Privacy Statement

TRAFFIC is a leading non-governmental organisation working globally on trade in wild animals and plants in the context of both biodiversity conservation and sustainable development, headquartered in the UK and with offices around the world. TRAFFIC has launched the WildCheck platform and initiative to increase awareness and responsible sourcing of wild-harvested plant ingredients. For more information, please see the “Who We Are” section of our Website.

The personal information that we may collect about you broadly falls into the following categories:

• Information that you provide voluntarily

We may ask you to provide personal information voluntarily when you contact us via email (such as when you sign up to TRAFFIC's #WeUseWild Pledge (the "Pledge"), or when contacting us). TRAFFIC aims to raise awareness and support responsible sourcing of wild-harvested plant ingredients, and if you sign up to the Pledge or contact us via email, we may deliver important information to you about our responsible sourcing experience and advice, reports and news.

The personal information that you are asked to provide (e.g. your name, title, email address, company logo), and the reasons why you are asked to provide it (e.g. to display your organisation as a Pledge signatory), will be made clear to you at the point we ask you to provide your personal information.

• Information that we collect via cookies

When you visit our Website, we may collect certain information from your device. In some countries, including countries in the European Economic Area and the United Kingdom, this information may be considered personal information under applicable data protection laws.

The WildCheck platform is hosted on SquareSpace. TRAFFIC International is the data controller, while SquareSpace is the data processor. Squarespace collects personal data when you visit this website, including:

• Information about your browser, network and device

• Web pages you visited prior to coming to this website

• Web pages you view while on this website

• Your IP address

Squarespace needs the data to run this website, and to protect and improve its platform and services. Squarespace analyses the data in a de-personalized form.

Collecting this information enables us to better understand the visitors who come to our Website, where they come from, and what content on our Website is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Website to our visitors.

This information is collected using cookies, as explained further under the heading “Cookies and similar tracking technology” below. You have the option to decline the collection of this information by clicking ‘Decline’ on Manage Cookies.

• Information that we obtain from social media

TRAFFIC may also obtain your personal information through your use of social media platforms, for example Facebook or Twitter, depending on the privacy policies of those services and your privacy settings. For example, if you use the #WeUseWild hashtag in a Twitter post, the tweet may appear in a feed on our website. To change your privacy settings with these services, please refer to their privacy policies, which will explain how to do this.

We may disclose your personal information to the following categories of recipients:

• to our group companies (other TRAFFIC offices) and to SquareSpace, who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Website), or who otherwise process personal information for purposes that are described in this Privacy Statement or notified to you when we collect your personal information;

• to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;

• to any other person with your consent to the disclosure; and

• with other parties in connection of a corporate transaction, for example, in the event that TRAFFIC merges with another organisation in the future, we may share your personal information with that organisation.

We collect and use your personal information for the following reasons:

• responding to your queries and contacting you, if you request us to do so;

• improving our platform and ensuring that the Website runs smoothly, including troubleshooting, data analysis, testing, and research;

• furthering TRAFFIC's WildCheck campaign, for example by signing your organisation up to the #WeUseWild Pledge if you request to do so;

• to protect the rights of TRAFFIC;

• keeping our systems secure and preventing unauthorised access;

• for the purposes of detecting or preventing illegal activities;

• to ensure the effective operation of software and IT services procured by us (including disaster recovery); and

• for other reasons which we may inform you of from time to time via updates to this policy.

We do not use your personal information to carry out any automated decision making.

Our legal bases for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our platform and communicating with you as necessary to provide our services to you, for instance: collecting your information to list your organisation as a signatory to the #WeUseWild Pledge, once you have indicated your interest to do so.

We do not think that any of the above activities prejudice your rights. However, you have the right to object to us processing your personal information on this basis, as set out under the "Your data protection rights" heading below.

If you have questions about or need further information concerning the legal bases on which we collect and use your personal information, please contact us using the contact details provided under the “How to contact us” heading below.

We use cookies and similar tracking technology (collectively, “Cookies”) to collect and use personal information about you. For further information about the types of Cookies we use, why, and how you can control Cookies, please see our Cookie Statement.

TRAFFIC uses appropriate technical and organisational measures to protect the personal information that we collect and process about you via email. The measures we use are designed to prevent unauthorised access to, and misuse of, your personal information.

SquareSpace, the web-host of WildCheck and our data processor for web analytics and cookie data, details their security measures and safeguards here: https://www.squarespace.com/security.

Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective). Specifically, our Website servers are located in the United Kingdom, and our group companies and third-party service providers and partners operate around the world. This means that when we collect your personal information, we may transfer your personal information outside of the United Kingdom.

However, we implement appropriate safeguards to ensure that your personal information remains protected in accordance with this Privacy Statement. These measures include only transferring your personal information outside of the United Kingdom where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your personal information, for example:

• to third parties which are located in a country where there has been a finding of adequacy; or

• by way of a data transfer agreement with third parties incorporating standard contractual clauses.

For more information about these safeguards please contact us using the contact details provided under the “How to contact us” heading below.

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

You have various rights in relation to the personal information which we hold about you.

In certain circumstances, you can exercise the following rights:

• the right to be informed;
• the right of access;
• the right to rectification;
• the right to erasure;
• the right to restrict processing;
• the right to data portability; and
• the right to object.

Find out more about your rights here.

You can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading below.

Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time using the contact details provided under the “How to contact us” heading below. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority, which is the Information Commissioner's Office in the UK.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

We may update this Privacy Statement from time to time. Changes to this Privacy Statement will come into effect immediately upon such changes being published. Please visit this page if you want to stay up to date, as we will post any changes here.

You can see when this Privacy Statement was last updated by checking the “last updated” date displayed at the top of this Privacy Statement.

If you would like to exercise any of your rights or if you have any questions or concerns about our use of your personal information, please contact us at: WildCheck@traffic.org.

If you wish to exercise any of your rights related to web analytics and cookie data, please contact privacy@squarespace.com.

Please note that privacy@squarespace.comwe may keep a record of your communications to help us resolve any issues which you raise.

The data controller of your personal information is TRAFFIC International.