Privacy Policy

Date last updated: 16 September 2020

INTRODUCTION

This is the ECOM Agroindustrial Corp. Limited and its Group’s privacy policy.

This privacy policy is addressed to individuals outside our Group with whom ECOM Agroindustrial Corp. Limited and its Group (together “ECOM”, “we”, “us” and “our”) interact, including visitors to our websites, including ecomtrading.com, atlanticspecialtycoffee.com and any other website we maintain that contains a link to this privacy policy (“Website“), ECOM’s customers, personnel of corporate customers and suppliers, and other recipients of our services (together “you“) and will inform you about how we collect, use, disclose, and look after your personal data and about your privacy rights and how the law protects you.

By accessing our Website, communicating with us, or making a sale to or a purchase from us, you agree to be bound by this policy. You can find the types of information we collect about you in the operation of our business below in the section entitled The data we collect about you. If you do not agree to be bound by this policy you should not access or view this Website or make contact with us or make use of our services.

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.

We keep our privacy policy under regular review and recommend that you revisit it on occasion to see the latest version.

Personal data collected through our Website is controlled by ECOM or its subsidiaries, depending on which website you visit. If you have any questions about this privacy policy, our privacy practices or would like access to your personal data and ask for it to be corrected or deleted please use the ‘Contact’ page.

If you are in the EU, you also have the right to raise a privacy concern with the relevant Data Protection Authority. However, please consider contacting us first.

The data we collect about you

ECOM collects a variety of personal data in the operation of its business. We use, store and transfer different kinds of personal data about you which we have grouped together in the following categories:

“Identity Data” includes personal identifiers, such as your first name, last name, client identifier, title.
“Contact Data” includes personal identifiers, such as your billing address, delivery address, email address, emails and telephone numbers.
“Financial Data” includes bank account details.
“Transaction Data” includes commercial information, such as details about payments to and from you and other details of products and services you have sold to or purchased from us.
“Technical Data” includes personal online identifiers, such as internet protocol (IP) address and cookie data (please refer to our Cookie Policy).
“Profile Data” includes personal identifiers, such as your client identifier, and other personal details such as your purchases or orders made by you and feedback.
“Usage Data” includes internet or other electronic activity information, such as information about how you use our Website, products and services.
“Marketing and Communications Data” includes your preferences in receiving marketing from us and your communication preferences.
“Inferences” drawn from any of the above categories.

These categories of data may be collected in the following ways:

If you decide to contact us (this may be via email, phone or our Website) or make use of personalised services (e.g. contacting us or by subscribing to a newsletter or publication), then you will be asked to submit Identity Data and Contact Data which is necessary for us to provide that service or handle your query. We will then create Marketing and Communications Data. This is completely voluntary.
If you make a purchase from or a sale to us then you will be asked to supply Identity Data, Contact Data and Financial Data. We will also keep records of Transaction Data and we will create Profile Data to enable us to process orders and manage records. Please be aware that your employer in making a sale to or a purchase from us may provide us with your personal information. This allows us to conduct know your client checks and conduct credit reference checks.
If you ask us to send you newsletters, apply for a job or make other communications, we rely on your active consent in order to do so and you will be asked to provide Identity Data and Contact Data. You may opt out of receiving communications at any time.
If you make any personal information public, including via social media such as LinkedIn, we may collect and use this information.
We also collect Usage Data, Technical Data, and Inferences with regards to personal data from cookies, which we explain more about in our Cookie Policy.

If any form provided by ECOM collects your personal data we seek this information because we think it will help us to give you a better quality service. You do not have to provide such information if you do not wish to do so, but we may not be able to provide you with the services you request.

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.

Where we need to collect personal data for instance 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 goods). In this case, we may have to cancel an order you have with us but we will notify you if this is the case at the time.

When you provide us with your information, you acknowledge that this information may be stored and processed on servers located anywhere in the world, including either inside or outside of the USA or the European Economic Area.

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 data by filling in forms or by corresponding with us. This includes personal data you provide when you:
- email our employees;
- offer to sell or purchase goods or services from or to ECOM;
- subscribe to any publications;
- request marketing to be sent to you; or
- give us feedback or contact us.
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. Please see our Cookie Policy for further details.

We only keep your information for as long as is necessary and then information is deleted.

Communications, Notices & Consent

You can ask us to stop sending you publications or marketing messages at any time. Where you opt out of receiving these publications or marketing messages, we will not send you further such communications; however, personal data provided to us as a result of product sales or purchases will not be deleted.

If you want to learn more about advertising networks or opt-out of receiving personalized advertisements on this browser or device from advertisers who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising you can visit the opt-out options of each of those organizations. Here are links to the sites of those organizations:

Network Advertising Initiative:

Browser Opt-Out: http://www.networkadvertising.org/choices/

Digital Advertising Alliance:

Browser Opt-Out: http://www.aboutads.info/choices/

Both Network Advertising Initiative and Digital Advertising Alliance

App Opt-Out: http://youradchoices.com/appchoices

Your device may include a feature (“Limit Ad Tracking” on iOS or “Opt Out of Interest-Based Ads” on Android) that allows you to opt-out of having certain information collected through apps used for interest-based advertising purposes. When you opt out of personalized advertising, you may continue to see online advertising on the Website and/or our ads on other websites and online services. Since this opt-out relies on cookies, if you delete your cookies, you will need to opt-out again.

Even when you opt-out of personalized advertising, you may continue to see online advertising on the Website and/or our ads on other websites and online services.

Accuracy of your information

ECOM strives to keep your personal information accurately recorded. You have the right to obtain a copy of the information we hold about you and/or to ask us not to process your information (or not to pass your information to third parties). If you would like copies of your information, or if you would like us to correct factual inaccuracies, or if you would like that information to be blocked or deleted from our records, then please contact Legal Department, 55 Old Broad Street, London, EC2M 1RX, U.K. or e-mail us using the details in the ‘Contact’ section of this Website.

How we use your personal data

ECOM does not sell your personal data and does not intend to sell your personal data in the future. We will only use your personal data when the law allows us to process your payments, to allow you to navigate our website, to communicate with you, and for our business and commercial purposes. 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, including the performance of know your client checks and conducting client on-boarding and the processing of orders (for example financial management).
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.
Where you have requested us to do so (e.g. subscriptions).
Where we need to comply with a legal obligation.
Where we conduct risk/credit management in line with ECOM policies and processes.
Where we need to establish, protect or defend our legal rights.

ECOM does not share your personal information with third parties for marketing or promotional purposes.

ECOM may share your personal information in the following ways:

From time to time your personal information may be transferred amongst Group entities or to third party agents, representatives or suppliers of ECOM for the purposes of system maintenance and support.
ECOM may be required to disclose your personal information to: (i) respond to duly authorised information requests from the police and governmental authorities; (ii) comply with any law, regulation, subpoena or court order; (iii) help prevent fraud or to enforce or protect the rights and properties of ECOM or its subsidiaries; or (iv) protect the personal safety of ECOM employees, third party agents or members of the public.
Circumstances may arise where ECOM decides to sell, buy, merge or otherwise reorganise businesses. Such a transaction may involve the disclosure of your personal information to prospective or actual buyers (or receive it from sellers). It is ECOM’s practice to seek appropriate protection for personal information transferred in these types of transactions.

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 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.

Is your information transferred?

Personal information that we collect may be transferred across international borders for further processing, storage or use in accordance with this policy. Transfers may occur between ECOM including their affiliates, third party agents, representatives, customers and suppliers. Please do not send us your information if you do not want it to be transferred or stored in this way.

We ensure your personal data is protected by requiring all our Group companies to follow the same rules when processing your personal data.

Whenever we transfer your personal data out of the European Economic Area, we ensure a similar degree of protection is afforded to it.

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 or contractors who have a business need to know. They will only process your personal data on our instructions and provided they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

How long do we keep your information?

We will only hold your personal information for as long as necessary to fulfil the purposes for which it was collected including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements, before making it non-identifiable or deleting it. 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.

In respect of job applications, personal information about speculative or unsuccessful candidates will be held for 12 months after the recruitment exercise has been completed, before being destroyed or deleted. We may retain de-personalised statistical information about applicants to help inform our recruitment activities, but no individuals are identifiable from that data.

If you send us any ‘contact us’ messages, we will delete or de-identify these messages once we have finally satisfied your query.

If you choose to unsubscribe from a service, we may keep a ‘suppression list’ containing your details so we know you have unsubscribed.

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.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

European Union Resident Privacy Rights

If you are residing in the European Economic Area (“EEA”) or Switzerland, you may request that we:

provide access to and/or a copy of certain information we hold about you;
delete certain information that we are holding about you;
update or rectify information that is out-of-date, incomplete, or incorrect;
oppose, cancel, or restrict how we process and disclose certain of your information; or
revoke your consent for the processing of your information.

If you wish to exercise any of the rights you have, please click here. You may also submit a request by contacting our Legal Department in the following ways:

Email address: Londonlegal@ecomtrading.com

Postal address: ECOM Agrotrade Limited, 10th Floor, 55 Old Broad Street, London, EC2M 1RX, U.K.

You will not have to pay a fee to access your personal data (or to exercise any of your 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.

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.

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.

Notice of California Resident Privacy Rights

We do not sell personal information, and we have not sold personal information since January 1, 2020, the date the CCPA went into effect. If you are a California resident, the California Consumer Privacy Act (“CCPA”) requires that we provide you with some additional information regarding how we collect, use, and share your “personal information” (as defined in the CCPA). The CCPA further allows you, or an authorized agent acting on your behalf, to make certain requests related to your personal information. Specifically, the CCPA allows you to request us to:

Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we share/disclose personal information.
Provide access to and/or a copy of certain personal information we hold about you.
Delete certain personal information we are holding about you.
Provide you with information about the financial incentives that we offer to you, if any.

The CCPA further grants California residents the right to not be discriminated against (as provided in applicable law) for exercising the above-listed rights.

Please note that certain information may be exempt from such requests under California law. For example, we need certain information in order to provide our services to you or verify your identity before responding to such a request. In doing so, we may request information from you so that we can match data points provided by you with data points that we maintain about you. If we are unable to verify your identity through these methods, we shall have the right, but not the obligation, to request additional information from you to continue verifying your identity.

To make a request or if you wish further information regarding how to exercise any of the rights listed above, or if you are an authorized agent of a California resident user seeking to exercise those rights, please submit that request here. You may also submit a request by contacting our Legal Department in the following ways:

Email address: Londonlegal@ecomtrading.com

Postal address: ECOM Agrotrade Limited, 10th Floor, 55 Old Broad Street, London, EC2M 1RX, U.K.

Phone: +44 (0) 203 214 2198

We try to respond to all legitimate, verifiable requests within one month or the time required by law. Occasionally, if your request is particularly complex or we are processing a large number of requests, we may need additional time. In that case, we will notify you of our need for additional time and keep you updated.

Other California Privacy Rights

Our Website does not currently respond to “do not track” signals or similar mechanism.

We do not share personal information (as defined by California Civil Code §1798.83) with other people or non-affiliated businesses for their direct marketing purposes.

Your Nevada Privacy Rights

Nevada residents have the right to submit a verified request directing us not to sell their personal information. If you are a Nevada resident, and would like to submit such a request, please send your request to Londonlegal@ecomtrading.com.

Notice of Collection of Personal Information for California Residents – To Applicants for Employment Positions with ECOM

This California Notice of Collection of Personal Information for job applicants applies to California residents who are applying for employment positions with ECOM. This notice explains how ECOM collects and uses your personal information when you submit it to us by website, email, paper, or other method to apply for employment with ECOM. Note that in some cases, when permitted by law, we may supplement the information you provide with other personal information from third parties and external sources we select, such as background check providers, from third parties that you instruct or authorise to send information to us, and from publicly available information.

If you are a prospective employee, the categories of personal information listed below that we receive will be used for the recruitment process, to conduct interviews, to assess your suitability as a ECOM employee, to evaluate your qualifications and eligibility for available or anticipated employment positions at ECOM, and for purposes of complying with legal obligations or governmental or regulatory requests. Unless you direct otherwise in writing, we may (but are not obligated to) retain the personal information we receive for up to 12 months to contact you regarding additional opportunities.

The categories of personal information we may collect and process (but only to the extent and in a manner that is consistent with applicable law) are as follows:

Personal identifiers and personal details, such as your name, address, telephone number, mobile phone number, social security number, other government identification number, work permit information, and data relating to criminal convictions and offences;
Educational, professional, and employment-related information, such as your application form and references, CV or resume, cover letter, professional experience, records relating to your career history, such as training records and other performance measures, professional affiliations and memberships, and prior job titles and job functions;
Job preference information, such as your compensation expectations, preferred position, and preferred start date;
Background check and public records information, such as background check reports or results and public government records (such as work history, credit history, driving records, criminal records, and court records);
Publicly available information, such as social media pages and other public Internet postings;
Health-related information, such as when you provide information about your ability to perform certain job functions, the need for accommodations, or a disability;
Protected class information, such as your citizenship and right to work information; and
Inferences we may draw from any of the above categories in connection with the purposes stated as to such categories.

If you have any questions concerning the above, please contact us at Londonlegal@ecomtrading.com.