Effective Date: 23 October 2022
(Amended to correct several grammatical errors and to update owner of MailChimp)
1. Who are we?
1.1 We are Carbon Market Pulse Limited registered in England with company number 09194907. We own and operate this website. Please contact us if you have any questions or feedback about this policy. You can write to us at our registered office and trading address:
Carbon Pulse
c/o Field Sullivan
9 Hare & Billet Road
Blackheath
London, UK
SE3 0RB
You can also contact us by email on admin (at) carbon-pulse.com. The Carbon Market Pulse data protection representative is Mike Szabo who can be contacted by email at admin (at) carbon-pulse.com.
1.2 We are registered with the Information Commissioner’s Register of Data Controllers under number ZA168321.
1.3 We are committed to safeguarding your personal data (i.e. information that can identify any living person).
2. What’s the point of this policy?
2.1 This policy tells you how we deal with your personal data. Please read on to find out what kinds of personal data we collect, how we collect it, why we collect it and our legal basis for doing so, how we protect it, to whom we disclose it, your rights in respect of it and how long we keep it.
2.2 Please do not use our website unless you are completely happy with this policy. If you do use our website, we will assume that you do accept it.
3. Might the policy change?
3.1 We may amend the policy in the future and will notify users by posting an alert on our website for 30 days following the update. We will assume you agree to the revised policy if you use the website after the effective date shown at the top of the policy.
4. What personal or other data do we collect?
4.1 We only ever collect the personal data that we need from you and keep to a minimum the personal data we hold on an ongoing basis.
4.2 We collect and store the personal data which you give us via forms on our website – such as your name, address, email address, job title, company, phone numbers, and social media and instant messaging usernames – or when communicating with us by email or in some other way.
4.3 We may receive and store certain information automatically when you interact with us. Examples include the internet protocol (IP) address used to connect your computer to the internet, connection information such as browser type and version, information about your mobile or other device including device-type and device identifier, operating system and platform, a unique reference number linked to the data you enter on our system, login details, clickstream data, details of your activity on our website with date / time stamps including the pages you visited, searches you made and services purchased.
5. How do we use your personal data and what is our legal basis for doing so?
5.1 To provide you with our services, e.g. to send service messages, process payments and/or fulfil orders. Our legal basis for doing so is that it is necessary for the performance of a contract with you.
5.2 To help us communicate with you effectively should you try to contact us via our website. Our legal basis for doing so is that it is necessary because you have asked us to do something prior to entering into a contract.
5.3 To provide you with information about our other services that are similar to those you have already purchased or enquired about. Our legal basis for doing so is that we have a legitimate business interest in contacting you in this way due to your previous purchase or enquiry.
5.4 If you have subscribed to one of our services, we may use your personal data to send you emails (or other communications such as mail, phone or SMS) with details of our or third party goods or services which may be of interest to you including information about special offers or promotions. Where you have subscribed to our services as part of your business requirements then our legal basis is that we have a legitimate business interest in providing direct marketing to you. Where you have subscribed to our services on an individual subscriber basis (unconnected to a business requirement) then our legal basis for doing so is that you have provided your consent.
5.5 To recognize you when you visit or return to our website to track anonymised traffic and usage patterns, to prevent or detect fraud or abuses or to help us improve our website. We may use cookies to do this. See above. Our legal basis for doing so is that we have legitimate business interests in processing your personal data for the stated purposes where there is a minimal impact on your privacy.
5.6 To enable us to use cookies as detailed in the next section. Our legal basis for doing so is that you have provided your consent in response to the pop-up message on our website
5.7 We may remove alter or otherwise use any personal data if we have reason to believe that it breaches our terms and conditions, or that such steps are necessary to protect us or others, or that a criminal act has been committed, or if we are required to do so by law or appropriate authority.
6. What about cookies?
6.1 We and/or third parties use cookies and other tracking technologies on our website. A cookie is an identifier (a small file of letters and numbers) that is sent to your computer. Our website’s functionality will be limited if you configure your browser to reject cookies.
6.2 Cookies are widely used to make websites work, or work more efficiently, as well as to provide information to the website owner or others. Session cookies are temporary cookies that remain in the cookie file of your browser only until your browser is closed. They allow websites to link your actions during a browser session. Persistent cookies stay in the cookie file of your browser for longer (though how long will depend on the lifetime of the specific cookie). For further information on cookies, including how to use your browser to block them and how to delete cookies already stored on your device, visit: www.allaboutcookies.org.
6.3 Cookies are used on this website for the following purposes:
a) Session cookies: We use session cookies to enable the website to keep track of your movement from page to page and store your selections so you do not get asked repeatedly for the same information. These cookies allow you to proceed through many pages of the website quickly and easily without having to authenticate or reprocess each new area you visit.
b) WordPress cookies: WordPress places persistent cookies (up to one year) to remember you when you return to the site, to verify details of your logged-in status, to customize your view of our interfaces and to avoid visitors who make repeat comments having to re-enter their details. Click here for more information.
c) Google cookies: Persistent cookies (up to four years we believe) are set in connection with the following Google services on our site and these cookies may involve certain non-personally identifying information being sent to Google:
d) Google Analytics (“GA”): We use cookies to recognise and count the number of website visitors as well as providing other information about the visit such as duration, route through the website and what sites the visitor came from. This information helps us to improve the way our website works, for example by making sure users find what they need easily.
More information and opt out: Click here for Google’s privacy policy and here for more information about the kinds of cookies placed by Google. Click here for information about how Google uses data from its partners’ sites or apps as well as how to opt out of Google cookies.
7. How do we protect personal data?
7.1 Security is a high priority for us. We take appropriate technical and organisational precautions to protect your personal data.
7.2 Email and other electronic communications are not secure if they have not been encrypted. Your communications will pass through a number of network nodes before they reach us, so we do not accept responsibility for any unauthorised access to or loss of personal data that stems from a cause beyond our control, nor can we be held responsible for the actions or omissions of other users or third parties who may misuse your personal data which they collect from the website.
8. To whom do we disclose personal data?
8.1 Payment details including credit card numbers are supplied direct to our payment partner mentioned on our website. We do not receive such information. To ensure your details are not being used without consent, your personal data may be supplied by our payment partners to relevant third parties including credit reference and fraud prevention agencies, who may keep a record of that information.
8.2 We may allow access to your personal data by third parties who supply us with a service. These include the following:
a) Salesforce.com (hosting of customer relationship management system)
b) Inuit Inc. (MailChimp – for sending of emails)
c) Our contractor who supports our operational activities;
d) Our e-commerce platform providers;
e) Our website hosts and monitoring providers;
f) Our content delivery networks provider;
g) Our provider who assists us in undertaking communications.
Our selected third parties are required by us to treat your personal data as carefully as we would and can only act on our instructions with regards to their use of your personal data.
8.3 Very important: Your real name will be shown in conjunction with any comments which you post on the site, and information including your company, city, state/province/region, country, Twitter and Yahoo! Messenger handles will be visible to other subscribers on your profile page unless you remove or decline to enter that information from your profile.
8.4 We may disclose personal data so far as reasonably necessary:
a) if we have reason to believe that it breaches our terms and conditions, or that such steps are necessary to protect us or others, or that a criminal act has been committed, or if there has been a complaint about content posted by you, or if we are required to do so by law or appropriate authority; or
b) in the case of an actual or proposed (including negotiations for a) sale or merger or business combination involving all or the relevant part of our business to the prospective seller or buyer.
8.5 Except as otherwise specifically included in this policy, this document addresses only the use and disclosure of information we collect from you. If you disclose your information to third parties, whether they are suppliers of services on our website (e.g. payment providers) or other websites, different rules will apply to their use or disclosure of your information. Please check their privacy policies carefully.
We will never sell your personal data and will never share it with a company for marketing purposes.
9. What are my rights in respect of my personal data?
9.1 You have the following rights in respect of your personal data:
a) to withdraw your consent at any time. You can do this by clicking unsubscribe on any email we send to you and deleting your Carbon Pulse account;
b) to object to us processing your personal data for direct marketing purposes;
c) to obtain a copy of your personal data which we hold about you.
d) the right in certain circumstances to:
- Have your personal data erased
- Restrict processing of your personal data
- Object to the processing of your personal data
- Have your personal data transferred to a third party
If you wish to withdraw your consent, then please follow the steps as outlined in a) above.
If you wish to exercise any of your other rights listed in this policy, or that you have in law, then please contact our data protection representative Mike Szabo at admin (at) carbon-pulse.com.
If you have an issue or a complaint arising under this policy, then in the first instance please contact our data protection representative Mike Szabo at admin (at) carbon-pulse.com.
If you are not satisfied with our handling of your issue or complaint then you have the right to lodge a complaint with the Information Commissioner’s Office (https://ico.org.uk/concerns/)
10. Storing and keeping your personal data
The data that we collect from you will primarily be processed and stored within the European Economic Area (EEA). The following third parties host your personal data on our behalf outside of the EEA:
a) Intiut Inc. (MailChimp) – host in the US
However, we have put in place adequate contractual safeguards in the form of a Data Processing Addendum to our Agreement with Intuit Inc. to protect your personal data in this situation.
We retain personal data from closed accounts for 10 years in order to comply with legal obligations, enforce our terms and conditions, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations and take other actions as permitted by law.
When we no longer need to keep your personal data, we undertake to delete it and dispose of it securely.
11. Governing law and jurisdiction
11.1 For business customers. This privacy policy, its subject matter and its formation (and any non-contractual disputes or claims) are governed by English law. We both agree to the exclusive jurisdiction of the courts of England.
11.2 For consumer customers. This privacy policy, its subject matter and its formation are governed by English law. You and we both agree that the courts of England will have non-exclusive jurisdiction. However, if you are a resident of Northern Ireland you may also bring proceedings in Northern Ireland, and if you are a resident of Scotland, you may also bring proceedings in Scotland.
Version 5.0 – 23 October 2022
