Welcome to Mondra’s Privacy Policy. Mondra respects your privacy and is committed to protecting your personal data. This privacy policy explains what kinds of personal data we may hold or process, your privacy rights and how the law protects you.
This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Alternatively, click on the attachment at the bottom of this article to download a pdf version of the policy.
This privacy policy aims to give you information on how Mondra collects and processes your personal data in the course of its work, including through your use of this website. It does not apply to employees, contractors, consultants or workers employed or engaged by Mondra or its group or associated companies. If you fall into one of these categories please contact us to request a copy of our Employee Privacy Notice, which will explain how we process your personal data.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Controller
Mondra Global Limited is the controller and responsible for your personal data (collectively referred to as “Mondra”, "we", "us" or "our" in this privacy policy). Mondra Global Limited is registered as a data controller with the ICO under registration number ZB337713.
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise
Your Legal Rights, please contact the data privacy manager by email to
infosec@mondra.com.
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 chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
2. The data we collect about you
“Personal data”, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We collect personal data from individuals in various ways in the course of our business, as summarised below.
- Website data – We may collect personal data from or about you when you visit our website, including when you:
- complete the contact form on our website;
- sign up for our newsletter; or
- fill out the form on our website to apply for the soil sequestration and reforestation compensation programme;
- Customer data – We may collect personal data about individuals who work for our clients or customers, or potential clients or customers, in the course of our work with those clients or customers.
- Supply chain data – We may collect personal data about individuals who work for organisations within our customers’ supply chains during the course of our work for those customers.
- Supplier data - We may collect personal data from individuals who work for our suppliers, or potential suppliers, in the course of our work with those suppliers.
- Other direct interactions – We may collect personal data from you if you contact us, for example if you were to contact us in connection with a research project or newspaper article.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, job title, name of employer, username or similar identifier.
- Contact Data includes work address, email address and telephone numbers.
- Technical Data includes internet protocol (IP) address, your login data for the Mondra Platform, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Profile Data includes your username and password, your preferences and feedback.
- Usage Data includes information about how you use our website, the Mondra Platform, and our other products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
We may also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
We do not sell your personal data.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity and Contact Data by filling in forms on our website, registering for and using the Mondra platform or by corresponding with us by post, phone, email or otherwise.
- Our customers. Our customers may supply us with Identity and Contact Data for individuals who work for their suppliers, in order to allow us to gather data regarding the supply chain for our customers’ products or services. In turn, those suppliers may provide us with Identity and Contact Data for individuals who work for their own suppliers, and so on.
- 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. Please see our Cookie Policy for further details.
- Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
- search and analytics providers such as Google based outside the UK; and
- publicly available information providers such as LinkedIn and Companies House.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract, we are about to enter into or have entered into with you;
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; or
- Where we need to comply with a legal obligation that we are subject to.
“Legitimate Interest” means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data.
We have set out below, in a table format, a description of all the ways we plan to use 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.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity | Type of Data | Lawful basis for processing including basis of legitimate interest |
To discuss and conclude the
terms of a contract with the organisation for which you work; to perform
services for the organisation for which you work; to gather data from the
organisation for which you work in order to analyse the environmental impact of
products or services | | Necessary
for our legitimate interests in pursuing our business, performing contracts
with our customers and engaging new customers |
To manage our relationship
with you which will include:
(a) notifying you about
changes to our terms or privacy policy
(b) asking you for feedback on our services
| (a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications | (a) Necessary to comply with a
legal obligation
(b) Necessary for our
legitimate interests (to keep our records updated and to study how customers
use our products/services) |
To
administer and protect our business and this website (including
troubleshooting, data analysis, testing, system maintenance, support, reporting
and hosting of data) | (a) Identity
(b) Contact
(c) Technical | (a) 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)
(b) Necessary to comply with a legal obligation |
To
deliver relevant website content to you | (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and
Communications
(f) Technical | Necessary
for our legitimate interests (to study how customers use our products/services,
to develop them, to grow our business and to inform our marketing strategy) |
To
use data analytics to improve our website, products/services, marketing,
customer relationships and experiences | | Necessary
for our legitimate interests (to define types of customers for our products and
services, to keep our website updated and relevant, to develop our business and
to inform our marketing strategy) |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
- Newsletter: You will receive our newsletter from us if you have signed up to receive it on the website, or have otherwise indicated to us that you wish to receive our newsletter.
- Third-party marketing: We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
- Other marketing communications: You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by emailing
infosec@mondra.com.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us for other purposes, such as using the Mondra Platform.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see Mondra's
Cookie Policy.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosure of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table [Purposes for which we will use your personal data] above.
- Other companies in the Mondra Group, acting as joint controllers or data processors, and who are based in Spain, Ukraine and India and provide development, IT support and back office services.
- Service providers based in the UK or the EEA who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
- 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.
6. International Transfers
We may share your personal data within the Mondra Group. This will involve transferring your data outside the UK.
Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data. For further details, see this link to the ICO’s website; or
- Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK. For further details, see this link to the ICO’s website.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
7. Data security
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.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
How long will you use my personal data for?
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.
In some circumstances you can ask us to delete your data: see
Your Legal Rights below for further information.
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.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data, as summarised below.
- Right to request access to your personal data (commonly known as a "data 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.
- Right to 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.
- Right to request erasure of your personal data. 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.
- Right to object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Right to request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in 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.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Right to 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.
- Right to 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.
If you wish to exercise any of the rights set out above, please contact us by email to
infosec@mondra.com.
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.
10. Review of this privacy policy
We may update this privacy notice from time to time as necessary. This version was last updated on 28 April 2023. Historic versions can be obtained by contacting us.