Privacy Policy

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Our Organisation

The International Cotton Association Limited, or ICA, is the world’s leading cotton trade association and arbitral body. Established in 1841, we operate on a not-for-profit basis which means that the income we generate is used to pursue the organisation’s objectives. Our mission is to protect the legitimate interests of all those who trade cotton. The services that we provide are membership, training, networking and arbitration along with cotton testing and research through our joint venture company, ICA Bremen.

This privacy policy concerns information that relates to a person and / or could be used to identify a person (“personal data”) that is collected by the ICA. “Non-personal data” is therefore any information that does not relate to a person and / or cannot be used to identify a person. We take the privacy of your personal data seriously. Please read this privacy policy as it includes important information regarding your personal data and other information.

Our Privacy Policy

Information we collect

The types of information that we collect across the organisation are:

Name, date of birth, email address, telephone numbers, personal addresses, IP addresses, device information, business name, business address, nature of business, business age, registration number, website, trading volume, nationality, directorship, annual accounts, association memberships. We also use your banking details to make and receive payments.

We collect your data through a variety of methods. For example, when you apply to become a member, we collect the information from your application.

We use your details from your membership application to populate our member directory and safe trading search on our website. We also add your details to our membership database.

When you sign in to your member area on our website, we see your email address and we can see which pages you visit.

When you sign up to our newsletter, we ask for your email address. The newsletter is provided through Mail Chimp, a third-party supplier, which gives us insights on links clicked and open rates.

When you visit our website we use cookies.

Any data that we share with third-party suppliers is given in order to provide our services.  We have carefully reviewed our suppliers to ensure that their data protection processes are compliant and secure.

When registering for our training or trade events, we collect more detailed personal information from you to help us make necessary adjustments to our programme to ensure you have an enjoyable experience tailored to your needs. Please view our Events Privacy Policy to see the full details:

We will request your consent to this policy before successfully registering you for any of our events.

 

Information that you provide directly

We collect personal information from you:

  • through the use of forms, which may be on paper or on our Websites, such as when you login to access our Services, signup to receive our newsletters, register for information;
  • when you book an event through the ICA and provide us with information about any special requirements, such as dietary requirements, that you may have; and
  • if you choose to provide us with information when you use our Website or access our events;
  • when you communicate with us for any reason, including by email, postal mail or telephone, and when you use our Services.

Some of the personal information that you provide may include sensitive personal information, such as health-related information, biometric data which we need for events, courses, statutory registration/reporting purposes and to ensure that we can provide the necessary duty of care.

 

Information we collect automatically

When you visit our Website, we may collect certain information automatically from your device.

Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Website, including the pages accessed and links clicked.

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.

Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading ‘Cookies’, below.

 

Information we collect from third party sources

We may receive personal information about you from third party sources:

  • As part of an arbitration process
  • such as your employer if they enrol you on an event or course, or only where we believe that these third parties either have your consent or are
  • Otherwise legally permitted or required to disclose your personal information to us.

We collect only the minimum amount of information required from these third parties to enable us to provide the requested service or process. We only use the information we receive from these third parties as set out in this Privacy Policy.

 

Use of your information

The information that we collect and store relating to you is primarily used to enable us to provide our Services to you. In addition, we may use the information for the following purposes:

  • to monitor the services, we provide
  • to provide you with information or Services you request from us;
  • to publish information that has been provided to the ICA (e.g. your name, business name and email address) on our website;
  • to provide arbitration services
  • we will use our email tools to contact attendees with information relating to past or current events, to inform you of important event information, hotel bookings, pre-arrival information and post event surveys;
  • to provide information on other ICA courses and events which we feel may be of interest to you, in accordance with your consent;
  • to meet our contractual commitments to you;
  • to obtain additional personal information to satisfy statutory legal or association requirements;
  • the ICA reserves the right to report any activity which violates any relevant laws or regulations to the appropriate authority. If the ICA is requested by such authority for the Information, the ICA reserves the right to disclose it to them.

Other ways we use your data

  • Other details are used for the purposes of representing the interests of ICA members when trading and as part of our function as an arbitral authority. Information regarding ICA members may be included on an ICA website as part of the ICA awards and arbitration process.
  • The Information provided by you or an ICA member may be shared with ICA members. Information that is part of the arbitration process will not be shared.
  • Information gathered from the arbitration may be stored and used for statistical and service delivery purposes.
  • The Information may also be shared with the Committee for International Co-operation between Cotton Associations for the purpose of improving trading practices. The ICA may share the Information with any relevant judicial body.
  • The ICA reserves the right to report any activity which violates any relevant laws or regulations to the appropriate authority. If the ICA is requested by such authority for the Information, the ICA reserves the right to disclose it to them.

In general, we will use any of the information we collect from you only for the purposes described in this Privacy Policy or for purposes that we explain to you at the time we collect such information.

However, we may also use your personal information for other purposes that are not incompatible with the purposes we have disclosed to you (such as statistical purposes) if and where this is permitted by applicable data protection laws.

If you do not want us to use your data for any marketing purposes, you will have the opportunity to withhold your consent to this when you provide your details to us.

Consent can be removed by emailing at comms@ica-ltd.org

 

Storing and retaining your personal data

The personal information you provided to us is stored within secure servers. We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information.

All ICA email addresses support TLS email encryption, so it is advised that if you are concerned about the contents of any email to use this encryption.

Where we have given you (or where you have chosen) a password so that you can access certain parts of our sites and portals, you are responsible for keeping these passwords confidential.

Please note that the transmission of information via the internet (including email) is not completely secure and therefore, although we endeavour to protect the personal information you provide to us, we cannot guarantee the security of data sent to us electronically and the transmission of such data is therefore entirely at your own risk. 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 or statutory need to process your personal information, we will either delete or anonymise it.

 

Disclosing your information

We consider your information to be a vital part of our relationship with you. Therefore, we will not sell your personal data to third parties, including third party advertisers. There are, however, certain circumstances in which we may disclose, transfer or share your personal data with certain third parties without further notice to you, as set forth below.

  • Parent companies, subsidiaries and affiliates:
    We may share your personal data with our parent companies, subsidiaries (e.g. ICA Bremen)and / or affiliates for purposes consistent with this privacy policy. Our parent companies, subsidiaries and affiliates will be bound to maintain that personal data in accordance with this privacy policy.
  • Agents, consultants and service providers:
    We may share your personal data with our contractors and service providers who process personal data on behalf of the ICA to perform certain business-related functions. These companies include our arbitrators, venues, hotels, marketing team, backup and disaster recovery service providers, email service providers and others. A list is available on request but maybe specific to the business function or an event. When we engage another company to perform such functions, we may provide them with information, including personal data, in connection with their performance of such functions.
  • Legal requirements
    We may disclose your personal data if required to do so by law in order to (for example)respond to a subpoena or request from law enforcement, a court or a government agency (including in response to public authorities to meet national security or law enforcement requirements), or in the good faith belief that such action is necessary to (a) comply with a legal obligation, (b) protect or defend our rights, interests or property or that of third parties, (c) prevent or investigate possible wrongdoing in connection with the services, (d) act in urgent circumstances to protect the personal safety of attendees or the public, or (e) protect against legal liability.

Where data maybe processed outside of the EU we will endeavour to ensure the data is processed safely and securely by the third party.

 

Keeping your data safe

All Information will be kept secure and confidential. This means that information can only be exchanged between you, the ICA and any third party to whom the ICA decides to transfer the information to for the purposes detailed above. We follow strict security procedures for storing and disclosing data to prevent unauthorised access.

The ICA uses industry standard practise to safeguard the confidentiality of the information. We treat your information as an asset that must be protected against loss and unauthorised access. ICA employees and relevant contractors use many different security techniques to protect the information from unauthorised access by users inside and outside the ICA. These include password protection, encryption, firewalls and backup files.

You can view the global privacy policy of Aventri (Event registration management system) here >

 

Third party links

You might find links to third party websites on our Websites or within documentation we provide.

If you access other websites using the links provided, the operators of these sites may collect information from you which will be used by them in accordance with their own privacy policies which you should review.

We do not accept any responsibility or liability for their policies whatsoever as we have no control over them.

 

Delegate lists

We may use your personal data to populate an event delegate list for each event which may be made accessible to all other attendees. If you do not wish for this to happen then please let us know at the earliest possible opportunity.

 

Social networking

The Website may offer you the opportunity to share or follow information about us (or the Website or our Services) using third party social networking functionality (such as through “share this”, “like” or “follow” buttons).

We offer this functionality in order to generate interest in us, the Website and our Services among the members of your social networks, and to permit you to share and follow opinions, news and recommendations about us with your friends. However, you should be aware that sharing personal or non-personal information with a social network may result in that information being collected by the social network provider or result in that information being made publicly-available, including through Internet search engines.

Please note that we do not exercise, endorse or control the policies or practices of any third-party social network whose functionality you may access through the Website.

You should always read the Privacy Notice of any social network through which you share information carefully in order to understand their specific privacy and information usage practices.

 

International data transfers

For some of our Services, your personal information may be transferred to, and processed in, countries outside of the EEA. However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Policy. These measures include transferring your personal data to third parties who are located in a country which the European Commission has determined has data protection laws that are at least as protective as those in Europe and transferring your personal data to third parties who have entered into standard contractual clauses with us. For more information about these safeguards please contact us using the contact details provided below.

 

Legal basis

Our legal basis for collecting and using personal information will depend on the personal information being collected and the specific context in which we collect it.

However, we will normally collect personal information from you only:

  • where we need the personal information to perform a contract with you or your business;
  • where the processing is in our legitimate interests and is not overridden by your rights; or
  • where we have your consent to do so;

In some cases, we may also have a legal obligation to collect personal information from you.

If we ask you to provide personal information to comply with a legal requirement or to perform a contact 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 website and communicating with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our website, undertaking marketing. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided below.

 

Cookies

We use cookies and similar tracking technology (collectively, “Cookies”) to collect and use personal information about you.

What are cookies?

Cookies are pieces of information that a website transfers to your computer’s hard disc for record keeping purposes. Cookies can make the web more useful by storing information about your preferences on particular sites, thus enabling website owners to provide more useful features for their users. They contain no name or address information or any information that will enable anyone to contact you via telephone, e-mail or any other means. Most browsers are initially set to accept cookies. If you would prefer, you can set your browser to disable cookies or inform you when they are set. However, given that we may sometimes use cookies you may not be able to take full advantage of our website if you do disable them.

Which cookies do we use?

We use the following cookies on this website:

  • Google Analytics:
    We use Google Analytics to collect information about visitor behaviour on our website. Google Analytics stores information about what pages you visit, how long you are on the site, how you got here and what you click on. This Analytics data is collected via a JavaScript tag in the pages of our site and is not tied to personally identifiable information. We therefore do not collect or store your personal information (e.g. your name or address) so this information cannot be used to identify who you are. We have turned on Google Analytics Demographics and Interest Reporting to get an idea of our demographics and users’ interests. Please see above for how we use this data.
  • WordPress:
    Our websites runs the popular WordPress CMS and cookies are used to store basic data on your interactions with WordPress, and whether you have logged into WordPress. We use a session cookie to remember your log-in for you if you are a registered user and we deem these as being strictly necessary to the working of the website. If these are disabled then various functionality on the site will be broken.

 

Data protection rights

You have the following data protection rights:

  • If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided below.
  • In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided below.
  • You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “Manage your Marketing Preferences” link in the marketing e-mails we send you and within our Websites.
  • Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. 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.

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

 

Contacting us

The data controller of your personal information will be the ICA unless your data has been captured directly by a third party:

We welcome any queries, comments or requests you may have regarding this Privacy Policy. Please do not hesitate to contact us via email at

Address: The International Cotton Association Limited
6th Floor
Walker House
Exchange Flags
Liverpool
L2 3YL
United Kingdom

Telephone +44 (0)151 236 6041
Fax +44 (0)151 255 0174
Email info@ica-ltd.org

 

Changes to this Privacy Policy

We may change this Privacy Policy from time to time by updating this document.

You should check this page from time to time to ensure that you are happy with any changes.

If material changes are made to this Privacy Policy, we will notify you by placing a prominent notice on the Website or by contacting you to let you know via the contact details you have provided us with.

 

Policy last updated 11 March 2019

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