1. General information
AMBI WASTE is committed to the privacy of Users and the security of their personal data, and therefore undertakes to use them in accordance with its legal responsibilities, in accordance with the General Data Protection Regulation (“GDPR“) and Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights (“LOPDGDD“).
In this sense, the following shows the identification details of AMBI WASTE, as the party responsible for the processing of Users’ personal data:
|Avenida de Burgos, 17, 9º Dcha. 28036, Madrid, Spain.
|Contact telephone number
|+34 91 277 57 89
2. Personal data and purposes of processing
In order to offer Users the services and functionalities available on Circular Place, AMBI WASTE may collect certain personal data from Users.
All personal data collected through Circular Place will be duly processed by AMBI WASTE. Likewise, AMBI WASTE keeps all data processing correctly updated through its Register of Processing Activities.
On the other hand, AMBI WASTE informs users that the fields requested in the forms that are marked with an asterisk are mandatory. Thus, if the requested information is not provided, AMBI WASTE will not be able to carry out the service.
The personal data that AMBI WASTE collects, the purposes for which they are used together with the basis for their legitimacy, and the length of time that the Users’ personal data are generally retained, are specified below
A. Registration and user account creation in Circular Place
In order to facilitate the functions and purposes of Circular Place, AMBI WASTE gives Users the possibility to register with Circular Place as (i) a Collective Extended Producer Responsibility Scheme (hereinafter “EPRS“); (ii) a producer or manufacturer of electrical and electronic equipment (hereinafter “Producer“), or (iii) a non-profit organisation or educational institution (hereinafter “Beneficiary“)
- CRSO registration
CRSOs, non-profit organisations formed by manufacturers and importers of electrical and electronic equipment, wishing to participate in Circular Place will need a user account on the platform.
The User data corresponding to CRSO will be pre-loaded by AMBI WASTE, using the contact name and email address collected during the contractual relationship between the parties for pre-registration. Once the User profile has been configured, CRSO will be notified of the creation of its account in Circular Place by e-mail, and CRSO must confirm the pre-registration within two (2) months and update its password to access the Platform.
If the aforementioned period elapses without receiving confirmation of registration, the pre-loaded CRSO account will be blocked, and the process of registering as a Circular Place User will have to be restarted.
- Registration as a Producer
Producers may register with Circular Place, as long as they are members of AMBI WASTE or one of the CRSOs registered with Circular Place.
To do so, Users must indicate in the pre-registration form the details of the Producer in which they perform their services or professional functions, also providing certain personal data, such as: (i) their name and surname; (ii) their position; (iii) their e-mail address; (iv) their telephone number; and (v) their user data (User name and password). Additionally, they must indicate the CRSO to which they are linked.
Once the pre-registration form has been completed, the CRSO responsible for each Producer will validate and confirm the registration request, verifying the existing relationship between the Producer and CRSO.
On the other hand, AMBI WASTE will only validate the registration of its own Producers with whom it has a contractual relationship. Therefore, such verification will not include in any case the communication or transfer of the User’s personal data to AMBI WASTE or to other CRSOs that do not have a relationship with the Producer.
In the case of Producers linked to a CRSO, and not to AMBI WASTE, the data provided during the use and relations maintained in Circular Place will be processed by each CRSO in its capacity as data controller, with AMBI WASTE acting as data processor in its capacity as owner of Circular Place.
Thus, once AMBI WASTE or CRSO have analysed the data entered for registration as a User, and these have been verified, the Producer will receive a validation email to confirm their registration, and will be able to access all the services and functionalities of Circular Place.
In addition, the Producer also has the possibility to send invitations to register as Users to other persons who also perform professional services or functions for the Producer (i.e. other employees of the organisation). To do so, the registered User must provide the email address of the invited User, who must then fill in the other personal information on the registration form. In these cases, the registered User of the Producer will be solely responsible for ensuring that the invited User has been previously informed. In this sense, AMBI WASTE is exempt from liability in relation to the incorporation of third party data of the Producer.
Producer User accounts may be cancelled and deactivated at any time by each CRSO responsible for them. In these cases, the Producer will be informed of the deactivation of their account, and may contact CRSO directly, as the data controller, or AMBI WASTE, if applicable, for any complaint, query or incident to this effect.
- Beneficiary Registration
On the other hand, any non-profit organisation or educational centre that carries out energy poverty projects, electrical rehabilitation projects for social purposes or educational projects that involve some electrical or lighting installation, can also register in Circular Place as a Beneficiary, with the aim of finding and accessing certain free products available thanks to the donations made by the Producers.
In order to participate in Circular Place, the Beneficiaries must meet certain minimum requirements, as well as make a pre-registration request. In the pre-registration application, Users must provide certain personal data, such as: (i) their name and surname; (ii) their position; (iii) their e-mail address; (iv) their telephone number; and (v) their User data (User name and password). In addition, they must provide other information relating to the organisation, such as company name, address or area of activity.
Pre-registration requests will be validated by AMBI WASTE, which may require additional information to verify the Beneficiary’s status. If the pre-registration request is accepted, the Beneficiary will receive an email informing him/her how to proceed to complete and formalise the registration process. Once the registration process has been confirmed and the User has been registered, he/she will be able to enjoy all the services and functionalities of Circular Place.
AMBI WASTE will retain the User account data for as long as you actively use it. After a period of five (5) years of inactivity, AMBI WASTE will proceed to block or delete your account, as well as all data associated with it, in accordance with its legal obligations.
B. Transaction management through Circular Place
Registered Users may carry out transactions and enter into relationships with each other through Circular Place, and AMBI WASTE and/or each CRSO may therefore access the information of its own Producers relating to the operations and transactions carried out through Circular Place. However, the accessible information shall not include personal data of third parties not involved in the transaction.
Transactions shall be carried out by Users in accordance with the provisions of the Terms and Conditions of Circular Place, expressly accepted in advance by Users.
In order to enable the correct relationship and contact between the Users involved in the transaction, the Platform may process their contact details in order to send them communications by e-mail and keep them informed about the status of the transaction and/or possible incidents related to the same.
Furthermore, Users are informed that the Platform may include contact details of the other Users involved in the transaction in such communications in order to provide the parties with the necessary information to formalise the transaction. Users’ data will be processed for the correct execution of the transaction requested, as well as to guarantee the operation of the service and use of Circular Place.
Under no circumstances shall the Platform be liable or assume any responsibility whatsoever for the processing that Users may carry out on the personal contact data provided, and the Beneficiary and Producer shall be solely responsible for compliance with the legal obligations that may correspond to them in accordance with current data protection regulations. Thus, the Beneficiary and the Producer undertake to adopt such technical and organisational measures as may be appropriate in each case to guarantee the protection of the personal data provided, exempting the Platform from any damage, claim or harm arising from the mere breach of their obligations.
The foregoing is without prejudice to the provisions of the Circular Place Terms and Conditions in relation to the development and final execution of the transaction outside the Platform environment, without AMBI WASTE or other CRSOs being a party to the contractual relationship or assuming any liability for the obligations arising therefrom.
C. User communications and helpdesk
This category includes any personal data provided by users in the course of their communications with AMBI WASTE, for the purpose of making or resolving any contact, incident or complaint. In this sense, if Users have made any request, query or suggestion through the contact forms, AMBI WASTE will process their personal data in order to respond to it.
The legal basis for the processing of this personal data is the consent of the Users when they provide their data through the contact forms.
D. Sending communications related to Circular Place to Users
AMBI WASTE may use the contact details provided by users to send communications of any kind, specifically of an informative nature. In these cases, AMBI WASTE will ensure that it has a valid legal basis for sending such communications which, in most cases, will be the legitimate interest of AMBI WASTE. When necessary, the consent of the Users will be required.
In particular, if Users have subscribed to any functionality, or requested information about any product, AMBI WASTE will have the possibility to communicate with Users to inform them about other similar products.
When Users do not wish to receive further emails, they can unsubscribe at any time by using the unsubscribe function enabled in each email, or they can contact AMBI WASTE at email@example.com.
E. Information on access and use of Circular Place
AMBI WASTE may collect certain information from Users automatically obtained from the use of Circular Place relating to Users’ equipment or devices, usage and browsing habits.
AMBI WASTE processes this personal data on the basis of its legitimate interest in order to improve its products and services. Personal data will be kept for the period of time indicated in each case in the Cookies Policy, counting from the last access to Circular Place.
AMBI WASTE may enrich Users’ personal data with non-identifying information obtained by Users through Circular Place, as described above. In these cases, the combined information will be treated as personal data.
F. Maintenance and optimisation of Circular Place
Users’ personal data will also be used for the maintenance and analysis of Circular Place, to resolve performance issues, improve availability and protect Circular Place against fraud (i.e. in case of repeated login attempts) or non-compliance with the terms and conditions (i.e. use of Circular Place by persons under 18 years of age). The analysis also makes it possible to check whether the different online services and processes offered on Circular Place are working effectively in order to improve the functionalities and services included, whenever possible.
The use of Users’ personal data for these purposes is done on the basis of the legitimate interest of AMBI WASTE and will be kept for a maximum period of six (6) months.
G. Carrying out statistical studies, quality surveys or satisfaction surveys.
AMBI WASTE may also process personal data for statistical analysis and studies, as well as to carry out quality or satisfaction surveys, in order to analyse the services offered and to be able to improve them.
The legal basis that legitimises this processing is the legitimate interest of AMBI WASTE in analysing the level of quality of its services, the degree of satisfaction of the Users, and to be able to improve its services.
The personal data resulting from this processing will be kept for the time necessary for these purposes and, when they are no longer necessary, they will be deleted or anonymised.
H. Compliance with legal obligations
Users’ personal data may be disclosed to the competent administrative authorities or courts in compliance with AMBI WASTE’s legal obligations, or to protect the rights and safety of AMBI WASTE, its customers, Circular Place Users and employees.
3. Obligations of CRSOs as responsible for treatment
In this regard, each corresponding CRSO has signed with AMBI WASTE before registering on the Platform and through the acceptance of the corresponding checkbox, a data processor contract that includes the obligations established in article 28 of the GDPR, for the provision of technological intermediation services through Circular Place with Beneficiaries for the management of the Transactions. Within the framework of this contract, AMBI WASTE will assume the role of data processor.
Finally, AMBI WASTE has subcontracted the hosting and information storage services to a third party service provider of Circular Place who will assume the role of sub-processor. This third party will access the information stored on the Platform and will provide the necessary maintenance services to ensure the proper functioning of the Platform.
4. How your personal data is shared
Sometimes it is necessary to share Users’ personal data with third parties to ensure the correct provision of a service requested by the User, or to ensure the proper functioning of Circular Place. All third parties with whom AMBI WASTE may share your information are service providers who will act in any case as AMBI WASTE’s data processors.
These entities may be located in Spain, in other countries of the European Economic Area (EEA), or anywhere else in the world. Where AMBI WASTE stores personal data outside the EEA, it ensures an adequate level of protection for the data transferred. To this end, service providers are required to take appropriate measures to protect the confidentiality and security of personal data. For example, Standard Contractual Clauses approved by the European Commission are used for services provided by service providers outside the EEA.
AMBI WASTE may also need to provide personal data to the authorities in order to comply with any legal obligation or court order. All data communications will always be carried out in compliance with the provisions of current data protection regulations and, in particular, the GDPR.
5. Security of personal data
AMBI WASTE is concerned to ensure the security and confidentiality of Users’ personal data. To this end, appropriate technical, physical and organisational measures have been implemented to protect the personal data collected through Circular Place from misuse, destruction, loss, alteration, disclosure, acquisition or accidental, illegal or unauthorised access, as required in accordance with the provisions of the GDPR and current data protection regulations.
However, no Internet-based site can be completely secure, therefore, AMBI WASTE is not responsible for unauthorised or unintended access beyond its control. It is the responsibility of Users to monitor the security of their information. In this regard, AMBI WASTE urges and encourages all Users to exercise caution when sharing information. AMBI WASTE does not control the content and information that Users choose to share with other Users and therefore is not responsible for the consequences of their actions.
AMBI WASTE undertakes (i) to act promptly and responsibly in the event that the security of Users’ personal data is compromised and (ii) to report this, where appropriate, with the utmost diligence.
In the event of a personal data breach, AMBI WASTE undertakes to notify the Spanish Data Protection Agency or the relevant data protection authority without undue delay after becoming aware of the breach. Likewise, when the personal data breach is likely to produce a high risk to the rights and freedoms of Users, AMBI WASTE will notify Users of the personal data breach and the measures taken to mitigate the risks and effects that may occur.
7. Users’ data protection rights
At any time, Users may exercise before AMBI WASTE their rights of access, rectification, deletion, opposition, limitation of processing and portability, under the terms provided in the current legislation. This means that Users may request to know which of their data is processed by AMBI WASTE, or update it, as well as request that AMBI WASTE stop using the data for a specific purpose, or simply request that AMBI WASTE delete all or some of their personal data from its files and databases.
In the event that Users object to the processing of their data, AMBI WASTE will cease to process the data, except for legitimate reasons provided for in current legislation or for the defence of possible claims.
After the exercise by the Users of any of these rights, and during the time of verification by AMBI WASTE, the data will remain blocked while certain circumstances of the same are verified, and AMBI WASTE will not be able to delete or process such data.
In order to exercise any of the rights described above, Users should contact AMBI WASTE via the following email address firstname.lastname@example.org , including as the subject of the email “EXERCISE OF RIGHTS”, duly proving their identity and indicating in the content of the email the specific right they wish to exercise.
Likewise, Users may also file a complaint with the Spanish Data Protection Agency (www.aepd.es), or the corresponding data protection authority, if they consider that AMBI WASTE has not processed their personal data in accordance with the regulations.
Last updated: 30 January 2023
What this policy covers
The following explains our policy regarding the personal information we collect about you whilst:
- in contract with Recolight for WEEE compliance services,
- in contract with Recolight for recycling services,
- providing services to Recolight,
- visiting this website.
It explains how we use the information we collect
- to provide you with the information you require,
- and improve the service we can offer you.
Recolight is committed to protecting and respecting any personal data shared with us.
Information we collect
- In accordance with the Legitimate Interests basis for processing as defined in the GDPR, we collect your contact name, address, telephone numbers, inbound voice calls and email addresses
Why we collect this information
- To provide the WEEE compliance, collection and/or recycling services you have requested and that we deliver.
- To provide you with information in relation to those services.
- To comply with our legal obligations under WEEE and other waste legislation.
Who we might share this information with
- If you are a Member, we share this information with the Environment Agency.
- If you are a Collection Point, we share this information with our logistics suppliers to collect your waste.
- If you are a Supplier, we share this information with our Collection Points and with the Environment Agency.
- Our legal advisors where this may be required.
Recolight will not sell or rent your personally identifiable information to anyone.
What we do with your information
We store it securely in our web-based systems:
- Customer Relationship Management.
- RecoWeb – online booking for collections.
- BlackBox – reporting tool for Producer participants.
- On our office server.
- In our Email system.
How long we keep your information for
- Producer Members – we hold your information for the period of your membership.
- Collection Points – we hold your information for the period of your relationship with Recolight.
- Suppliers – we hold your information for the period of your contract.
- We also keep the information for the current Environment Agency Reporting year, and for a period of 6 Years thereafter for clarification of any potential dispute and compliance with applicable legislation.
On the “Contact Us ” page of the Recolight website we collect personal information from you when you complete the form. By opting in to receive more information on offers and promotions, you will be added to our active customer list. By being on the active customer list you may be contacted occasionally via the website or email for direct marketing purposes. The provision of personal information is entirely voluntary.
Whilst you are browsing this website, a cookie is stored on your computer in order that we can identify your session for measuring visitors to the website. Your web browser destroys this cookie after 20 minutes of inactivity, or when you close the web browser application. At no stage is any personal information stored in a cookie, or any information that would allow us to identify you as an individual.
This website may provide links to a number of external websites. Recolight is not responsible for the privacy practices or content of such websites.
Events and webinars
Where processing of your personal data is based on consent, you can withdraw that consent at any time.
We collect personal data, or personal information, which means any information about an individual from which that person can be identified.
This is information about you that you give us by filling in forms on our site or at our events or by corresponding with us by phone, email or otherwise. The information you give us may include your name, job title/function, organisation, email address and phone number.
We process your personal information to invite you to our events and update you on products and services.
With your request, at sign up for an event, we will share information with exhibitors, speakers and event sponsors in our and their legitimate interests of improving our businesses for the purposes set out above.
How you can access the information we hold
By submitting a Subject Access Request letter to the Data Protection Officer at Recolight. This must be submitted in writing to Recolight, Airport House, Purley Way, Croydon, CR0 0XZ or by email to email@example.com
OUR WEBSITE TERMS AND CONDITIONS
1. Use of Website Informacion
You may download, view, copy and print documents and graphics incorporated in these documents (the “Documents”) from the Site subject to the following: (a) the Documents may be used solely for personal, informational, non-commercial purposes; and (b) the Documents may not be modified or altered in any way. Except where your use constitutes “fair use” under copyright law, you may not otherwise use, download, upload, copy, print, display, perform, re-produce, publish, license, post, transmit or distribute any information from this Site in whole or in part without the express authorisation of Recolight.
2. Use of Forums and Public Communication
“Forum” means a discussion group, chat area, bulletin board, news group, letter to Recolight, its webmaster or employees, or e-mail function offered as part of the Site. You agree not to upload, email, post, publish or otherwise transmit through a Forum any content that: (a) is false or misleading; (b) is defamatory; (c) is harassing or invades another’s privacy, or promotes bigotry, racism, hatred or harm against any group or individual; (d) is obscene; (e) infringes another’s rights, including but not limited to intellectual property rights; (f) constitutes unsolicited bulk e-mail, “junk mail,” “spam” or chain letters; or (g) violates any applicable laws or regulations.
Forums shall be used in a non-commercial manner only. You shall not distribute or otherwise publish any content containing a solicitation of funds, promotion, advertising, solicitation for goods or services, or other commercial matter. You agree not to solicit other users of the Site to use or join or become members of any commercial online or offline service to other organisation. Except where expressly authorised by Recolight, you agree not to collect or store personal data about other users.
By uploading, emailing, posting, publishing or otherwise transmitting content to any Forum or submitting any content to Recolight, you automatically grant (or warrant that the owner of such rights has expressly granted) Recolight a perpetual, royalty-free, irrevocable, nonexclusive right and license to use, reproduce, modify, adapt, publish, transmit and distribute such content on in any form, medium, or technology now known or later developed. In addition, you warrant that all so-called moral rights in the content have been waived.
3. Passwords and Security
You are responsible for maintaining the confidentiality of any password(s) you are given to access the Site, and are fully responsible for all activities that occur under your password(s). You agree to notify Recolight immediately of any unauthorised use of your password(s).
Recolight is concerned about the security of personal information we have collected from you and has taken reasonable steps to prevent unauthorised access to that information.
4. Termination of Use
You agree that Recolight may, in its sole discretion, at any time terminate your access to the Site and any account(s) you may have in connection with the Site. Access to the Site may be monitored by Recolight.
5. Third Party Web Sites, Content, Products, and Service
The site may provide links to Web sites and access to content, products and services from third parties, including users, advertisers, affiliates and sponsors of the Site. You agree that Recolight is not responsible for the availability of, and content provided on, third party Web sites. You should refer to the policies posted on other Web sites regarding privacy and other topics before you use them. You agree that Recolight is not responsible for third party content accessible through the Site, including opinions, advice, statements and advertisements, and understand that you bear all risks associated with the use of such content. If you choose to purchase any products or services from a third party, your relationship is directly with the third party. You agree that Recolight is not responsible for: (a) the quality of third party products or services; and (b) fulfilling any of the terms of your agreement with the seller, including delivery of products or services and warranty obligations related to purchased products and services. You agree that Recolight is not responsible for any loss or damage of any sort you may incur from dealing with any third party.
Except where expressly provided otherwise, the site, and all content, materials, information, software, products and services provided on the site, are provided on an “as is” and “as available” basis. Recolight expressly disclaims all warranties of any kind, whether express or implied, including, but not limited to the implied warranties of merchantability, fitness for a particular purpose and non-infringement. Recolight makes no warranty that: (a) the site will meet your requirements; (b) the site will be available on an uninterrupted, timely, secure, or error-free basis; (c) the results that may be obtained from the use of the site or any services offered through the site will be accurate or reliable; or (d) the quality of any products, services, information, or other material purchased or obtained by you through the site will meet your expectations.
Any content, materials or information downloaded or otherwise obtained through the use of the site is done at your own discretion and risk. Recolight shall have no responsibility for any damage to your computer system or loss of data that results from the download of any content, materials, information.
Recolight reserve the right to make changes or updates to the site at any time without notice.
7. Limitation of Liability
In no event shall Recolight be liable for direct, indirect, incidental, special or consequential damages, or damages for loss of profits, revenue, data or use, incurred by you or any third party, whether in an action in contract or tort, arising from your access to, or use of, the site.
You agree to defend, indemnify and hold harmless Recolight, its officers, directors, employees and agents from and against any and all claims, liabilities, damages, losses or expenses, including reasonable attorneys’ fees and costs, arising out of or in any way connected with your access to or use of the Site.
Recolight is concerned about your privacy and has developed a policy to address privacy concerns.
10. Law and Jurisdiction
By use of this website you agree to the application of the laws of England and to the exclusive jurisdiction of the English courts.
All material on this website is the copyright of Recolight, save from where permission has been sought by us from others. All rights are reserved and owned by Recolight or the material is included with the permission of the owner of the rights. Reproduction of this website in whole or in part, in any form or medium, without the express written permission of Recolight is prohibited. Use of this website is subject to our legal terms and conditions shown below. Should you believe there has been a breach of these terms and conditions, please contact us.
We always aim to ensure that the information on this site is accurate and complete. However, we do not accept any liability arising from any inaccuracy or omission in the information provided and we advise you to verify the accuracy of any information and take appropriate professional advice before relying on it. If you believe any of the information to be inaccurate please contact us at firstname.lastname@example.org or in urgent situation call 020
You can alter the size at which text is displayed in this site by adjusting your browser’s settings, usually via the View menu. Alternatively, if you have a mouse with a wheel-button you can usually hold down Ctrl and rotate the wheel to adjust text size.
Web and Accessibility Standards
This site complies with the majority of checkpoints contained in the W3C’s Web Content Accessibility Guidelines 1.0.
It also follows recommendations for XHTML 1.0 Transitional and CSS 2.0.
Help with pdf files
You need Adobe Acrobat Reader installed on your computer to open pdf files and this can be freely downloaded from Adobe’s website.
Adobe’s website at www.adobe.com
If you need information on making pdf files accessible, Adobe have a website aimed at improving access to electronic information for people with disabilities, featuring an online tool to convert pdfs to text.
Adobe’s Access website
Adobe’s online pdf conversion tool
If you have any problem accessing information on the pages, please email email@example.com