Privacy policy

Introduction This privacy policy explains how personal data is processed when using ESG Tool, an ESG evaluation tool designed to help companies get started on their ESG journey. The tool gives a helping hand in assessing their risks, opportunities, and impacts for sustainability reporting. The tool is offered for free, as part of a collaboration between sector organizations and public sector entities and funded by Interreg Baltic Sea Region.

The project consortium consists of:

From Estonia

• Ministry of Economic Affairs and Communications (MKM); Ministry of Finance of Estonia;

• The Estonian Association of Information Technology and Telecommunications (ITL);

• Zero Waste Estonia Foundation;

From Latvia

• Ministry of Smart Administration and Regional Development (VARAM);

• Latvian Information and Communications Technology Association (LIKTA);

From Lithuania

• Association INFOBALT;

And from Finland

• DIMECC.

We value your privacy and are committed to ensuring the protection of your personal data following the General Data Protection Regulation (GDPR), as well as other applicable national and international laws.

Data controller ESG Tool consortium is responsible for the data, and the data controller is responsible for processing personal data concerning the use of ESG Tool.

What data we collect We may collect and process the following types of organizational data when you use ESG Tool:

1. Name of the organization

2. Fiscal registration number (VAT or equivalent)

3. Contact person and authorized persons who can access and edit organization data

4. Role in the enterprise

5. Email address

6. Organization staff size

7. Organizations foundation year

8. Organization operation sector based on NACE

9. The country where the Organization's business unit is located (Lithuania, Latvia, Finland, Estonia, and others)

10. Company-specific data filling in the assessment.

Purpose of data collection We collect personal data for the following purposes:

• To provide access to and facilitate the use of ESG Tool.

• To offer support services, respond to inquiries, and provide feedback on tool usage.

• To monitor, evaluate, and improve the tool’s functionality and performance.

• To carry out statistical analyses on anonymized data to enhance sustainability reporting practices across industries.

• To inform you of updates, changes, or new features of the tool.

We do not use your data for marketing purposes unless you explicitly consent to receive promotional content.

Legal basis for processing The legal bases for processing your data are as follows:

• Consent (GDPR Article 6(1)(a)): when you voluntarily provide data, such as feedback or responses to surveys.

• Performance of a contract (GDPR Article 6(1)(b)): when we process data to fulfill our service commitments, including offering access to the tool and responding to your requests.

• Legitimate interests (GDPR Article 6(1)(f)): we may process your data to improve our tool and understand usage patterns without infringing on your rights.

How we use your data Personal data is used to:

• Facilitate your use of ESG Tool by creating user accounts and ensuring accessibility.

• Track and analyze usage trends to continuously enhance the tool’s functionality and improve the user experience.

Data sharing We may share your data with:

• Service providers: we work with third-party companies to help maintain and improve the tool. These include cloud service providers, analytics providers, and IT support teams.

• Research partners: data will be anonymized and aggregated for research purposes with our partners in our consortium, ensuring that your identity is not disclosed.

We do not sell, rent, or lease your data to third parties for marketing purposes. Data is shared only as necessary to deliver the services outlined in this policy.

Data retention We retain personal data for no longer than necessary to fulfill the purposes outlined in this policy:

• Personal data related to your account and usage of the tool will be retained for as long as you continue to use ESG Tool.

• Anonymized and aggregated data for research and statistical purposes may be retained indefinitely.

• If you choose to delete your account, all associated personal data will be erased within 24 hours unless retention is required by law. However, please note that we are required to maintain records of the companies that access or use the tool.

User rights As a user of ESG Tool, you have the following rights:

1. Right of access: you have the right to request access to the personal data we hold about you.

2. Right to erasure ("Right to be forgotten"): you can ask us to delete your personal data, especially if the data is no longer necessary for the purposes it was collected.

3. Right to data portability: you have the right to receive your personal data in a structured, commonly used format and transfer it to another data controller.

4. Right to object: you may object to the processing of your personal data where we rely on legitimate interests.

5. Right to withdraw consent: if processing is based on your consent, you can withdraw it at any time without affecting the legality of the processing carried out prior to withdrawal.

Use of cookies ESG Tool uses cookies to enhance user experience and for basic operational functionality. Cookies are small text files stored on your device when you access the tool. We use both session cookies, which expire after you close your browser, and persistent cookies, which remain on your device for a defined period. You can manage or disable cookies through your browser settings, but note that disabling certain cookies may impact the functionality of ESG Tool. Third-party services ESG Tool may contain links to third-party websites, services, or resources. Please note that this privacy policy applies solely to ESG Tool and does not extend to other services. We are not responsible for the privacy practices or content of third-party websites, so we encourage users to review the privacy policies of those external services.

Changes to this Privacy policy We may occasionally update this privacy policy to reflect legal, technical, or service-related changes. We will notify you of any significant changes by email or via the tool itself. Your continued use of ESG Tool after any modifications implies your acceptance of the updated policy.

Confidentiality We are committed to ensuring the confidentiality of all company-related data provided through the ESG Tool. All information collected will be handled with discretion and will only be accessible to authorized personnel who require it to perform their duties as consortium members. Any data shared with third parties, such as research partners or service providers, will be anonymized or aggregated to prevent the disclosure of any identifiable details. We implement strict confidentiality protocols to safeguard your data and ensure it is not disclosed, altered, or misused.

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Contact information If you have any questions or concerns about this privacy policy, or if you wish to exercise your data protection rights, please contact us through the tool´s About Us section.