Privacy Policy

The ICA considers your privacy and that of the ICA members to be very important and this policy sets out the reasons for requesting and using information

Why are we updating our privacy policy?

The Data Protection Act (directive 95/46/EC) is being replaced by General Data Protection Regulation effective 25 May 2018. The new regulation helps us ensure that our members and stakeholders understand what personal data we hold relating to them, why we have it and how we use and store it. We want to ensure that our stakeholders understand and agree to our policy. If something is not clear, or you disagree, you can contact us at any time using the details below.

Privacy Policy

The ICA considers personal privacy to be very important and this policy explains why we might request personal information, how we store it and when we use it.

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 ICA Bremen.

What information do 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.

Sometimes, we collect and process data that GDPR terms “Special Categories” (Article 9). Special categories apply to data that reveal:

  • Racial or ethnic origin
  • Political opinions
  • Religious or philosophical beliefs
  • Trade union membership
  • Biometric data
  • Data concerning health or sexual orientation.

This is usually as part of our event registration process and we collect information such as dietary requirements and if you have health conditions. This information helps us to make necessary adjustments to our programmes to ensure that you have an enjoyable experience tailored to your needs. This information may be shared with a venue, who have the same obligation to protect your personal data as we do and to only use it for the purpose given.

How do we collect your data?

When you apply to become a member, we collect the information from your application.

When you visit our website, we use cookies. 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 and full name. The newsletter is provided through MailChimp, a third-party supplier, which gives us insights on links clicked and open rates.

If you register for one of our events or training opportunities, we collect the required information though our preferred software, E-Touches.

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.

How do we use your data?

Most of the data that we hold is processed with the legal basis of Legitimate Interest. Legitimate interest is when we have a business or commercial reason to use your data, but this does not mean that we can use your information in a way that is not right for you. This means that we make sure that you don’t miss out on news, membership matters, event and training dates by using your name, email address to send you notifications, emails and our newsletter. We also use your data in ways that enable us to provide useful services to our members and other stakeholders.

This can include, for example, contacting you:

  • to monitor the services we provide
  • to inform you of ICA services for our members
  • to publish Information that has been provided to ICA (e.g. your name, business name and email address) on our website.

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.

Keeping our records accurate

We aim to keep all Information as accurate as possible. If you would like to review or change the Information that you have supplied to us, please contact us using the details below. ICA will remove any data that is no longer relevant to business pursuit.

Keeping your data safe

All Information will be kept securely as 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 so as 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.

Your data, you’re in control

If at any time you decide that you do not want ICA to retain information that you have provided, you can exercise your right to erasure (right to be forgotten).

Article 17 of EU GDPR, The Right to erasure, states:

  1. Data Subjects have the right to obtain erasure from the data controller, without undue delay, where one of the following grounds applies:
  2. The personal data are no longer necessary in relation to the purposes for which they were collected
  3. The subject withdraws consent for the processing with which they previously agreed to (and it is not a legal requirement to keep it)
  4. The subject exercises their right to object (Article 21) to the data processing unless the controller demonstrates compelling legitimate grounds for the processing
  5. Personal data have been unlawfully processed
  6. Personal data have to be erased in accordance to a legal obligation.

Upon request, we will delete or anonymise personal data unless we are legally bound to keep it.

If you want to cleanse your data, contact us using the details below.

General

The ICA reserves the right to vary the terms and conditions of this policy from time to time, but always in keeping with GDPR principles. Such variations become effective immediately upon the posting of the varied policy on the ICA website. Our privacy policy is freely available on our website and hard copies are available upon request.

In the event that any term of this policy is held to be invalid, unlawful, void or for any reason unenforceable, that term shall be deemed severable and the remainder of this policy shall remain valid and enforceable. No waiver of any term of this policy shall be deemed a further or continuing waiver of such term or any other term.

This policy shall be governed and construed by the laws of England.

Our contact details

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 [email protected]

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