Privacy Policy

1. Introduction

Active Steward Ltd ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website and use our services related to Digital Product Passports for plastic products.

We comply with the General Data Protection Regulation (GDPR) and other applicable data protection laws. By using our website and services, you consent to the data practices described in this policy.

2. Information We Collect

2.1 Information You Provide

We may collect information that you voluntarily provide to us when you:

• Contact us through our website forms or email
• Request a demo or consultation
• Subscribe to our newsletter or marketing communications
• Register for an account or use our services
• Participate in surveys or provide feedback

This information may include your name, email address, phone number, company name, job title, and any other information you choose to provide.

2.2 Automatically Collected Information

When you visit our website, we may automatically collect certain information about your device and browsing behavior, including:

• IP address
• Browser type and version
• Operating system
• Pages visited and time spent on pages
• Referring website addresses
• Date and time of access

3. How We Use Your Information

We use the information we collect for the following purposes:

• To provide, maintain, and improve our services
• To respond to your inquiries and provide customer support
• To send you information about our products and services (with your consent)
• To process transactions and manage your account
• To analyze website usage and improve user experience
• To comply with legal obligations and protect our rights
• To prevent fraud and ensure security

4. Legal Basis for Processing (GDPR)

Under GDPR, we process your personal data based on the following legal bases:

• Consent: When you have given clear consent for us to process your data for specific purposes
• Contract: When processing is necessary for the performance of a contract with you
• Legal Obligation: When we need to comply with a legal obligation
• Legitimate Interests: When processing is necessary for our legitimate business interests, provided they do not override your rights and freedoms

5. Data Sharing and Third Parties

We do not sell, trade, or rent your personal information to third parties. We are committed to protecting your privacy and will only share your information in the following limited circumstances:

• Service Providers: We may share information with trusted service providers who assist us in operating our website and conducting our business, provided they agree to keep this information confidential and use it only for the purposes we specify
• Legal Requirements: We may disclose information if required by law, court order, or government regulation
• Business Transfers: In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction
• With Your Consent: We may share your information with third parties when you have given us explicit consent to do so

All third parties with whom we share data are contractually obligated to maintain the confidentiality and security of your information and to use it only for the purposes we specify.

6. Data Security

We implement appropriate technical and organisational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include encryption, secure servers, access controls, and regular security assessments. However, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

7. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. When we no longer need your information, we will securely delete or anonymize it.

8. Your Rights Under GDPR

If you are located in the European Economic Area (EEA), you have the following rights regarding your personal data:

• Right of Access: You have the right to request access to your personal data and receive a copy of the data we hold about you
• Right to Rectification: You have the right to request correction of inaccurate or incomplete data
• Right to Erasure: You have the right to request deletion of your personal data under certain circumstances
• Right to Restrict Processing: You have the right to request restriction of processing of your personal data
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used format
• Right to Object: You have the right to object to processing of your personal data for direct marketing purposes or based on legitimate interests
• Right to Withdraw Consent: Where processing is based on consent, you have the right to withdraw consent at any time

To exercise any of these rights, please contact us using the information provided in the "Contact Us" section below.

9. Cookies and Tracking Technologies

Our website may use cookies and similar tracking technologies to enhance your browsing experience. Cookies are small text files stored on your device that help us analyze website traffic and improve our services.

You can control cookies through your browser settings. However, disabling cookies may affect the functionality of our website.

10. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. We ensure that appropriate safeguards are in place to protect your data in accordance with this Privacy Policy and applicable data protection laws.

11. Children's Privacy

Our services are not intended for individuals under the age of 16. We do not knowingly collect personal information from children. If we become aware that we have collected information from a child under 16, we will take steps to delete such information promptly.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the "Last updated" date. We encourage you to review this Privacy Policy periodically.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

You also have the right to lodge a complaint with your local data protection authority if you believe we have not addressed your concerns adequately.