1 ABOUT THIS NOTICE
1.1 SEI Oxford Office Ltd is committed to protecting the privacy and security of your personal information.
1.2 This privacy policy describes how we collect and use personal information about you in accordance with data protection law. Please read it carefully.
1.3 Data protection law says that the personal information we hold about you must be:
1.3.1 used lawfully, fairly and in a transparent way;
1.3.2 collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
1.3.3 relevant to the purposes we have told you about and limited only to those purposes;
1.3.4 accurate and kept up to date;
1.3.5 kept only as long as necessary for the purposes we have told you about;
1.3.6 kept securely.
1.4 If you have any questions about this notice or how we collect and use personal information about you please contact us.
2 INFORMATION ABOUT US
2.1 We are SEI Oxford Office Ltd a limited company registered in England and Wales under company number 04404220 and have our registered office at Oxford Eco Centre Roger House, Osney Mead, Oxford, Oxfordshire, England, OX2 0ES.
2.2 We operate the www.weadapt.org platform; and the microsites (together the “website”). A list of our microsites covered by these terms is available at https://www.weadapt.org/microsites.
2.3 We operate the website on behalf of the “Stockholm Environment Institute” which is comprised of the following legal entities:
2.1 Stiftelsen The Stockholm Environment Institute (SEI), Stockholm, Sweden (including SEI HQ, SEI Asia, SEI Africa, SEI Latin America);
2.2 SEI Oxford Office Ltd, UK
2.3 SEI US, United States; and
2.4 SEI Tallinn, The Estonian Institute for Sustainable Development, Estonia.
2.5 We can be contacted at [email protected]
3 PRIVACY POLICY
3.1 Our privacy policy is primarily drafted to take account of the principles of the EU General Data Protection Regulation and the United Kingdom’s data protection legislation (including UK GDPR).
3.2 Where you reside in countries outside of the EU or the United Kingdom different data protection and privacy laws may apply to you. Where this is the case, we have included an Appendix to this privacy policy outlines any additional provisions which may apply.
4 DATA WE COLLECT ABOUT YOU
Personal Data
4.1 We will collect personal data about you.
4.2 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, which is anonymous data.
4.3 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
(a) Identity Data: your title, first name, last name, username or similar identifier.
(b) Corporate Data: your job title and organisation.
(c) Contact Data: your address and email address.
(d) Content: your content which you share on the website (e.g. projects, publications).
(e) Technical Data your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website.
(f) Profile Data your username and password, your interests, preferences, feedback and survey responses.
(g) Usage Data information about how you use our website and services.
(h) Newsletter and Communications Data your preferences in receiving newsletters and communications from us.
Aggregated Data
4.4 We 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.
4.5 For example, we may aggregate your Usage Data to calculate the percentage of users accessing the website from a particular country. 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.
Special Categories of Personal Data
4.6 We do not collect any Special Categories of Personal Data.
4.7 Special Categories of Personal Data 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.
4.8 We are conscious that the website allows the exchange of information and research regarding climate adaptation issues. We would welcome users keeping to the ethos of the website by sharing information and research rather than providing political opinions or engaging in political discussions.
If you fail to provide personal data
4.9 We may need to restrict your access to our services, where we need to collect personal data by law (or under our Terms of Use) and you fail to provide that data when requested.
5 HOW IS YOUR PERSONAL DATA COLLECTED?
5.1 We use different methods to collect data from and about you including through:
5.1.1 Direct interactions. You may give us your Identity Data, Corporate Data and Contact Data by registering on our website or by corresponding with us by email or otherwise. This includes personal data you provide when you:
(a) create an account on our website;
(b) user our services on the website;
(c) subscribe or request newsletters marketing to be sent to you; or
(d) give us feedback or contact us.
5.1.2 Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookies Policy for further details.
5.1.3 Third parties or publicly available sources. We don’t receive personal data about you from any third party or public sources.
5.1.4 Technical Data from analytics providers such as Google based outside the UK. For more information about Google Analytics Privacy & Terms, please click here: https://policies.google.com/privacy.
6 HOW WE USE YOUR PERSONAL DATA
6.1 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:
6.1.1 where we need to perform the contract entered into with you (in relation to provision of the weADAPT platform and microsite services).
6.1.2 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.
6.1.3 where we need to comply with a legal obligation.
6.2 Please click here Glossary to find out more about the types of lawful basis that we will rely on to process your personal data.
6.3 Generally, we do not rely on consent as a legal basis for processing your personal data. Where we do you have the right to withdraw consent to marketing at any time by contacting us.
7 PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
7.1 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.
7.2 Please 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 |
Description |
Type of data |
Lawful basis for processing |
|---|---|---|---|
|
Registration |
register you as a new user |
(a) Identity (b) Corporate (c) Contact |
|
|
Services |
Providing services to you on the weADAPT platform and microsites |
(a) Identity (b) Corporate (c) Contact (d) Content |
|
|
Uploading Content |
Uploading your content to the weADAPT platform and microsites. |
(a) Identity (b) Corporate (c) Contact (d) Content |
|
|
Downloading content |
Providing you with content to download from the weADAPT platform and microsites |
(a) Identity (b) Corporate (c) Contact (d) Content |
|
|
Relationship Management |
Manage our relationship with you, including notifying you about changes to our terms or privacy policy. |
(a) Identity (b) Corporate (c) Contact (f) Profile (h) Newsletter and Communications |
|
|
Surveys |
contact you to complete surveys regarding our services. |
(a) Identity (b) Corporate (c) Contact (f) Profile (g) Usage (h) Newsletter and Communications |
|
|
Administration |
Administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity (b) Corporate (c) Contact (e) Technical |
|
|
Newsletter and Communications |
Deliver relevant newsletter and website content to you and measure or understand the effectiveness of the newsletters and website content we serve to you |
(a) Identity (b) Corporate (c) Contact (f) Profile (g) Usage (h) Newsletters and and Communications |
|
|
Data analytics |
to improve our website, products/services, marketing, customer relationships and experiences |
(e) Technical (g) Usage |
|
8 COMMUNICATIONS
Newsletters and Communications
8.1 We will provide you with newsletters and communications where you have subscribed to do so, whether as part of the registration process or otherwise.
8.2 We use Mailchimp to set our newsletters and communications. Please see paragraph 15 of Mailchimp’s – Standard Terms of Use on the following link for more detail regarding how Mailchimp will process your personal data - https://mailchimp.com/legal/terms/.
8.3 Please also read the individual microsite Newsletter Data Policies where applicable.
Opting out
8.4 You can ask us to stop sending you newsletter or communication messages at any time by:
8.4.1 following the opt-out links on any newsletter or communications message sent to you;
8.4.2 contacting us at any time via email; or
8.4.3 logging into the website and checking or unchecking relevant boxes to adjust your newsletter and communication preferences.
8.5 Where you opt out of receiving these newsletter or communication messages, this will not apply to where we need to communicate with you to enforce our rights or update you on significant operational matters (e.g. updates to our Terms of Use).
Third-party marketing
8.6 We will not share your personal data with third parties for marketing purposes, unless with your express prior consent.
9 CHANGE OF PURPOSE
9.1 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.
9.2 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.
9.3 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.
10 DISCLOSURES OF YOUR PERSONAL DATA
Disclosure of your personal data
10.1 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.
10.1.1 weADAPT Network
10.1.2 SEI Network
10.1.3 External Third Parties.
weADAPT Network
10.2 weADAPT microsites and website members may have access to your personal data through use of the website.
10.3 We will limit the personal details which can be viewed about you to:
10.3.1 Identity Data – your title, first name, last name, username or similar identifier;
10.3.2 Corporate Data – your job title and organisation; and
10.3.3 Content – the content shared by you as a user of the website (e.g. projects, publications, etc)
10.4 Website users under our Terms of Use are required only to use another user’s personal details (accessible as outlined above) for the purposes of using and benefiting from the Website. Where we become aware that a user is failing to comply with this rule we may remove their access to the Website.
SEI Network
10.5 We may share your personal data across the SEI network to facilitate research into climate adaptation knowledge management, platform interoperability, knowledge co-production, social learning and developing tools and solutions related to these areas. The SEI network is made up of the following organisations:
10.5.1 Stiftelsen The Stockholm Environment Institute (SEI), Stockholm, Sweden (including SEI HQ, SEI Asia, SEI Africa, SEI Latin America);
10.5.2 SEI Oxford Office Ltd, UK
10.5.3 SEI US, United States; and
10.5.4 SEI Tallinn, The Estonian Institute for Sustainable Development, Estonia
10.6 As such, we may share public profile or project data uploaded on weADAPT in such tools (e.g. the Tandem tool on co-producing climate services and the Connectivity Hub which maps the climate change adaptation and disaster risk reduction landscape of organizations, actors and activities). We also share content across the weADAPT network to increase its' visibility, reach and potential impact (e.g. through our newsletter). If you would like your data removed from weADAPT, our tools or microsites, you can contact [email protected].
External Third Parties
10.7 We may share your personal data with the following external third parties:
10.7.1 Service providers who provide IT and system administration services.
10.7.2 Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
10.7.3 governmental organisations, regulators and other authorities who require reporting of processing activities in certain circumstances.
Disclosure requirements for third parties
10.8 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.
Sale of Business
10.9 We may share your personal data with 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.
11 WEBSITE INFORMATION
Cookies
11.1 Please see our Cookies Policy regarding the use of cookies on our website.
11.2 You can set your browser to refuse all or some browser cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
Third Party Links
11.3 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.
12 INTERNATIONAL TRANSFERS
12.1 weADAPT originated from SEI Foundation in Sweden and continues to operate across Europe and the United Kingdom.
12.2 We, however, now operate in Africa (through SEI Africa), Asia (through SEI Asia), the USA (through SEI US) and Latin America (through SEI Latin America).
12.3 Where required for operation of our network or for our wider business purposes, the information that we hold about you may be transferred to, and stored at, a destination outside the European Economic Area (EEA) and the United Kingdom. It may also be processed by staff operating outside the EEA and the UK who work for us or for one of our service providers.
12.4 We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this privacy notice.
12.5 Some countries or organisations outside of the EEA and the UK to which we may transfer your information to will have an "adequacy decision" in place. This means the EEA and the UK considers them to have an adequate data protection regime in place.
12.6 Where we transfer data to countries or organisations outside of the EEA and the UK which is not considered to have an adequate data protection regime in place, we will ensure that appropriate safeguards. For example, ensuring EU or UK data supervisory authority approved standard international data transfer clauses are put in place where required.
12.7 Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA or the UK.
13 DATA SECURITY
13.1 We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
13.2 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.
13.3 Communications from us in connection with the website may be sent to you by email. Email is not a fully secure means of communication and we cannot guarantee our emails are free from viruses and other harmful effects.
14 DATA RETENTION
14.1 We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory 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.
14.2 To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
14.3 Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
14.4 In some circumstances you can ask us to delete your data. Please see “Your Rights” section below for further information.
14.5 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.
15 YOUR RIGHTS
Your Rights
15.1 Data protection law gives you a number of rights when it comes to personal information we hold about you. The key rights are set out below. More information about your rights can be obtained from your national data protection supervisory authority. Under certain circumstances, by law you have the right to:
· Be informed in a clear, transparent and easily understandable way about how we use your personal information and about your rights. This is why we are providing you with the information in this notice. If you require any further information about how we use your personal information, please let us know.
· 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.
· 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. 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.
· 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.
· 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.
· 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.
· Lodge a complaint. If you think that we are using your information in a way which breaches data protection law, you have the right to lodge a complaint with your national data protection supervisory authority.
15.2 If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal information, withdraw your consent to the processing of your personal information or request that we transfer a copy of your personal information to another party, please contact us.
No fee usually required
15.3 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
15.4 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
15.5 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 CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
16.1 We keep our privacy policy under regular review. We reserve the right to make amendments at any time and notify you of such changes (either by email or a notification on our website).
16.2 This version was last updated in August 2023. Historic versions can be obtained by contacting us.
16.3 It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
17 GLOSSARY
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product 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.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Version 1.0 (August 2023)
