Thank you for visiting the Cotton Lives On™ (“CLO”) web site and supporting our efforts to recycle denim products. This Notice explains what we do with your personal information, why we want to use it, how we protect it, and what rights you have to control our use of your personal data.
The data controllers
The data controllers associated with the CLO website are Novem Vitas Limited (“Novem Vitas”) and Cotton Incorporated. Novem Vitas’ company number is 13692491. Novem Vitas is listed as a data controller on the ICO’s register of fee payers, registration reference is ZB301004.
Cotton Incorporated is located at 6399 Weston Parkway, Cary, North Carolina 27513 USA.
Novem Vitas operates the CLO recycling programme website on behalf of Cotton Incorporated.
If you want to contact us about any of the points on this Notice, or just generally about how we protect your privacy, please email us at firstname.lastname@example.org. We use this email address for all data protection and data access matters.
Why do we need your personal data?
If you use our website contact form we use your name and email address to send a reply to you and to address your questions. It is in our “legitimate interests” to reply to you and we won’t keep your details for any longer than needed for addressing your questions and administering the CLO program. Your personal information won’t be used for any other reason.
When you visit our website, we may record your journey on our website to help us improve it but this doesn’t record any personal information (such as your computer’s IP address). We use special software that does not track your personal information – this is called “privacy by design”.
Who receives your personal data?
We work with Cotton Incorporated. Your enquiries to our website will be shared with Cotton Incorporated to ensure that we can respond with the best information. We also use a small range of service providers to run this website and respond to enquiries. These include:
- Email service provider
- Software and web service providers
- Associates and subcontractors
We have arrangements in place with each organisation to protect the personal data under our control. If you’d like more information about our suppliers, please contact us at email@example.com
International transfers of personal data, and their safeguarding measures
Cotton Incorporated is located in the United States and is a co-controller of the information provided on the CLO web site. Novem Vitas operates the CLO web site and has entered into appropriate GDPR standard contractual clauses approved by the EC and/or the UK with Cotton Incorporated with regards to the transfer of data to the United States.
Our email systems use data centres in different locations. We have implemented standard contractual clauses approved by the EC and/or the UK with the providers of these systems.
Your personal data rights
The personal data we hold about you is your data, so you have certain rights over them. You can exercise any or all these rights when you choose, and the easiest way is by dropping us an email at firstname.lastname@example.org.
You have the right to request a copy of all personal data we hold relating to you and we must provide this within 30 days. You also have the right to require us to correct any records that are wrong.
You have the right to require us to erase personal data and we must comply unless we need it for one of the purposes described above. We also retain the right to keep data that is needed to establish, exercise or defend a legal claim.
Where we process your data based on a “legitimate interest” you still have the right to object to our processing of that data. From that point, we must stop processing your data until we have determined whether your rights override our interests.
Finally, you have the right to have your personal data transferred to another organisation, and we’re obliged to provide it to you in a clear and reasonable format.
Your rights to lodge a complaint with the Regulator
At all times, you have the right to report a concern or lodge a complaint with the Information Commissioner’s Office. Please refer to the ICO at https://ico.org.uk/concerns or by calling them on 0303 123 1113.
Of course, we hope that we can resolve your issue quickly and fairly – you can contact us at email@example.com. If you contact the ICO, they are likely to ask whether you’ve tried to resolve the issue with us first
Other purposes for processing personal data
We don’t perform any automated processing or decision making using personal data.
We don’t process your personal data for any other purpose than we’ve described here. We won’t sell your personal data to other companies.
Should we want to develop a new processing purpose, we will publish information about it here.
If you have any questions, concerns or just want some more information about our privacy management, drop us a line at firstname.lastname@example.org