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Data controller Assheton Carter Limited t/a TDi Sustainability (company number 08825320)
Registered office TDi Sustainability | C/O Bishop Fleming LLP, 10 North Place, Cheltenham, United Kingdom, GL50 4DW
Email [email protected]

[email protected]

SECTION 1

Privacy and Cookie Policy | Solar Stewardship Initiative (SSI) Website

Please see SECTION 2 below for the privacy and cookie policy relating specifically to the SSI MEMBER PORTAL.

Introduction

Assheton Carter Ltd (trading as TDi Sustainability) (“we”, “us”, “our”) is committed to protecting personal data and safeguarding the privacy of visitors to the Solar Stewardship Initiative (“SSI”) website accessible at www.solarstewardshipinitiative.org (“Site”). This Privacy Policy outlines how visitors’ personal data is collected, used, disclosed, and protected in relation to the Portal in compliance with applicable data protection and privacy legislation in force from time to time in the United Kingdom, including the General Data Protection Regulation, the Data Protection Act 2018, the Privacy and Electronic Communications Regulations 2003 and other relevant data protection laws as amended from time to time.

Obtaining, Purpose and Use of Information

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

You are not required to provide any personal data on our website. However, you may choose to do so in order to: –

  • contact us or to sign up and/or subscribe to the SSI newsletter or obtain access to our downloadable resources;
  • contact us using the ‘contact us’ form;
  • apply for SSI membership;
  • apply to become an assessment body or assessor; or
  • submit a complaint using the ‘make a complaint’ form.

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:

  • 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.
  • 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 client 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).
  • 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.
  • Contract: 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.

Personal data submitted on this website will be used only for the purposes specified in the relevant part of the website and for any other purposes for which you give your consent. It will not be passed on to other parties.

You may also provide us with personal data during introductions, in-person meetings, phone calls, emails, website interactions, or through other means. For example, you might submit an SSI membership form or complete an Assessment Body or Assessor application. These might be downloaded via our website and returned to us by email, or submitted directly through the website.

While most personal data is directly collected from you, we may also obtain information from publicly accessible sources, websites associated with you or your company, social media platforms such as LinkedIn, or through referrals.

We collect, utilise, and process personal data solely for legitimate purposes that do not harm or prejudice you. These purposes (and our legal basis) include:

  • Provision of services to SSI members, along with relevant information pertaining to these services (based on contract and “legitimate interests” where the data subjects are existing clients or contacts).
  • Maintenance of accurate and up-to-date contact records (based on consent and/ or legitimate interests).
  • Member/Contact relationship management and direct marketing, including newsletters and event notifications, notifications relating to changes in our privacy policy, dealing with your requests, complaints and queries (based on necessity to comply with legal obligations, consent or legitimate interests in order to keep our records updated).
  • To administer and protect our business and this website, including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting data (based on legal obligations and legitimate interests for running our business provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise).
  • To deliver relevant website content to you and measure or understand how you use our website (based on legitimate interests to study how clients use our website, for us to develop it and to inform our marketing strategy).
  • To use data analytics to improve our website and its content, client relationships and experiences and to measure the effectiveness of our communications and marketing (based on legitimate interests to define types of clients, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).
  • To send you relevant marketing communications and make personalized suggestions and recommendations to you about SSI that may be of interest to you (based on legitimate interests to carry out direct marketing, develop our products/services and grow our business).
  • Compliance with legal obligations, as required by law or regulation (based on legal requirement).

Data Collection via Website

Visiting our website (SSI) is generally anonymous, with no activities aimed at personally identifying visitors. However, we may collect, store, and utilize personal data that relates to your website visits and the device used to access it, including:

  • Internet Protocol (IP) address, device identifier, browser type and settings, operating system, platform, and geographical location.
  • Information regarding visitors’ use of our website, such as viewed pages and search terms.
  • Marketing and communications data including your preferences in receiving marketing from us and communication preferences.
  • You can opt out of the collection of this data by ‘declining’ the website cookies.
  • You may also choose to provide personal data when using our website in order to contact us or sign up to our email newsletter for the means outlined above. Personal data submitted on this website will be used only for the purposes specified in the relevant part of the website and for any other purposes for which you give your consent. It will not be passed on to other parties.

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.

Opting out of Marketing

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.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or client service purposes for example relating to SSI memberships or checking that your contact details are correct.

  1. Contact us form

When you use any of the ‘contact us’ forms on this website you are requesting we contact you and providing us with your contact details so that we may do so. When we use your personal data for the purposes of contacting you to respond, we are relying on your consent (which is given when you provide your contact details and invite us to “contact you”).

The information we collect

In order to deal with your request, we may collect some personal data. The  personal data we collect on the ‘Contact us’ forms includes the following:

  • Full name
  • Email address
  • IP address
  • Cookie ID
  • Date and time
  • Specific content such as your messages provided by user which might contain further personal and business data specific to each ‘Contact us’ online form

How we use your data

We process your data to communicate with you and to develop market intelligence. All of the personal data we collect is processed by TDi Sustainability and EPIA SolarPower  AiSBL  and located on TDi Sustainability and EPIA SolarPower Europe AiSBL’s servers. It may be shared with other SSI members solely to respond to your enquiry, and not for other purposes. We will not collect any personal data from you that we do not need to provide and oversee this service to you.

  1. Sign up to newsletter form

By providing your email address to sign up to our newsletter, you agree to the terms of this privacy policy.

When you sign up to receive our newsletter, the data you provide will be used exclusively for this purpose. It will be stored on our database of newsletter recipients.

For an effective registration we need a valid e-mail address. The data will be used exclusively for newsletter distribution and will not be passed on for third parties.

You can unsubscribe from our newsletter at any time by clicking the unsubscribe link in any one of the newsletter communications or sending a written request to [email protected].

  1. Applying for SSI membership

Currently application to the SSI is not done directly through the website – users must download a form and then send it by email to [email protected]. The data collected on this form is then held by the data processor (EPIA SolarPower Europe AiSBL) in accordance with their data protection policy. The data collected includes:

  • Name and address of applicant including full name of legal entity and country of incorporation Telephone number of applicant’s head office
  • Applicant’s website address
  • VAT number for all EU and VAT registered companies
  • Primary contact name
  • Signature (digital)
  • Main company representative name, position, address, telephone, email
  • Main company finance contact name, position, email address, telephone, address
  • Company name and address to be used on invoices
  • Additional contact details for general correspondence – name, position, address, telephone, email
  • Number of employees in applicant organisation
  • All countries of operation for the applicant organisation
  • Organisation description
  • Joining statement
  • Name, position, organisation, date, signature of person completing the form
  • Latest financial statements
  • Company logo

How we use your data

We process your data to communicate with you and to process your membership application. The personal data we collect to as part of your membership application is processed by EPIA SolarPower Europe AiSBL and located on EPIA SolarPower Europe AiSBL’s servers. It may be shared with other SSI members solely to respond to your enquiry, and not for other purposes. We will not collect any personal data from you that we do not need to provide and oversee this service to you.

  1. Make a complaint form

The information we collect

In order to deal with your request, we may collect some personal data. The personal data we collect on the ‘Make a complaint’ form includes the following:

  • Full name
  • Email address
  • IP address
  • Cookie ID
  • Date and time
  • Specific content (‘your message’) provided by user which might contain further personal and business data specific to each ‘Contact us’ online form

How we use your data

We process your data to communicate with you and respond to your complaint. All of the personal data we collect is processed by TDi Sustainability and EPIA SolarPower Europe AiSBL  and located on TDi Sustainability and EPIA SolarPower Europe AiSBL’s  servers. It may be shared with other SSI members solely to respond to your complaint, and not for other purposes. We will not collect any personal data from you that we do not need to provide and oversee this service to you.

Disclosure of your Personal Data 

We may share your personal data where necessary with the parties and for the purposes set out below:

  • EPIA SolarPower Europe AISBL solely to respond to your enquiries and for no other purposes.
  • 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 privacy policy.

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.

International Transfers 

We transfer personal data outside the UK solely to enable our partnership members to respond to your specific enquiries, and for no other reason. Where we transfer the personal data outside the UK and the EEA, we do so ensuring that the appropriate safeguards are in place, in accordance with Data Protection laws.

Confidentiality and Security

We employ appropriate technical and organisational measures to protect personal data both online and offline from unauthorised use, loss, or destruction. Access to personal data is restricted to authorised personnel and third-party service providers, limited to necessity.

We employ industry-standard efforts to maintain data confidentiality, including encryption and firewalls. Reasonable administrative, technical, and physical security controls are in place to prevent data loss, misuse, or alteration.

While we strive to secure information transmitted over the Internet, we cannot guarantee absolute security or immunity from unauthorised access. In the event of a data breach, affected parties will be notified, as required by applicable regulations.

Your Rights

We have a legal obligation to ensure that your information is kept accurate and up to date. Please assist us to comply with this obligation by ensuring that you inform us of any changes. You have the right to request details of the information we hold about you and to delete or rectify any inaccurate information about you by sending a written request to [email protected].

You can unsubscribe from our newsletter at any time by clicking the unsubscribe link in any one of the newsletter communications or sending a written request to [email protected].

Any information collected about you will be used lawfully, in compliance with the Data Protection Act 1998 and the General Data Protection Regulation 2018. Your personal data will not be disclosed, sold, rented, or shared with any external parties beyond TDi Sustainability or EPIA SolarPower Europe AiSBL, which processes data for the SSI Secretariat. Access to your personal data is restricted to authorised employees and contracted service providers, who manage this data solely for the purpose of contacting you based on your preferences.

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

  • 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.
  • 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.
  • 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.
  • 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.
  • You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see Opting Out of Marketing above for details of how to object to receiving direct marketing communications).
  • 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.
  • Withdraw consent at any time where we are relying on consent to process your personal 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.
  • 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.

If you wish to exercise any of the rights set out above please contact us.

No Fee usually Required 

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.

 What we may need from you 

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.

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.

 Data Retention 

We will only retain your personal data for as long as reasonably necessary to fulfill 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.

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.

By law we have to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for six years after they cease being clients for tax purposes.

 Cookies

TDi Sustainability uses cookies on the SSI website for storing session data so we can track our website usage. A cookie does not give us access to your computer or any information about you other than the data you choose to share with us. By using our website, you consent to the use of cookies in accordance with this Privacy Policy, unless you choose to ‘decline’ cookies when prompted.

The cookies used on this website include the following:-

Google Analytics Cookies

We utilize Google Analytics cookies to analyze visitor behavior on our website, aiding in the improvement of navigability. These cookies do not collect personally identifiable information and are not disclosed to third parties. Google Analytics cookies are first-party cookies and can only be accessed by TDi Sustainability, acting as the Project Management Office for SSI.

Contact Details 

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 us in the following ways:

Email address: [email protected]

Concerns or Complaints

If you have concerns regarding our data handling practices or wish to make a complaint you may contact TDi Sustainability at  any time or contact the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to our Privacy Policy

We reserve the right to change this Privacy Policy from time to time to ensure that it complies with current legal requirements or to implement changes to our services in the Privacy Policy Statement, for example, when introducing new services. In this case your further visit will be subject to the new privacy policy. Be sure to check back here periodically for any changes.

This Privacy Policy Statement does not extend to anything that is inherent in the operation of the Internet, and beyond the control of TDi Sustainability or EPIA SolarPower Europe AiSBL, and is not to be applied in any manner contrary to applicable laws, rules or regulations.

Latest update: December 2024

 

 

SECTION 2: SSI MEMBER PORTAL

1 Introduction

Assheton Carter Ltd (trading as TDi Sustainability) (“we”, “us”, “our”) is committed to protecting personal data and safeguarding the privacy of Users (the types of Users are described in Section 2 below) of the Solar Stewardship Initiative (“SSI”) Member Portal accessible at www.solarstewardshipinitiative.org (“Portal”). This Privacy Policy outlines how Users’ personal data is collected, used, disclosed, and protected in relation to the Portal in compliance with applicable data protection and privacy legislation in force from time to time in the United Kingdom, including the General Data Protection Regulation, the Data Protection Act 2018, the Privacy and Electronic Communications Regulations 2003 and other relevant data protection laws as amended from time to time.

Details regarding the processing of personal data in relation to the website are accessible within the Website Privacy and Cookie Policy.

2 Users of the Portal

Users of the Portal (which includes prospective users who have submitted a Portal Registration Form) fall into five categories: (i) Manufacturer Users, (ii) Buyer Users, (iii) Stakeholder Advisory Group Users (the “SAG Users”) which includes both individual SAG Users and organisational SAG Users; (iv) Users of the SSI Board of Directors; and (v) Users of the SSI Secretariat (“Users”, “you”, “your”). Each category of User may be granted access to the Portal upon approval of their registration request by the SSI, and our processor, EPIA Solar Power Europe AiSBL, will assist us with the registration process of Users to the Portal. Once approved, Users may provide personal data to us, share personal data with other Users, or access personal data made available by other Users, subject to the permissions associated with their User registration. By accessing or using the Portal, you acknowledge that you fall within one or more of the categories defined above and that your personal data will be handled in accordance with this Privacy Policy.

3 Obtaining, Purpose and Use of Personal Data

Personal data means any information about an individual from which that person can be identified. We may process different kinds of personal data about Users as follows:

 

  • Identity Data includes first name, last name, any previous names, username or similar identifier, job title, company name and email addresses.
  • Marketing and Communications Data includes Users’ preferences in receiving marketing from us and our third parties.

 

4 Legal Basis

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

  • Performance of a contract with Users: Where we need to perform the contract we are about to enter into or have entered into with Users.
  • Legitimate interests: We may use 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 Users the best and most secure experience. We make sure we consider and balance any potential impact on Users and Users’ rights (both positive and negative) before we process personal data for our legitimate interests. We do not use personal data for activities where our interests are overridden by the impact on Users (unless we have Users’ consent or are otherwise required or permitted to by law).
  • Legal obligation: We may use 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.
  • Consent: We rely on consent only where we have obtained Users’ active agreement to use their personal data for a specified purpose, for example if a User subscribes to our newsletter.

 

5 Purposes for which we will use your personal data

Personal data, either provided by Users or collected by us, in respect of the Portal, will only be used for the purposes outlined in this Privacy Policy or specified in the relevant part of the Portal or for any other purposes for which Users’ give consent. Such personal data will not be disclosed to third parties unless stated in this Privacy Policy.

Users’ personal data may be provided to us during introductions, in-person meetings, phone calls, emails, and other online or offline interactions. For example, to request User access to the Portal, a prospective User must submit a Portal Registration Form. By submitting personal data on the User Registration Form, Users represent and warrant that they have obtained the necessary consent from each individual whose personal data has been provide to us. Such Users agree that such personal data may be processed, collected, stored, and used by us in connection with the relevant User’s Portal account and related services as further outlined in this Privacy Policy.

While most personal data is directly collected from Users, we may also obtain information from publicly accessible sources, websites associated with Users or Users’ companies, social media platforms such as LinkedIn, or through referrals.

We collect, utilise, and process personal data solely for legitimate purposes in relation to the Portal. These purposes (and our legal basis) include:

Purpose/Use Type of Data Legal basis
Assessment of whether or not to grant access to a prospective User to the Portal following submission of a Portal Registration Form; provision of access to the Portal to Users; provision of relevant information pertaining to the above services. (a) Identity Data

 

(a) Performance of a contract.

(b) Necessary for our legitimate interests.

Maintenance of accurate and up-to-date contact records in relation to the Portal. (a) Identity Data

 

(a) Performance of a contract

(b) Necessary for our legitimate interests

(a) Contract relationship management and direct marketing, including newsletters and event notifications, notifications relating to changes in our Privacy Policy.

(b) Dealing with User requests, complaints and queries.

(a) Identity Data

(b) Marketing and Communications Data

 

(a) Performance of a contract

(b) Necessary for our legitimate interests

(c) Having obtained User consent to receiving direct marketing communications, including newsletters and event notifications.

To administer and protect our business and the Portal and the website through which the Portal is accessible, including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting data. (a) Identity Data

(b) Marketing and Communications Data

 

(a) Performance of a contract

(b) Necessary for our legitimate interests for running our business provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise

To deliver relevant content to you and measure or understand how you use the Portal (a) Identity Data

(b) Marketing and Communications Data

 

(a) Performance of a contract

(b) Necessary for our legitimate interests

To use data analytics to improve the Portal and its content, client relationships and experiences and to measure the effectiveness of our communications and marketing (a) Identity Data

(b) Marketing and Communications Data

 

(a) Performance of a contract

(b) Necessary for our legitimate interests for defining types of clients, keeping our Portal updated and relevant, developing our business and informing our marketing strategy

To send Users relevant marketing communications and make personalised suggestions and recommendations about the SSI and/or the Portal that may be of interest to you (a) Identity Data

(b) Marketing and Communications Data

 

Necessary for our legitimate interests (to carry out direct marketing, develop our products/services and grow our business).
Compliance with legal obligations, as required by law or regulation (a) Identity Data

(b) Marketing and Communications Data

 

(a) Performance of a contract

(b) Necessary for our legitimate interests

(c) Compliance with a legal obligation

 

6 Direct Marketing

During the newsletter subscription process on the Portal when Users’ personal data is collected, Users will receive marketing communications from us if they have requested information from us or purchased products or services from us and they have not opted out of receiving marketing communications. We may also analyse Users’ personal data to form a view as to which products, services and offers may be of interest so that we can send Users relevant marketing communications. If you have subscribed to receive the newsletter your personal data will be shared with EPIA Solar Power Europe AiSBL, who is our processor who will send the newsletter to you..

7 Third Party Direct Marketing

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

 

8 Opting out of Marketing or Receiving Newsletters

Users can opt out of marketing communications or newsletters at any time as follows:

  • Marketing Communications:

Click on the opt-out link included in any marketing message or contact us at [email protected].

  • SSI Newsletters:

Click on the unsubscribe link in any newsletter email or contact us at [email protected].

If a User has opted out of receiving marketing communications, they will still receive service-related communications that are essential for the performance of a contract we have with you, or that are required for administrative and/or client-service purposes.

9 Disclosure of Personal Data 

We may share personal data where necessary with third parties and for the purposes set out below:

  • The SSI (whether individuals or companies) for the purpose of responding to User enquiries and reviewing and approving registrations to the Portal.
  • EPIA Solar Power Europe AiSBL, our processor, in relation to the registration process of the Portal and the communication of the newsletter if you have subscribed to receive it.
  • 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 process User personal data in the same way as set out in this Privacy Policy.
  • Third party service providers, such as IT service providers who provide services in relation to the Portal.

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 User personal data for their own purposes and only permit them to process that personal data for specified purposes and in accordance with our instructions.

 

10 International Transfers 

We may transfer personal data outside the UK, as described above, for the purpose of responding to your specific enquiries. Where we transfer personal data outside the UK and the EEA, we do so ensuring that the appropriate safeguards are in place, in accordance with Data Protection laws.

 

11 Confidentiality and Security

We employ appropriate technical and organisational measures in an effort to protect personal data both online and offline from unauthorised use, loss, or destruction. Access to personal data is restricted to authorised personnel and third-party service providers, limited to necessity. We employ industry-standard efforts to maintain data confidentiality, including encryption and firewalls. Reasonable administrative, technical, and physical security controls are in place in an effort to prevent data loss, misuse, or alteration. While we strive to secure information transmitted over the Internet, we cannot guarantee absolute security or immunity from unauthorised access. In the event of a data breach, affected parties will be notified, as required by applicable data protection laws.

 

12 Your Rights

We have a legal obligation to ensure that personal data is kept accurate and up to date. Please assist us to comply with this obligation by ensuring that you inform us of any changes. You have the right to request details of the personal data we hold about you and to delete or rectify any inaccurate information about you by sending a written request to [email protected].

You can unsubscribe from our newsletter at any time by clicking the unsubscribe link in any one of the newsletter communications or sending a written request to  [email protected].

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

  • 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.
  • 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.
  • 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.
  • 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.
  • Object to direct marketing. You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see Opting Out of Marketing above for details of how to object to receiving direct marketing communications).
  • 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.
  • Withdraw consent at any time where we are relying on consent to process your personal 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.
  • 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.

If you wish to exercise any of the rights set out above, please contact us.

 

13 No Fee usually Required 

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 What we may need from you 

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 Data Retention 

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. 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. By law we have to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for six years after they cease being clients for tax purposes.

17 Cookies

For full details on how we use cookies please refer to SECTION 1 ABOVE

18 Contact Details 

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 us in the following ways:

Email address: [email protected]

19 Concerns or Complaints

If you have concerns regarding our personal data handling practices or wish to make a complaint you may contact us at any time or contact the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to resolve concerns before you approach the ICO so please contact us in the first instance.

20 Third-party links

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

21 Changes to our Privacy Policy

We reserve the right to change this Privacy Policy from time to time to ensure that it complies with current legal requirements or to implement changes to our services in the Privacy Policy, for example, when introducing new services. In this case your further visit will be subject to the new Privacy Policy. Be sure to check back here periodically for any changes.

This Privacy Policy does not extend to anything that is inherent in the operation of the Internet, and beyond our control  and is not to be applied in any manner contrary to applicable laws, rules or regulations.

Latest update: 8 DECEMBER 2025

 

SECTION 3: SSI Portal China Privacy Notice Addendum

This SSI Portal China Privacy Notice Addendum (“Addendum“) supplements the information and disclosures contained in the SSI Portal Privacy Policy (“Policy”). This Addendum applies to Users based in mainland China.

Personal Information means information related to identified or identifiable natural persons recorded by electronic or other means, as defined under the China Personal Information Protection Law. Personal Information that, once leaked or illegally used, may easily cause harm to your dignity or grave harm to personal or property security is categorized as Sensitive Personal Information, normally including information on biometric characteristics, religious beliefs, specially-designated status, medical health, financial accounts, and individual whereabouts. We will not collect or process Sensitive Personal Information unless required by applicable laws. Personal Information does not include anonymized information or otherwise exclude from the scope of China personal information protection laws.

Personalized Recommendation

You acknowledge and understand that, we may use your Personal Information to make personalized suggestions and recommendations about the SSI and/or the Portal that may be of interest to you. You can refuse to receive such personalized suggestions and recommendations by contacting us through the method as disclosed in the section of “Contact Details” of the Policy. You also have the right to require us to explain how we use your Personal Information to make personalized suggestions and recommendations and its impact to your personal rights and interests.

Data Transfers

We may transfer your Personal Information to recipients outside of mainland China. Such recipients primarily include our business partners as disclosed under section 9 of the Policy, who will process your Personal Information in accordance with the Policy and this Addendum. If you have any questions regarding such cross-border personal information transfer, you may contact us through the method as disclosed in the section of “Contact Details” of the Policy.

Your Rights and Choices

In addition to the rights disclosed in the section of “12 Your Rights” of the Policy, you can request a copy of your Personal Information, as well as explanation on our Personal Information processing rules.

If you are a close relative of the deceased, unless otherwise arranged by the deceased, you can exercise the rights with respect to the Personal Information of the deceased as set out in this section as well as the section of “12 Your Rights” of the Policy.