GENERAL INDEX WEBSITE PRIVACY POLICY

General Index Limited (“GX”) is a provider of commodity indexing solutions. References in this privacy policy (“Privacy Policy”) to “we”, “our” or “us” are references to General Index Limited. We operate the GX website available at: www.general-index.com (the “Website”) to promote the GX commodity indexing services and solutions and to provide you with the opportunity to register to receive information and promotional materials about those services and solutions.

We are committed to protecting and respecting the privacy of those who visit the Website (“you” or “your”). This Privacy Policy sets out the basis on which the personal data collected from you, or that you provide to us, will be processed by us as a result of you visiting the Website. Please read the following carefully to understand how we will use your personal data. For the purpose of data protection legislation in the UK, we are the controller of personal data we collect via the Website and we are registered with the Information Commissioner’s Office (the ICO), the supervisory body for the UK.

We handle customer data according to regulatory requirements. If you have an enquiry, please contact info@general-index.com.           

1. WHAT PERSONAL DATA DO WE COLLECT AND PROCESS, AND HOW DO WE USE IT?

When you access the Website, you may provide us with personal data, and we may collect and process such personal data in accordance with this Privacy Policy and for the following purposes: 

What personal data do we process?

- Identity Data: this may include your first name, surname, job title, employer and geographical location.

- Contact Data: this may include your email address, phone number(s), physical address and any other contact details you may choose to provide to us.

- Usage Data: we may process data regarding general technical use of the Website, such as IP addresses and diagnostic information.

Why do we process this personal data?
- To register your enquiry
- To contact you with details on our commodity indexing solutions
- To send you marketing and promotional material
- To identify any problems, defects or issues with the Website
- To optimise the performance of the Website
- To improve future versions of the Website

What is our lawful basis for processing?
- To satisfy our legitimate interests (to run and operate the Website, run our business and maintain our records)
- Your consent (you can withdraw your consent at any time by emailing info@general-index.com or clicking on the “unsubscribe” link in any email).
- To take steps to fulfil a contract with you
- To satisfy our legitimate interest (to enable you to use the Website most effectively, improve the usability of the Website and make any necessary modifications and updates to the Website).

2. WHO DO WE SHARE YOUR PERSONAL DATA WITH?
By using the Website, we may need to disclose your personal data to the following categories of third parties in limited circumstances:· 

Third party infrastructure providers: your personal data may be held and processed securely by us on the dedicated systems supplied, monitored and maintained by our third party infrastructure providers, such as our Website hosting provider and customer relationship management provider;

Regulators or law enforcement agencies: if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation, we may share your personal data with a regulator or law enforcement agency to comply with legal or regulatory requests.


3.  TRANSFERS OF YOUR PERSONAL DATA
We do not transfer your personal data outside of the EU(or the UK to the extent the UK is no longer part of the EU).If there are circumstances which would require us to transfer your personal data outside of the EU (or the UK to the extent the UK is no longer part of the EU), the following will apply. Where applicable, we may look to rely on an adequacy decision of the European Commission (for example, relying on a Privacy Shield certification where the transfer contains a US entity); click here for more information. Alternatively, in the case of transfers of your personal data outside of the EU (or the UK to the extent the UK is no longer part of the EU), where the transfers are not to countries that provide an adequate level of protection, we will use reasonable efforts to put in place appropriate safeguards to cover transfers of your personal data including, for example, signing standard contractual clauses/data protection clauses adopted by the European Commission. Please click here for a link to the standard contractual/data protection clauses and click here for more information about the Privacy Shield for US companies. If you would like further information, please contact us at info@general-index.com.

4. COOKIES
On visiting any website, browsers download and store text files holding small pieces of data which provides a record of your visit and allow full functionality of the website. They enable personalisation where applicable and to see how visitors use the site in order to make improvements for future visits.

GX uses performance cookies which collect aggregated information on how visitors use our website. Google analytics services help us to do this, as such we may share your site usage data with this provider. Functionality cookies are essential for certain of our website features, such as remembering your log-in details. Functionality cookies remember choices you make and allow us to provide an experience more appropriate to those choices. These cannot track browsing on other sites, and information collected may be anonymised where possible.

We require your consent for cookies to be enabled on devices. If you decline, information will not be tracked other than a single cookie in your browser to give effect to your request not to be tracked.  You can opt out via the Google Browser Add-On functionality using any browser. Additional information on cookies including further details on how to opt-out on different browsers can be found at www.allaboutcookies.org

The main cookies used on General Index website:
Name - GoogleAnalytics _ga
Description- This helps us understand how visitors arrive at and use the website
Retention Period - GoogleAnalytics: 2 years 

5. THE WEBSITE AND THIRD PARTY WEBSITES
The Website may contain links to third party websites. If you follow a link to a third party website, please note that this Privacy Policy does not apply to those websites. We are not responsible or liable for the privacy policies or practices of those websites, so please check their policies before you submit any personal data to those websites.

6. DATA RETENTION AND STORAGE

We store your personal data in line with legal, regulatory, financial and good-practice requirements. If you want to know more about our data retention policies, please contact us at info@general-index.com.This information is stored for as long as necessary and permitted by law for the legitimate business purpose(s) for which we originally collected it. In line with the GDPR storage limitation principle, we do not keep data for longer than is needed and data records are periodically reviewed and deleted or anonymised where possible. Personal data is stored on secure server sin line with GDPR guidelines. 

7.  ACCESSING YOUR PERSONAL DATA AND YOUR RIGHTS

As a result of us collecting and processing your personal data, you have the following legal rights:
· to access personal data held about you;
·  to request us to make any changes to your personal data if it is inaccurate or incomplete;
· to request your personal data is erased where we do not have a compelling reason to continue to process such data in certain circumstances;
· to receive your personal data provided to us as a data controller in a structured, commonly used and machine-readable format where our processing of the data is based on: (i) your consent; (ii) our necessity for performance of a contract to which you are a party to; or (iii) steps taken at your request prior to entering into a contract with us and the processing is carried out by automated means;
·  to object to, or restrict, our processing of your personal data in certain circumstances;
· if we use your personal data for direct marketing, you can ask us to stop and we will comply with your request;
· if we use your personal data on the basis of having a legitimate interest, you can object to our use of it for those purposes, giving an explanation of your particular situation, and we will consider your objection;
· to object to, and not be subject to a decision which is based solely on, automated processing (including profiling), which produces legal effects or could significantly affect you; and
· to lodge a complaint with a data protection supervisory body.

To exercise any of your rights set out above, including to withdraw your consent where we have stated we are processing your personal data based on your consent, please contact us at info@general-index.com.

8. CONTACTING US AND CHANGES TO YOUR PERSONAL DATA
If you have any questions, comments and requests about this Privacy Policy or your personal data, please email us at: info@general-index.com. Please notify us by email with any changes to your personal data at any time.

9. CHANGES TO OUR PRIVACY POLICY
Any changes we may make to this Privacy Policy in the future will be posted https://general-index.com/pages/privacy-policy-and-cookies. Please check back regularly to keep informed of updates or changes to this Privacy Policy. This Privacy Policy was last updated on 19 June 2020.