Privacy Notice

Curation Corporation Limited is committed to protecting the privacy and security of the personal data of our website visitors, Sustt newsletter subscribers, portal subscribers, potential and existing clients and suppliers we deal with in the course of our business operations and the provision of our services. This Privacy Notice explains who we are, how we collect, share, and use your personal data, and how you can exercise your data protection rights.

We ensure that your personal data:

Is processed lawfully, fairly and in a transparent manner.
Is collected only for specified, explicit and legitimate purposes.
Is adequate, relevant, and limited to what is necessary in relation to the services that we are providing you.
Is accurate and where necessary, kept up to date.
Is not kept in a form which allows for you to be identified for longer than is necessary.
Is only processed in a manner that ensures its security using appropriate technical and organisational measures to protect it against unauthorised or unlawful processing and against accidental loss, destruction, or damage.

Our name and contact details

Curation Corporation Limited, 5 Fleet Place, London, London, EC4M 7RD and our data protection manager’s email address is privacy@curationcorp.com.

What we do

Curation Corporation Limited provides curated articles on sustainability trends, risks and technological advances to individuals, businesses, and academic institutions.

Processing your personal data

We process and manage your personal data according to the relationship we have with you. This relationship helps us to identify the appropriate data subject category you belong to (or group of individuals whose data we process in an identical manner) and allows us to provide you the details of how we process your personal data. We interact with you in one of more of the following ways:

	As a *website visitor*
	We collect, store, and use your personal data to make our website more intuitive and easier to use and protect the security and effective functioning of our websites on the basis of our legitimate interest. It is necessary for our legitimate interests to monitor how our website is used to help us (a) improve the layout and information available on our website and provide a better service to our website users and (b) monitor how our website is used to detect and prevent fraud, other crimes, and the misuse of our website.
	We collect		IP address, device used and website analytics.
	From		Directly from yourself through the website and from our website analytics providers.
	Share with		Third parties who provide us the following services: technology and website support, website analytics. Only aggregated data is retained by our website analytics provider.
	Store in		UK, EEA and USA.
	Retain for		Your personal data is retained for the period of website visit or for the terms of the cookies you agree to.
	Safeguards		Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: · We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data · Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK. We have put in place security measures to prevent your personal information from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. We limit access to your personal information to authorised employees or contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality. Details of these measures may be obtained from privacy@curationcorp.com.

	As a *Sustt newsletter subscriber*
	We collect, store, and use your personal data to register and manage your Sustt newsletter subscription on the basis of your consent and our legitimate interest. If you withdraw your consent, you will no longer receive the Sustt newsletter. We will advise you if this is the case at the time you withdraw your consent. It is in our legitimate interest to provide you with information on our related services and products that we think you may be interested in.
	We collect		Email address, analytics.
	From		Directly from yourself and through the analytics providers.
	Share with		Third parties who provide us the following services: technology analytics providers, technology support and client relationship management services.
	Store in		UK, EEA and the USA.
	Retain for		Your personal data is retained until you unsubscribe from the Sustt newsletter and thereafter only for as long as reasonably necessary to fulfil our legal and regulatory requirements.
	Safeguards		Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: · We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data · Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK. We have put in place security measures to prevent your personal information from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. We limit access to your personal information to authorised employees or contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality. Details of these measures may be obtained from privacy@curationcorp.com.

As a *subscriber*
We collect, store, and use your personal data to provide and service your or your corporate portal subscription, take payment and provide you or provide access to individuals to whom you issue portal access. We process this data on the basis of contract, legal obligation, and our legitimate interest. We need to process your personal information to manage the contract for our corporate service we have entered into with you. If you fail to provide certain information when requested, we may not be able to perform the contract for the portal service we are about to, or have entered into with you, or we may be prevented from complying with our legal obligations. It is in our legitimate interest to collect your contact and payment data in order for us to bill you for the service.
We collect		Email address, name, IP address, website analytics and payment details.
From		Directly from yourself.
Share with		Third parties who provide us the following services: technology and website support, payment services and client relationship management services.
Store in		UK, EEA and USA.
Retain for		The period of your contract plus 6 years.
Safeguards		Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: · We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data · Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK. We have put in place security measures to prevent your personal information from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. We limit access to your personal information to authorised employees or contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality. Details of these measures may be obtained from privacy@curationcorp.com.

As a client
We collect, store, and use your personal data when you provide us goods or services on the basis of contract, legal obligation, and our legitimate interest. If you fail to provide certain information when requested, we may not be able to perform the contract we are about to, or have entered into with you, or we may be prevented from complying with our legal obligations. It is in our legitimate interest to collect your contact, inform you of other services or products we think you may be interested in and payment data in order for us to bill you for our services.
We process		Name, email address, company name and address, tax, payment details and analytics.
From		Directly from yourself and analytic providers.
Share with		Third parties who provide us the following services: technology support, accounting, client relationship management services and payment where it is necessary to administer the working relationship.
Store in		UK, EEA and the USA.
Retain for		The period of our contract with you plus 6 years.
Safeguards		Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: · We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data · Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK. We have put in place security measures to prevent your personal information from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. We limit access to your personal information to authorised employees or contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality. Details of these measures may be obtained from privacy@curationcorp.com.

As a *supplier*
We collect, store, and use your personal data when you provide us goods or services on the basis of contract, legal obligation, and our legitimate interest. If you fail to provide certain information when requested, we may not be able to perform the contract we are about to, or have entered into with you, or we may be prevented from complying with our legal obligations. It is in our legitimate interest to collect your contact and payment details in order for us to pay you, to prevent fraud, to make decisions about the continued provision of goods and/or services by you, and to make arrangements for the termination of the provision of goods and/or services by you.
We collect	Name, email address, mobile number, physical address, payment details, tax information.
From	Directly from yourself through the contract negotiation and setup process and potentially from referees.
Share with	Third parties who provide us the following services: technology support, accounting, and payment.
Store in	UK and EEA.
Retain for	The period of our contract plus 6 years.
Safeguards	Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: · We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data · Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK. We have put in place security measures to prevent your personal information from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. We limit access to your personal information to authorised employees or contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality. Details of these measures may be obtained from privacy@curationcorp.com.

As a *potential client*
We collect, store, and use your personal data to send you information about our services, invitations to events and other communications which we think you may be interested in on the basis of contract and our legitimate interest in generating new business with you. We need to process your personal information to manage your contract we are about to or have entered into with you. If you fail to provide certain information when requested, we may not be able to perform the contract we are about to or have entered into with you. It is in our legitimate interest to contact you about our products or services that we think you may be interested in.
We collect	Name, email address, company name and role.
From	Directly from you and indirectly from third-party publicly available sources.
Share with	Third parties who provide us the following services: technology support, email.
Store in	UK and EEA and USA.
Retain for	Three years or until you inform us you do not want any further contact from us.
Safeguards	Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: · We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data · Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK. We have put in place security measures to prevent your personal information from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. We limit access to your personal information to authorised employees or contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality. Details of these measures may be obtained from privacy@curationcorp.com.

As a *job applicant*
We collect, store, and use your personal data to assess your skills, qualifications, and suitability for the work or role, during this process on the basis of our legitimate interest and contract. It is in our legitimate interest to carry out background checks, communicate with you about the recruitment process and keep records related to our hiring process. If you fail to provide information when requested, which is necessary for us to consider your job application, we will not be able to process your application.
We collect	Name, email address, CV, interview notes, references, qualifications, skills, employment history and entitlement to work in the UK. We may also collect health data, for example if the applicant needs reasonable adjustments to be made for an interview or for their role, if accepted.
From	Directly from yourself, however, we may sometimes collect additional information about you from third parties including recruitment agencies, social media, former employers and referees.
Share with	Recruitment agencies or referees.
Store in	UK and EEA.
Retain for	One year after we have communicated to you our decision about whether to appoint you. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way.
Safeguards	Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: · We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data · Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK. We have put in place security measures to prevent your personal information from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. We limit access to your personal information to authorised employees or contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality. Details of these measures may be obtained from privacy@curationcorp.com.

Your data

May, in certain circumstances, be provided to other third parties such as HMRC or Companies House, or other regulatory or law enforcement bodies, technology companies that provide us with cloud-based solutions, professional advisers (as we engage with law firms, banks, accountants etc.) but only in compliance with the law and where strictly necessary.

Automated decision-making and profiling

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, including profiling, unless you have given us your consent to do so, or it is necessary for entering into or the performance of a contract.

Your rights

Access – you have the right to ask us for information on the personal data that we store and copies of examples of the personal data. This right always applies. There are some exemptions, which means you may not always receive all of the information and examples of copies of your personal data.
Rectification – you have the right to ask us to rectify any of your personal data that you think is inaccurate or incomplete. This right always applies.
Erasure – you have the right to ask us to erase your personal data where it is no longer required for purpose for which it was collected, or you withdraw your prior consent to us processing it and we have no other legal ground for processing it, or it is being processed unlawfully, or when it must be erased to comply with a legal obligation, or it is being used for direct marketing purposes where we have no legitimate grounds for us doing so.
Restriction – you have the right to ask us to restrict the processing of your personal data where it is inaccurate (allowing us to verify the accuracy), or it is being processed unlawfully (and you want us to stop processing rather than erasing it), or where you have objected to us processing it while we’re verifying whether we have legitimate grounds for processing, or it is no longer required for purpose for which it was collected and you want us to keep it for the establishment, exercise or defence of legal claims.
Portability – this only applies to personal data you have given us. You have the right to ask us to transfer the information you provided us from one organisation to another or give it to you. This only applies if we are processing personal data based on your consent or as part of a contract, or in talks with you about entering into a contract and the processing is automated.
Objection – you have the right to object to processing your personal data if we are using legitimate interests as our lawful basis for processing, or it is being used for direct marketing.
Withdrawing consent – you can withdraw your consent that you have previously given to us for one or more specified purposes to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. It may mean we are not able to provide certain products or services to you and we will advise you if this is the case.
You have the right to complain to a Supervisory Authority, in the UK that is the Information Commissioner’s Office.

Breaches

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

Dealing with your data subject requests

We will deal with your requests as soon as possible and within 1 month of receipt of the request (possibly extended to 3 months where the law permits). Normally there is no charge, however we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive or 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 your 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.

Note

This notice does not form part of any contract of employment or other contract to provide services.

Updates

We may update this privacy notice from time to time in order to reflect any changes to the way in which we process your personal data or changing legal requirements. Any changes to this privacy notice will be posted on this page and, where appropriate, notified to you by email (if you have registered your e-mail details with us) when we are required to do so by applicable law. We recommend that you review this privacy notice regularly for changes.

How to make a complaint

Data privacy laws are constantly evolving, and we endeavour to maintain best practices. However, if you believe that we have not got something right and you wish to discuss our processes, we would be happy to hear from you on privacy@curationcorp.com in the first instance. If you are still unhappy, you should know that you have the right to contact the Information Commissioner’s Office, which is our data protection supervisory authority, by clicking here: https://ico.org.uk/make-a-complaint/.

Supplementary information

Direct marketing

Our direct marketing activities comply with the Privacy and Electronic Communications (EC Directive) Regulations 2003 (SI 2003/2426) which means that you may receive direct marketing communications from us if you have requested these, or you have purchased any of our services and have not opted-out from receiving these, or the communications are necessary for performing a contract between us.

Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, destroyed, or accessed without authorisation. While no data transmission or storage can be guaranteed to be secure, we implement a range of commercially reasonable physical, technical, and procedural measures to help protect personal data. These measures include confidentiality agreements with third parties, secure development practices, security due diligence of service providers, products, services that may be used and ISO27001-based organisational security policies.

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

Cookies

Cookies are small files we store on the device (computer, mobile phone, tablet, or any other mobile device) that you use to access our website or portal – this is so we can recognize repeat users improve your experience while you navigate through the website.

We use the term ‘cookies’ to include not only cookies, but also other technologies such as pixels, web beacons and page tags. Our website uses ‘first-party’ cookies (which are set by our own website) and ‘third-party’ cookies (which are set by websites other than our own).

Telling you about and managing how we use cookies is required by the Privacy and Electronic Communications (EC Directive) Regulations 2003 (SI 2003/2426).

What cookies do we use?

We use the following types of cookie:

Necessary

These are essential for our website to function properly. This category only includes cookies that ensures basic functionalities and security features of the website. These cookies do not store any personal information.

Non-necessary

These may not be necessary for the website to function and are used to collect user personal data via analytics, ads, other embedded content and help us analyse and understand how you use our website. We always ask for your consent before using this type of cookie.

Blocking cookies

You can also disable cookies by changing settings on your browser that allows you to refuse the setting of all or some cookies. The settings and steps for managing cookies vary by browser, so we suggest referring to your browser’s documentation.

If you use your browser settings to block all cookies (including ‘Necessary’ cookies) you may not be able to access all or parts of our website.

Requesting more details about the cookies we use

For a detailed list of cookies we use including information about type of cookie, expiry periods and links to third party sites please contact privacy@curationcorp.com or click on this link www.curationcorp.com/cookie-policy

Cookie	Duration	Description
__hssrc	session	This cookie is set by Hubspot. According to their documentation, whenever HubSpot changes the session cookie, this cookie is also set to determine if the visitor has restarted their browser. If this cookie does not exist when HubSpot manages cookies, it is considered a new session.
cookielawinfo-checkbox-analytics	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Analytics".
cookielawinfo-checkbox-functional	11 months	The cookie is set by GDPR cookie consent to record the user consent for the cookies in the category "Functional".
cookielawinfo-checkbox-necessary	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookies is used to store the user consent for the cookies in the category "Necessary".
cookielawinfo-checkbox-non-necessary	1 year	This cookie is set by GDPR Cookie Consent plugin. The cookies is used to store the user consent for the cookies in the category "Non-necessary".
cookielawinfo-checkbox-others	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Other.
cookielawinfo-checkbox-performance	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Performance".
viewed_cookie_policy	11 months	The cookie is set by the GDPR Cookie Consent plugin and is used to store whether or not user has consented to the use of cookies. It does not store any personal data.

Cookie	Duration	Description
__hssc	30 minutes	This cookie is set by HubSpot. The purpose of the cookie is to keep track of sessions. This is used to determine if HubSpot should increment the session number and timestamps in the __hstc cookie. It contains the domain, viewCount (increments each pageView in a session), and session start timestamp.
_gat	1 minute	This cookies is installed by Google Universal Analytics to throttle the request rate to limit the colllection of data on high traffic sites.
bcookie	2 years	This cookie is set by linkedIn. The purpose of the cookie is to enable LinkedIn functionalities on the page.
lang	session	This cookie is used to store the language preferences of a user to serve up content in that stored language the next time user visit the website.
lidc	1 day	This cookie is set by LinkedIn and used for routing.

Cookie	Duration	Description
__hstc	1 year 24 days	This cookie is set by Hubspot and is used for tracking visitors. It contains the domain, utk, initial timestamp (first visit), last timestamp (last visit), current timestamp (this visit), and session number (increments for each subsequent session).
_ga	2 years	This cookie is installed by Google Analytics. The cookie is used to calculate visitor, session, campaign data and keep track of site usage for the site's analytics report. The cookies store information anonymously and assign a randomly generated number to identify unique visitors.
_gat_gtag_UA_39710400_12	1 minute	This cookie is set by Google and is used to distinguish users.
_gid	1 day	This cookie is installed by Google Analytics. The cookie is used to store information of how visitors use a website and helps in creating an analytics report of how the website is doing. The data collected including the number visitors, the source where they have come from, and the pages visted in an anonymous form.
_lr_hb_-trmgqt%2Fcuration-website	1 day
_lr_tabs_-trmgqt%2Fcuration-website	1 day
_lr_uf_-trmgqt	session
ajs_anonymous_id	1 year	This cookie is set by Segment.io to check the number of new and returning visitors to the website.
ajs_user_id	never	The cookie is set by Segment.io and is used to analyze how you use the website
AMP_TOKEN		This cookie is set by Google Analytics - This cookie contains a token that can be used to retrieve a Client ID from AMP Client ID service. Other possible values indicate opt-out, inflight request or an error retrieving a Client ID from AMP Client ID service.
AnalyticsSyncHistory	1 month
hubspotutk	1 year 24 days	This cookie is used by HubSpot to keep track of the visitors to the website. This cookie is passed to Hubspot on form submission and used when deduplicating contacts.a
li_gc	2 years

Cookie	Duration	Description
_fbp	3 months	This cookie is set by Facebook to deliver advertisement when they are on Facebook or a digital platform powered by Facebook advertising after visiting this website.
bscookie	2 years	This cookie is a browser ID cookie set by Linked share Buttons and ad tags.
UserMatchHistory	1 month