top of page

Privacy Policy

This Privacy Statement applies to personal data collected, used, stored, and otherwise processed by Transformative Procurement Change, 637 Chemin de la Gabelle, 06220 Vallauris, France referred to as “Transformative Procurement Change,” “we,” or “our”) in connection with our online and mobile applications, including https://www.transformativeprocurement.com (collectively, the “Website”).


This Privacy Statement explains the types of personal data we collect from and about our Website visitors, Users of our Online Evaluation Tool and Reporting, Contractors and Other Business Contacts, Attendees of our events, and Sponsors (“you” and “your”), and how we use, disclose, and protect that data, as well as your rights regarding your data.

 

1. What is personal data?

Personal data refers to any information relating to an identified or identifiable natural person (also known as a ‘data subject’). This includes, for example, your name, telephone number, address, and email address.

We do not knowingly collect personal data from individuals under the age of 18.

 

2. What types of data are automatically collected through the Website?

The Website automatically collects certain information about you through local storage and session storage technologies, including cookies and web beacons (also known as clear gifs, pixel tags, and single-pixel gifs) (collectively referred to as “Cookies”). Cookies are small files or data pieces downloaded or stored on your computer or device, linked to your usage of the Website and certain third-party services and features.

 

Examples of information gathered by Cookies include your IP address, the browser and operating system you are using, the pages you visit on the Website, and details about your transaction activity, such as the amount, date, and time of each transaction. We may engage third-party companies to customize content on the Website or to deliver interest-based ads and messages on our behalf. These companies may use Cookies to evaluate the effectiveness of advertising or messaging, tracking metrics like which web pages are visited, which messages receive responses, and what products are purchased.

 

When accessing the Website from a mobile device, we may also collect additional categories of information, including:

 

  • Your name associated with your mobile device

  • Your mobile phone number

  • Your geolocation

  • Your mobile device ID information

 

With your express consent, your contacts and/or contact information (e.g., names, phone numbers, physical addresses, email addresses, photos) stored on or through your mobile device

With your express consent, information about third-party software applications on your mobile device (including general software apps, downloadable software apps, and social media apps)

We maintain social media pages on third-party networks and feature social media icons on our Website. When you visit or link to our social media pages, data is processed by both us and the relevant social media provider. Please note that social media providers are independent of us, and we are not responsible for their content or privacy practices. Each social media provider has its own terms of use and privacy policies, which we encourage you to review whenever you interact with their platforms.

 

3. What Do We Use Your Personal Data For?

At Transformative Procurement Change, we utilize personal data for various purposes, depending on your relationship with us.

 

Visitors to Our Website

 

We process the personal data automatically collected from visitors to our Website for the following purposes:

 

  • To display tailored advertisements based on your interests.

  • To manage and ensure the integrity of our Website.

  • To provide, maintain, and protect the functionality of our Website.

  • To analyze usage of our services and tools.

  • To monitor the performance of our Website and enhance your user experience.

​​

Users of Our Products and Services

​

At Transformative Procurement Change, we value your privacy and are committed to protecting your personal data. We process personal data for users of our products and services for the following purposes:

  • Evaluation Form Submission: We collect your responses through evaluation forms or surveys to assess and report on your sustainable procurement maturity. This data helps us provide tailored recommendations for improvement.

  • User Registration and Confirmation: We process your registration for our tools and services, sending you confirmation of your account setup to ensure a smooth onboarding experience.

  • Data Analysis and Reporting: We analyze the data you provide to generate insights and reports that reflect your organization's procurement maturity. This analysis helps us identify trends and areas for development.

  • User Support and Communication: We communicate with you regarding your use of our products and services, including answering questions, providing technical support, and offering guidance to maximize your experience.

  • Improving User Experience: We monitor and analyze the usage of our products and services to enhance their functionality and overall user experience. Your feedback plays a crucial role in our continuous improvement efforts.

  • Marketing and Updates: With your consent, we may send you updates about our services, relevant content, and promotional materials related to sustainable procurement practices. This helps keep you informed about new offerings and industry insights.

  • Feedback Collection: After using our products and services, we may reach out to ask for your feedback. This information is invaluable in helping us refine and improve our tools, resources, and training programs.

We are committed to ensuring that your personal data is processed fairly and in accordance with applicable laws. If you have any questions about how we handle your data or our privacy practices, please contact us using the contact form available on our website.

Contractors and Other Business Contacts

 

For contractors, service providers, suppliers, and other business contacts, we use personal data for the following purposes:

  • To communicate about agreements and their performance.

  • To finalize agreements with you or your organization.

  • To process payments as necessary.

  • To maintain our commercial relationship.

  • To comply with legal obligations related to payments.

  • To keep an archive of agreements, including their conclusion and performance, and to manage disputes.

 

4. On What Legal Grounds Do We Process Your Personal Data?

At Transformative Procurement Change, we process your personal data based on the following legal grounds:

  • Performance of an Agreement: We process your data when it is necessary to fulfill an agreement with you or to take pre-contractual steps at your request.

  • Compliance with Legal Obligations: We process your data to comply with applicable legal obligations, such as tax administration duties or when required to disclose personal information to government authorities.

  • Your Consent: We may process your data based on your consent, which includes your opt-in to receive emails from communications from us, as well as your agreement to collect location data through our app (when applicable). You have the right to revoke your consent at any time; however, this will not affect the legitimacy of processing that occurred prior to your revocation.

  • Necessity for Agreements and Legal Obligations: Certain personal data are essential for us to conclude agreements with you and to fulfill our legal obligations.


5. What Third Parties Receive Your Personal Data?

We may share your personal data with our affiliated companies, which may be located outside your country of residence.

We share personal data of users (with their consent) with our partners and sponsors as appropriate. We make commercially reasonable efforts to ensure that these partners process personal data in accordance with the consent provided and solely for the purposes outlined in our communications. Please note that our partners are unaffiliated with us, and we cannot be held responsible for their privacy practices. We encourage you to review their privacy policies before consenting to share your information with them.

We utilise several service providers to assist us in promoting, marketing, and organizing our initiatives. We also employ service providers that support our business operations, such as our website hosting provider, email and document management systems, customer relationship management systems, and financial advisors.

In the event of any reorganisation, merger, sale, joint venture, assignment, transfer, liquidation, or other disposition of all or any portion of our business, assets, or stock, we may share your data with third parties involved in that process.

Additionally, we may be required by law to disclose your personal data to third parties, including government authorities.

 

6. International Transfers

If you are from the European Economic Area (EEA) or the United Kingdom (UK), please note that some of our external third parties (service providers, sponsors) are based outside the UK and EEA so their processing of your personal data will involve a transfer of data outside the UK and EEA. When we transfer your personal data out of the UK and EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

 

  • the country to which personal data is being transferred has been deemed to provide an adequate level of protection for personal data by the European Commission; 

  • the party to whom the personal data is transferred and who is established outside the UK and EAA has a Data Privacy Framework certification; or

  • standard contractual clauses that have been approved by the European Commission have been concluded with respect to the transfer.

 

7. How do we secure your personal data?

At Transformative Procurement Change, we implement reasonable administrative, physical, and technical measures to safeguard your personal data and communications with us. This includes, when necessary and deemed appropriate, the use of encryption and obtaining written commitments from third parties who may have access to your data, ensuring they protect it with reasonable safeguards.

 

We also make commercially reasonable efforts to ensure that our service providers utilize encryption to protect your personal data from unauthorized access.

 

However, it's important to note that no Internet or email transmission is completely secure or error-free. Therefore, while we strive to protect your data, we cannot guarantee absolute security, and we are not responsible for the processes and networks we do not control. Users assume the risk of security breaches and any consequences that may arise from them. Please exercise caution when deciding what information you send to us via email or the Internet.

 

If you would like to receive a copy of the relevant safeguards we have in place, please contact us using the details provided at the bottom of this Privacy Statement.

8. How long are your personal data retained?

We will retain your personal data only as long as necessary to fulfill the purposes for which we process it and, where applicable, for any purposes that are compatible with those purposes. For instance, we may retain your personal data for a longer duration in the event of a complaint or if we reasonably believe there is a possibility of litigation concerning our relationship with you or the organization you represent.
 

9. Automated decision-making and profiling

Your personal data is not used in any automated decision making (a decision made solely by automated means without any human involvement) or profiling (automated processing of personal data to evaluate certain conditions about an individual).
 

10. What rights do you have with respect to your data?

Your Rights

 

At Transformative Procurement Change, we are committed to facilitating the exercise of your rights under applicable laws, which may include the right to request the correction, modification, or deletion of your personal data, as well as the right to opt out of the sale or sharing of your personal information, where applicable. We will make every effort to honor your requests while adhering to legal and contractual obligations.

 

If you would like to make a request, cancel your account, or request the deletion of your personal information, please contact us using the contact form or update your user profile information as applicable.

 

You can opt out of receiving electronic marketing communications from us by clicking the “unsubscribe” link in our communications or by contacting us . Please note that certain non-marketing communications, such as those related to transactions, legal disclosures, software updates, and support-related information, may not be subject to a general opt-out.

 

Subject to local law, you may have additional rights regarding your personal data, including the right to complain to your local data protection authority and the right to appeal our decisions regarding data access requests.

 

You may be able to disable cookies through your browser settings. However, if you delete or disable cookies, you may experience limited functionality or interruptions in certain areas of our services.

 

Under the General Data Protection Regulation (GDPR)

 

If you are located in the EEA, the UK, or another jurisdiction that has adopted laws substantially similar to the GDPR, you have the following rights:

 

Access: You have the right to request access to your personal data, commonly known as a “data subject access request.” This allows you to receive a copy of the personal data we hold about you and confirm our lawful processing of it.

 

Correction: You can request the correction of any incomplete or inaccurate personal data we hold about you. We may need to verify the accuracy of the new data you provide.

 

Erasure: You have the right to request the deletion or removal of your personal data when there is no valid reason for us to continue processing it. This right also applies if you have successfully exercised your right to object to processing or if we processed your information unlawfully. Please note that we may not always be able to comply with your request for erasure due to specific legal reasons, which we will inform you about, if applicable.

 

Objection: You have the right to object to the processing of your personal data where we rely on legitimate interests (or those of a third party), particularly if there is something about your situation that prompts you to object, as you believe it impacts your fundamental rights and freedoms. You can also object to our processing of your personal data for direct marketing purposes. In some cases, we may demonstrate compelling legitimate grounds for processing that override your rights and freedoms.

 

Restriction: You can request the restriction of the processing of your personal data in specific situations, such as when you want us to verify the data's accuracy or when our use of the data is unlawful but you do not want it erased.

 

Transfer: You have the right to request the transfer of your personal data to you or to a third party. We will provide your personal data in a structured, commonly used, machine-readable format. This right only applies to automated information you initially provided to us based on your consent or for which we used the information to fulfill an agreement with you.

 

Withdraw Consent: You can withdraw your consent at any time where we rely on consent to process your personal data. However, this withdrawal will not affect the lawfulness of any processing carried out before your consent was withdrawn.

 

Complaints: You have the right to make a complaint to the relevant regulatory authority. The regulatory authority in France is the Commission Nationale de l'Informatique et des Libertés (CNIL).

 

To ensure the security of your personal data and verify your identity when you exercise your rights, we may request specific information from you. This measure helps prevent unauthorized access to personal data. We may also contact you for additional information to expedite our response. We may be entitled to refuse your request, in whole or in part, and will inform you if this occurs.

 

11.How do we respond to “Do Not Track” browser signals?

Our website does not respond to Do Not Track (DNT) signals.

 

12.How can you contact us?

If you have any questions regarding this Privacy Statement or your privacy, you can contact us using the Contact Form or write to Transformative Procurement Change, 637 Chemin de la Gabelle, 06220 Vallauris, France


13.Can we change this Privacy Statement?
Yes, we may have to change this Privacy Statement from time to time, e.g. to reflect relevant changes to the processing activities. We will indicate at the bottom of the notice when it was most recently updated. We will also communicate changes as required by applicable law.

Dated: 10th October 2024

bottom of page