the nature of your interaction with us. It may include any of the following: 

Name, email address, address, phone number, personnel number, age, office location, company/department, job title, overview of personnel actions regarding registered incidents, workplace accidents and illnesses, IP address, device type, OS version, app version, usage history, metadata, SSN (if exposure module is used), contract data, connection data, grades and evaluation reports, text, audio, video, or image files, metadata, uploaded documentation, certificates. 

(E) Sensitive Personal Data

As a Data Controller, EcoOnline Processes Sensitive Personal Data in a very limited number of situations, most typically in relation to our Anti-Bribery and Corruption, and Trade Controls screening procedures. Our screening activities might reveal information about our corporate clients’ executives’ and people in management or board positions’ criminal records (e.g., if they have been put on international sanctions lists or have been mentioned by the press). 

As a Data Processor, EcoOnline Processes Sensitive Personal Data also only in a very limited number of situations, typically in relation to particular modules within our EHS offering. 

In general, where we need to Process Sensitive Personal Data for a legitimate purpose, we do so in accordance with applicable law. 

As a Data Processor, we generally only Process Sensitive Personal Data in relation to particular modules of our EHS offering. As a Data Controller, and where it becomes necessary to Process your Sensitive Personal Data for any reason, we rely on one of the following legal bases: 

• Compliance with applicable law: We may Process your Sensitive Personal Data where the Processing is required or permitted by applicable law (e.g., to comply with our diversity reporting obligations);
• Detection and prevention of crime: We may Process your Sensitive Personal Data where the Processing is necessary for the detection or prevention of crime (e.g., the prevention of fraud);
• Establishment, exercise or defence of legal claims: We may Process your Sensitive Personal Data where the Processing is necessary for the establishment, exercise or defence of legal claims; or
• Consent: We may Process your Sensitive Personal Data where we have, in accordance with applicable law, obtained your express consent prior to Processing your Sensitive Personal Data (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

If you provide Sensitive Personal Data to us, you must ensure that it is lawful for you to disclose such data to us, and you must ensure a valid legal basis applies to the Processing of that Sensitive Personal Data. 

(F) Purposes of Processing and legal bases for Processing

Summary – Purposes of Processing and legal bases for Processing

We Process Personal Data for the following purposes: providing our Sites, Apps, and services to you; compliance checks; operating our business; communicating with you; managing our IT systems; health and safety; financial management; conducting surveys; ensuring the security of our premises and systems; conducting investigations where necessary; compliance with applicable law; improving our Sites, Apps, and services; fraud prevention; establishment, exercise and defence of legal claims; and recruitment and job applications. 

EcoOnline as Data Controller

The purposes for which we Process Personal Data, subject to applicable law, and the legal bases on which we perform such Processing, are as follows: 

EcoOnline as Data Processor

EcoOnline as Data Processor does not have its own legal basis for processing personal data in the provision of products and services to our clients (the Data Controllers). For the provision of products and services to our clients, we process the personal data only on the documented instructions of the relevant client. 

(G) Disclosure of Personal Data to third parties

Summary – Disclosure of Personal Data to third parties

We disclose Personal Data to: legal and regulatory authorities; our external advisors; our Processors; any party as necessary in connection with legal proceedings; any party as necessary for investigating, detecting or preventing criminal offences; any purchaser of our business; and any third-party providers of advertising, plugins or content used on our Sites or our Apps. 

We disclose Personal Data to other entities within the EcoOnline group, for legitimate business purposes and the operation of our Sites, Apps, or services to you, in accordance with applicable law. 

In addition, EcoOnline may also disclose personal data to:

• you and, where appropriate, your appointed representatives;
• legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;
• accountants, auditors, consultants, lawyers and other outside professional advisors to EcoOnline, subject to binding contractual obligations of confidentiality;
• any relevant party, regulatory body, governmental authority, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal claims;
• any relevant party, regulatory body, governmental authority, law enforcement agency or court, for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties; and
• any relevant third-party acquirer(s) or successor(s) in title, in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation).

If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law. 

Please find the list of Processors and Subprocessors engaged by EcoOnline here: Sub-processors | EcoOnline.

(H) Profiling

Personal Data is not subject to automated decision-making and Profiling.

(I) International transfer of Personal Data

We transfer Personal Data to recipients in other countries. Where we transfer Personal Data from the United Kingdom and/or the EEA to a recipient outside the United Kingdom/EEA that is not in an Adequate Jurisdiction, we do so on the basis of an International Data Transfer Agreement or Standard Contractual Clauses. 

Because of the international nature of our business, we transfer Personal Data within the EcoOnline group, and to third parties as noted in Section (G) above, in connection with the purposes set out in this policy. For this reason, we transfer Personal Data to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located. 

If an exemption or derogation applies (e.g., where a transfer is necessary to establish, exercise or defend a legal claim) we may rely on that exemption or derogation, as appropriate. Where no exemption or derogation applies, and we transfer your Personal Data from the United Kingdom or the EEA to recipients located outside the United Kingdom/EEA who are not in Adequate Jurisdictions, we do so on the basis of an International Data Transfer Agreement or Standard Contractual Clauses. You are entitled to request a copy of our International Data Transfer Agreement and Standard Contractual Clauses using the contact details provided in Section (Q) below. 

Please note that when you transfer any Personal Data directly to an EcoOnline entity established outside the United Kingdom and the EEA, we are not responsible for that transfer of your Personal Data. We will nevertheless Process your Personal Data, from the point at which we receive those data, in accordance with the provisions of this policy. 

(J) Data security

We implement appropriate technical and organizational security measures to protect your Personal Data. Please ensure that any Personal Data that you send to us is sent securely. 

We have implemented appropriate technical and organizational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of Processing, in accordance with applicable law. 

Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your Personal Data, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk, and you are responsible for ensuring that any Personal Data that you send to us is sent securely. Personal Data that you send to us is sent securely.

(K) Data accuracy

We take every reasonable step to ensure that your Personal Data is kept accurate and up-to-date and is erased or rectified if we become aware of inaccuracies.

We take every reasonable step to ensure that:

• your Personal Data that we Process is accurate and, where necessary, kept up to date; and
• any of your Personal Data that we Process that is inaccurate (having regard to the purposes for which it is Processed) is erased or rectified without delay.

From time to time, we may ask you to confirm the accuracy of your Personal Data.

As a Data Processor, we support our clients in updating personal data in our systems and applications when requested either manually or, where possible, through automated means such as synchronization. 

(L) Data minimization

We take every reasonable step to limit the volume of your Personal Data that we Process to what is necessary. 

We take every reasonable step to ensure that your Personal Data that we Process is limited to the Personal Data reasonably necessary in connection with the purposes set out in this policy. 

(M) Data retention

We take every reasonable step to ensure that your Personal Data is only retained for as long as it is needed in connection with a lawful purpose. 

We take every reasonable step to ensure that your Personal Data is only Processed for the minimum period necessary for the purposes set out in this policy. The criteria for determining the duration for which we will retain your Personal Data is as follows: 

1)    we will retain Personal Data in a form that permits identification only for as long as:

• your Personal Data is necessary in connection with the lawful purposes set out in this policy, for which we have a valid legal basis (e.g., where your personal data is included in a contract between us and your employer, and we have a legitimate interest in processing that data for the purposes of operating our business and fulfilling our obligations under that contract; or where we have a legal obligation to retain your Personal Data),
• we maintain an ongoing relationship with you (e.g., where you are a user of our services, or you are lawfully included in our mailing list and have not unsubscribed); or

Plus:

2)    the duration of:

• any applicable limitation period under applicable law (i.e., any period during which any person could bring a legal claim against us in connection with your Personal Data, or to which your Personal Data is relevant); and
• an additional twelve (12) month period following the end of such applicable limitation period (so that, if a person brings a claim at the end of the limitation period, we are still afforded a reasonable amount of time in which to identify any Personal Data that is relevant to that claim),

and:

2)    in addition, if any relevant legal claims are brought, we continue to Process Personal Data for such additional periods as are necessary in connection with that claim.

During the periods noted in paragraphs (2)(a) and (2)(b) above, we will restrict our Processing of your Personal Data to storage of, and maintaining the security of, that data, except to the extent that that data needs to be reviewed in connection with any legal claim, or any obligation under applicable law.

Once the periods in paragraphs (1), (2) and (3) above, each to the extent applicable, have concluded, we will either:

• permanently delete or destroy the relevant Personal Data; or
• anonymize the relevant Personal Data.

(N) Your legal rights

Subject to applicable law, you may have a number of rights, including: the right not to provide your Personal Data to us; the right of access to your Personal Data; the right to request rectification of inaccuracies; the right to request the erasure, or restriction of Processing, of your Personal Data; the right to object to the Processing of your Personal Data; the right to have your Personal Data transferred to another Controller; the right to withdraw consent; and the right to lodge complaints with Data Protection Authorities. In some cases it will be necessary to provide evidence of your identity before we can give effect to these rights.

Subject to applicable law, you may have the following rights regarding the Processing of your Relevant Personal Data:

• the right not to provide your Personal Data to us (however, please note that we will be unable to provide you with the full benefit of our Sites, Apps, or services, if you do not provide us with your Personal Data – e.g., we might not be able to process your requests without the necessary details); 
• the right to request access to, or copies of, your Relevant Personal Data, together with information regarding the nature, Processing and disclosure of that Relevant Personal Data;
• the right to request rectification of any inaccuracies in your Relevant Personal Data;
• the right to request, on legitimate grounds:
  • erasure of your Relevant Personal Data; or
  • restriction of Processing of your Relevant Personal Data;
• the right to have certain Relevant Personal Data transferred to another Controller, in a structured, commonly used and machine-readable format, to the extent applicable;
• where we Process your Relevant Personal Data on the basis of your consent, the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the Processing of your Personal Data in reliance upon any other available legal bases); and
• the right to lodge complaints regarding the Processing of your Relevant Personal Data with a Data Protection Authority (in particular, the Information Commissioner’s Office in the United Kingdom and the Data Protection Authority of the EU Member State in which you live, or in which you work, or in which the alleged infringement occurred, each if applicable).

Subject to applicable law, you may also have the following additional rights regarding the Processing of your Relevant Personal Data:

• the right to object, on grounds relating to your particular situation, to the Processing of your Relevant Personal Data by us or on our behalf, where such processing is based on Articles 6(1)(e) (public interest) or 6(1)(f) (legitimate interests) of the GDPR; and
• the right to object to the Processing of your Relevant Personal Data by us or on our behalf for direct marketing purposes.

This does not affect your statutory rights.

To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Notice, or about our Processing of your Personal Data, please use the contact details provided in Section (Q) below. Please note that:

• in some cases it will be necessary to provide evidence of your identity before we can give effect to these rights; and
• where your request requires the establishment of additional facts (e.g., a determination of whether any Processing is non-compliant with applicable law) we will investigate your request reasonably promptly, before deciding what action to take.

(O) Cookies and similar technologies

We Process Personal Data by using Cookies and similar technologies. For more information, please see our Cookie Policy.

When you visit a Site we will typically place Cookies onto your device, or read Cookies already on your device, subject always to obtaining your consent, where required, in accordance with applicable law. We use Cookies to record information about your device, your browser and, in some cases, your preferences and browsing habits. We Process Personal Data through Cookies and similar technologies, in accordance with our Cookie Policy here: Cookie Policy | EcoOnline.

(P) Direct marketing

We Process Personal Data to contact you with information regarding Sites, Apps, or services that may be of interest to you. You may unsubscribe for free at any time. 

We Process Personal Data to contact you via email, telephone, direct mail, or other communication formats to provide you with information regarding Sites, Apps, or services that may be of interest to you. We also Process Personal Data for the purposes of displaying content tailored to your use of our Sites, Apps, or services. If we provide Sites, Apps, or services to you, we may send or display information to you regarding our Sites, Apps, or services, upcoming promotions and other information that may be of interest to you, including by using the contact details that you have provided to us, or any other appropriate means, subject always to obtaining your prior opt-in consent to the extent required under applicable law. 

You may unsubscribe from our promotional email list at any time by simply clicking on the unsubscribe link included in every promotional electronic communication we send. Please note that it may take up to 2 weeks to process your unsubscribe request during which time you may continue to receive communications from us. After you unsubscribe, we will not send you further promotional emails, but in some circumstances, we will continue to contact you to the extent necessary for the purposes of any Sites, Apps, or services you have requested. 

(Q) Contact Details

In relation to any queries arising out of this privacy policy, please contact EcoOnline’s Data Protection Officer: [email protected].

(R) Definitions

• “App/Applications” means any application made available by us (including where we make such applications available via third-party stores or marketplaces, or by any other means), including:

• “Adequate Jurisdiction” means a jurisdiction that has been formally designated by the United Kingdom and/or the European Commission (as applicable) as providing an adequate level of protection for Personal Data.
• “Cookie” means a small file that is placed on your device when you visit a website (including our Sites). In this policy, a reference to a “Cookie” includes analogous technologies such as web beacons and clear GIFs.
• “Controller” means the entity that decides how and why Personal Data is Processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws.
• “Data Protection Authority” means an independent public authority that is legally tasked with overseeing compliance with applicable data protection laws.
• “EEA” means the European Economic Area.
• “GDPR” means the General Data Protection Regulation (EU) 2016/679.
• “Group Companies” means any direct or indirect subsidiary or any direct or indirect holding company or any such subsidiary of any such holding company or any such holding company of such subsidiary, “subsidiary” and “holding company” having the meanings defined in Section 1159 of the Companies Act 2006 as amended from time to time, including:

• “International Data Transfer Agreement” means the agreement issued by the Information Commissioner under section 119A(1) of the Data Protection Act 2018.
• “Personal Data” means information that is about any individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.
• “Process”, “Processing” or “Processed” means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
• “Processor” means any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller).
• “Profiling” means any form of automated Processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
• “Relevant Personal Data” means Personal Data in respect of which we are the Controller.
• “Sensitive Personal Data” means Personal Data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, national identification number, or any other information that is deemed to be sensitive under applicable law.
• “Standard Contractual Clauses” means template transfer clauses adopted by the European Commission or adopted by a Data Protection Authority and approved by the European Commission.
• “Site” means any website operated, or maintained, by us or on our behalf.