At Verdn Ltd (“we”, “us”, or “our”) we are committed to protecting and respecting your privacy and Personal Data in compliance with the United Kingdom General Data Protection Regulation (“GDPR”), the Data Protection Act 2018 and all other mandatory laws and regulations of the United Kingdom.
The individuals from which we may gather and use data can include:
and any other people that the organisation has a relationship with or may need to contact.
Verdn Ltd is your Data Controller and responsible for your Personal Data. We are not obliged by the GDPR to appoint a data protection officer and have not voluntarily appointed one at this time. Therefore, any inquiries about your data should either be sent to us on email at email@example.com or sent in a letter to Office 1.01, 411-413 Oxford Street, London, W1C 2PE, United Kingdom.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority 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.
In discharging our responsibilities as a Data Controller we have employees who will deal with your data on our behalf (known as “Processors”). Therefore, the responsibilities described below may be assigned to an individual, or may be taken to apply to the organisation as a whole. The Data Controller and our Processors have the following responsibilities:
“Personal Data” 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 may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together below. Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect and when we collect it from you:
We may also aggregate data to enable research or analysis so that we can better understand and serve you and others. For example, we may conduct research on your demographics and usage. Although this aggregated data may be based in part on Personal Data, it does not identify you personally. We may share this type of anonymous data with others, including service providers, our affiliates, agents and current and prospective business partners.
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.
There are a number of justifiable reasons under the GDPR that allow collection and processing of Personal Data. The main avenues we rely on are:
We will only use your Personal Data when the law allows us to. Set out below is a table containing the different types of Personal Data we collect and the lawful basis for processing that data. Please refer to section 2.2 for more information on the lawful basis listed in the table below.
Examples provided in the table below are indicative in nature and the purposes for which we use your data may be broader than described but we will never process your data without a legal basis for doing so and it is for a related purpose. For further inquiries please contact us.
|Activity||Type of data||Legal justification||Lawful basis for processing data|
|When a visitor uses our website||Legitimate Interest||We use this data to facilitate site access (e.g. adjust the site based on the device used), and for performance metrics, including the monitoring and tracking of errors.|
|When a visitor signs up on our website||Consent||We collect info (name, email, company) to respond to incoming signups and queries. If a site visitor receives email from us, we may use certain analytics tools to assess the performance of those communications (e.g. email open rates).|
|When a company installs Verdn, creates an account, or logs in to our software or app||Legitimate Interest||We solely process this Personal Data to provide our software in accordance with Article 6(1)(b) GDPR.|
|When a customer sells products with impact||Legitimate Interest||When a customer sells products with impact, we need the transactional data to correctly generate/update an impact timeline (e.g. to display the correct products and pledges), and we need Personal Data on the end-customer (e.g. to correctly display the first name). We also need the end- customer's email to send the timeline to them.|
|When a customer contacts customer support||Legitimate Interest||We will solely process this Personal Data to provide our software in accordance with Article 6(1)(b) GDPR|
|When an end-customer engages with their impact timelines, or the emails linking to them||Legitimate Interest||We need this data to provide our core service: enabling companies to engage their end-customers with transparent updates about their positive environmental impact. We also use de-identified and aggregated information for analytics and performance measurement, the legal basis of which is Article 6(1)(f) GDPR.|
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.
We are concerned with keeping your data secure and protecting it from inappropriate disclosure. We implement a variety of security measures to ensure the security of your Personal Data on our systems, including adopting a secure protocol and encrypting our databases. Any Personal Data collected by us is only accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of 4 confidentiality. If and when we use subcontractors to store your data, we will not relinquish control of your Personal Data or expose it to security risks that would not have arisen had the data remained in our possession. However, unfortunately no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of Verdn Ltd to intercept or access transmissions or private communications unlawfully. While we strive to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us.
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, we could refuse to comply with your request.
We may need to request specific information from you to help us confirm your identity and ensure you have the 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.
We may share non-Personal Data with third parties. We may share your Personal Data with subcontractors or affiliates (subject to confidentiality obligations to use it only for the purposes for which we disclose it to them and pursuant to our instructions).
We may also share Personal Data with interested parties in the event that Verdn Ltd anticipates a change in control or the acquisition of all or part of our business or assets or with interested parties in connection with the licensing of our technology.
We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your Personal Data for a longer period than usual in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
You must not use Verdn Ltd unless you are aged 16 or older. If you are under 16 and you access Verdn Ltd by lying about your age, you must immediately stop using Verdn Ltd.
This website is not intended for children and we do not knowingly collect data relating to children.
Your information may be stored and processed in the US or other countries or jurisdictions outside the US where Verdn Ltd has facilities. We are currently storing data in the EU and so, by using Verdn Ltd, you are permitting and consenting to the transfer of information, including Personal Data, outside of the US.
All uses of the word "including" mean "including but not limited to" and the enumerated examples are not intended to in any way limit the term which they serve to illustrate. Any email addresses set out in this policy may be used solely for the purpose for which they are stated to be provided, and any unrelated correspondence will be ignored. Unless otherwise required by law, we reserve the right to not respond to emails, even if they relate to a legitimate subject matter for which we have provided an email address. As a matter of common sense, you are more likely to get a reply if your request or question is polite, reasonable and there is no relatively obvious other way to deal with or answer your concern or question (e.g. FAQs, other areas of our website etc.).
Our staff are not authorised to contract on behalf of Verdn Ltd, waive rights or make representations (whether contractual or otherwise). If anything contained in an email from a Verdn Ltd address contradicts anything in this policy, our terms or any official public announcement on our website, or is inconsistent with or amounts to a waiver of any Verdn Ltd rights, the email content will be read down to grant precedence to the latter. The only exception to this is genuine correspondence expressed to be from the Verdn Ltd legal department.