Better Cotton’s Data Privacy Policy

Depending on how you choose to interact with Better Cotton, we may collect personal information from you, for example your name, e-mail address, address, phone number, date of birth, gender, age and other persistent identifiers that can be used to personally identify you. We may also collect other personal information regarding your interaction with Better Cotton Websites, myBetterCotton, LMS  and Better Cotton Platform, including usage information, the items that you browse, download, read, watch and otherwise access, and your geographic location. 

We collect your personal information to provide you with a superior service and, as necessary, to administer our business. It allows us to provide you with easy access to our services, with a particular focus on the information that may be of most interest to you. For more information as to why we collect personal information, please see the section below entitled: “How do we use your personal information?” 

 Your personal information also allows us to communicate with you about newer initiatives, research programs and news that may be of interest to you. You always can unsubscribe from emails/newsletters by following the instructions Better Cotton includes in each communications email. 

(a) Information that you provide to us 

As a general matter, you can browse on the Better Cotton Websites without submitting your personal information to us. We do see information your Internet browser automatically sends when you visit our websites, and some information is collected by essential cookies such as remembering your cookie preferences. 

We may ask to receive and collect other personal information, as outlined in Section 3(b) of this Privacy Policy, including site analytics regarding our websites through our cookie banner on your visit.   

However, there are a number of circumstances in which you may need to provide us with your personal information. The most common of these circumstances include: 

• When you apply for Better Cotton membership 
• Using Better Cotton Websites, myBetterCotton, LMS and Better Cotton Platform 
• As part of implementing your activities in the Better Cotton programme 
• Signing up for communications/newsletter 
• Attending the Better Cotton Conference & Events (Virtual/in-person) 
• Contacting Helpdesk 

 For your convenience, we have provided a summary description of each of these circumstances below: 

When you apply for Better Cotton membership 
When you apply for Better Cotton membership, personal data (such as name, phone number, and email address) and organisation data is captured from your application form, through email conversations, as well as through any other form of communication exchange between you and Better Cotton. Reporting information is also gathered from member reports on an annual basis.  

Using Better Cotton Websites, myBetterCotton & Better Cotton Platform 
Better Cotton Websites, myBetterCotton and Better Cotton Platform may provide you with the ability to enter certain information such as your contact information you may submit to us to help us providing you with the requested services. 

 List of Better Cotton Websites: 

• Better Cotton: https://bettercotton.org/ 
• Delta Framework: https://www.deltaframework.org/ 
• Better Cotton Platform: https://cottonplatform.bettercotton.org/login/ 
• LMS: https://learn.bettercotton.org
• We also own several additional domain names: 
• bettercotton.com   
• bettercotton.co.uk 
• bettercotton.hk 
• bettercotton.ch 
• bettercotton.co.in  
• bettercotton.de  
• bettercotton.net  
• bettercotton.nl  
• bettercotton.tw  
• bettercottonfund.org  
• bettercottontracer.org
• myBetterCotton

Statistical information (such as number of users, pages most accessed and timing of access) is collected through the Better Cotton ICT platforms (incl. the website and the Better Cotton Platform) and processed into aggregated data. Individual persons or organisations are not identified in this collection. 

As part of Better Cotton Programme 
Better Cotton is a multi-stakeholder not-for-profit member association that collects data from farmers, programme partners and members. In some cases, we capture personal data such as name, gender, contact information, location data. We will store and use this information to administer the programmes and services e.g., access to use the Better Cotton Chain of Custody, in which you choose to participate, and as permitted by this Privacy Policy. 

Signing up for communications/newsletter/partnerships 
We also collect personal data if you share it with us on your own initiative, e.g., when executing an agreement, contacting us, or when registering for services such as our quarterly newsletter.  

Contacting Helpdesk 
When you contact Better Cotton Helpdesk, we may ask you to provide, or confirm, personal information so that we can better serve you. 

(b) Information automatically collected 

There are circumstances in which we receive and collect information from you depending on your cookie preferences. The most common sources of this information include: 

• Web server logs 
• Cookies 
• Pixel tags or clear GIFs 
• Third party web analytics services 
• Geolocation, including general and precise location information

For your convenience, we have provided a summary description of each of these circumstances below: 

Web server logs 
When you visit Better Cotton Websites, our web servers automatically log information that your browser sends us. For example, we may receive and collect: the name of the domain and host from which you access the Internet; the Internet Protocol (IP) address of the computer you are using; the date and time you access the Website; and the Internet address of the website from which you linked directly to the Better Cotton Websites. We may also collect information regarding search queries run on the Better Cotton Websites. We use this information to monitor the usage of the Better Cotton Websites and as necessary for our business. 

Cookies 
We use cookies to recognize you as you use or return to the Better Cotton Websites. This is done so that we can personalize and enhance your browsing and shopping experience. “Cookies” are small files that are placed in your browser to collect information about your activities on a Better Cotton Websites. Cookies help us to: (1) speed navigation, keep track of items browsed and provide you with content that is tailored to you; (2) remember information you gave us so that you do not have to re-enter it; (3) determine the effectiveness of some of our and our third party partners’ marketing efforts and communications; and (4) monitor the total number of visitors, pages viewed, and the total number of ads displayed. Browsers are typically set to create cookies automatically. You can choose to have your browser notify you when cookies are being written to your computer or accessed, or you can disable cookies entirely. To learn more about the types of cookies that we use and how to manage your cookie settings please view our Cookie Policy. 

Pixel tags or clear GIFs 
If you have accepted our suggested cookie preferences in the cookie banner we are making you aware that these use sensing technologies such as pixel tags or clear GIFs (which are also called web beacons). These technologies allow us to determine the effectiveness of our e-mail and marketing efforts. For this purpose, we tie the pixel tags and clear GIFs to personally identifiable information. We may also collect information regarding the links within such marketing materials that you click on and purchase statistics regarding items you buy following receipt of such marketing. 

Third party web analytics services 
We work with third-party service providers such as Google Analytics to help us better understand how you use the Better Cotton Websites. These third-party service providers will place cookies in your browser to collect information such as how you were referred to the Better Cotton Websites, how you navigate around the Better Cotton Websites, what you purchase and what traffic is driven by various marketing methods. This information will help us to better serve you and provide you with more personalized information. We do not allow third party service providers to collect your personal information.  

To learn more about the privacy practices of Google, you may review its privacy policy located here. To disable the Google Analytics cookie and other third-party web analytics service provider cookies, you can choose to have your browser notify you when cookies are being written to your computer or accessed, or you can disable cookies entirely. You may opt out of Google Analytics by using the following link: https://tools.google.com/dlpage/gaoptout?hl=en. 

For the LMS, Moodle Workplace has site logs where you can see activity but unless you implement third party analytics these sit within the Moodle Workplace only.

Geolocation 
In addition, to provide location-based services on Devices, Better Cotton may automatically collect real-time geographic location information or other location-based information about you and your Device only after you provide your consent to do so.  

Social Media plug-ins 
We may provide you the ability to interact with social media account such Twitter, LinkedIn and Instagram or use your social media accounts to share information directly from Better Cotton website. This enables us to improve our services and make them more interesting for you as a user. The legal basis for the use of the plug-ins is our legitimate interest. When using social plug-ins, we use the so-called double click solution: When you visit our website, the plug-ins are not fully integrated into the website. This ensures that a connection to the social network provider is established only if you click on the plug-in icon. After the connection has been established, we cannot influence the type and scope of data that are collected and processed by the provider; please refer to the data privacy notice of the relevant provider for more information in this regard. More information on the purpose and scope of the data collected and processed by the plug-in providers can be found in the providers’ data privacy notices specified below.  

In these notices, you will also find further information on your rights in this respect and the setting options to protect your privacy: Twitter, Inc., 1355 Market St, Suite 900, San Francisco, California 94103, USA; https://twitter.com/privacy. Twitter has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework 

Please see the privacy policy for the applicable social media site to learn more about how these sites share your personal information. 

Video integration 
For the integration of videos we use Vimeo, a service provided by Vimeo LLC with its headquarters at 555 West 18th Street, New York, New York 10011, USA (“Vimeo”).  

When you watch a video embedded with Vimeo, a connection is established to the Vimeo servers located in the USA. For storage in the U.S., Vimeo’s self-certification under the Privacy Shield provides an appropriate level of privacy protection. The Vimeo server receives information about which of our Internet pages you have visited. If you are logged in as a member of Vimeo, Vimeo assigns this information to your personal user account. When you click on the start button of a video, this information is also assigned to your user account. You can prevent this assignment by logging out of your Vimeo user account before using our website and deleting the corresponding cookies from Vimeo. The legal basis for this data processing derives from the legitimate interests of Better Cotton to embed videos and thus to enable an improved user experience on their website. Vimeo uses Persistent Cookies which expire between a few days and two years after the last viewing of a Vimeo video. The purpose and scope of the data collection and the further processing and use of the data by Vimeo as well as your related rights and setting options for the protection of your personal data can be found in Vimeo’s privacy policy: https://vimeo.com/privacy 

YouTube is embedded and links to video conferencing meetings are available through Moodle Workplace, our LMS, but there aren’t any other direct integrations.

Better Cotton uses your personal information across our enterprise to provide you with a superior Better Cotton services and, as necessary, to administer our business. For example, we use your personal information to: 

• Enable Better Cotton to deliver stated membership services and benefits (performance of a contract). This includes, but is not limited to, providing members with information about meetings, events, application support, member support, and access to specific account/profile information for administrative purposes.  
• Allow users of myBetterCotton to network with other members, engage in discussion forums and contact other members through direct messages;
• Administer our programmes; 
• Protect against deceptive and fraudulent activity; 
• Conduct research and perform analysis in order to measure, maintain, protect, develop and improve our programmes and services; 
• Communicate events, or new programmes that may be of interest to you; 
• Customise and enhance the Better Cotton Websites; 
• Make communications necessary to notify you regarding security, privacy, and administrative issues; 
• Manage our business; and
• Enable Better Cotton Programme Partner staff, knowledge partners and internal Better Cotton staff to learn more about the implementation of the Better Cotton Principles & Criteria via the LMS.

Protecting the privacy and security of your personal information is a priority at Better Cotton. Better Cotton shares your personal information with: 

• Name, job title & organisation data as well as any other information you choose to share as part of myBetterCotton may be shared in group communications between Better Cotton and its members (for instance, in the organisation of workshops and communications with specific Better Cotton working groups or on myBetterCotton). 
• Name, gender, email address of users, course start date, course completed date, last activity of the user, course status, course results, final score, duration, number of course attempts  as well as any other information you choose to share as part of LMS may be shared with your Programme Partner staff managers and internal Better Cotton staff members for supervision and administration management respectively.
• Programme partners, contractors, consultants, research teams who perform services on our behalf. We provide personal information to third party service providers, consultants, programme partners that work under contract on our behalf to provide certain services. These third parties do not have the right to use personal information we provide to them in any way that is not authorized by Better Cotton. They are contractually obligated to use such information only as necessary to assist us and to maintain the confidentiality and security of such information. 
• Credit card companies. Credit card transactions are handled by third party financial institutions and their vendors and contractors. Although Better Cotton’s treatment of this information is governed by this policy, the use of your information by the third-party financial institutions and their vendors and contractors will be subject to their own privacy policies. 
• Law enforcement officials and as required by law. Better Cotton may release personal information to third parties when we determine, in our judgment, and without your consent, that it is necessary to (a) comply with the law, regulation, legal process, or enforceable governmental request; (b) enforce or apply the terms of any of our policies or user agreements; (c) establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, (d) protect the rights, property or safety of Better Cotton, our employees, our members, users, or others; or (e) to comply with your request for the shipment of products to or the provision of services by a third party intermediary. 
• Your Consent. We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy.
• Retailers. Better Cotton would like to share your personal (or non-personal) information with retailers if this is required for their supply chain management and verification process in the context of the Better Cotton Initiative. In this context, please note that retailers may use such data to document their supply chain process and/or disclose your company name as product descriptions of provenience in stores or online on their website. Please note: retailers will be able to export this data from the BCP to be used in their internal systems. For such cases, and solely for physical Better Cotton products, we will only make the following information available to retailers:
  • Your company name (of the site that handled the product in question)
  • Your company type e.g. Trader
  • Your BCP number e.g. 140000-2
  • Site CoC Access e.g. Mass Balance & Physical
  • Your site full address
  • Supplier contact (name, email, phone)
  • The BCP Product ID
  • The Product Name
  • The volume of Better Cotton (for the product in question) e.g. 1,000kg
  • Transactional documentation evidencing the sale or purchase

By providing transaction documents or evidence of sale or purchase, you acknowledge and agree that Better Cotton is not responsible or liable for any potential anti-competitive behaviour, violations of competition laws, or adverse effects that may result from the sharing of such information. Better Cotton shall not be held accountable for any consequences arising from the user’s actions, including but not limited to any legal, financial, or reputational implications related to antitrust or competition laws.

Should you not wish that your personal (or non-personal) information is shared with retailers, we will respect this, but we may enable our retailers to contact you anonymously in case they have supply-chain-related questions and/or provide them with anonymized information (i.e. information that will not identify you). The following data that will always be shared as it does not require your consent:

• • Company type e.g. Trader
  • Company country e.g. India
  • Product type e.g. Yarn
  • Volume of Better Cotton e.g. 1,000kg

Please note that once you download or store such data in your own systems, you are responsible yourself for complying with all applicable provisions under Swiss or foreign applicable data privacy laws. Once such data is no longer used for mandatory purposes of documenting your supply chain or to describe your product provenience online, then such data should be deleted.

No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law. 

Better Cotton Platform 
When a Better Cotton Platform account is created, you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account as soon as possible, but at least within 2 working days. 

myBetterCotton
The communication is encrypted using standard SSL and HTTPS. Direct messages however can be read by internal users of Better Cotton such as System Administrators who have the ‘Login as Other user’ permission. When a myBetterCotton account is created, you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account as soon as possible, but at least within 2 working days.

Moodle Workplace LMS
Data is encrypted at rest and always encrypted in transit via SSL. When a LMS account is created, you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorised by you. You should notify us of any unauthorised use of your password or account as soon as possible, but at least within 2 working days.

You may choose to opt out from receiving communications from Better Cotton at any time as Better Cotton Platform account holder, as users of myBetterCotton or as Members by selecting the link at the bottom of any email communications or writing to us at [email protected] / [email protected].

As users of LMS you can write to us at [email protected].

Even if you opt-out of receiving communications, you may receive emails and notifications on Better Cotton Platform transactions.

We do not provide your name, phone number, address, email address or other personally identifiable information to third parties in exchange for money. 

If you have any questions about this Privacy Policy, please contact us at [email protected]. 

Data retention policy 
We will retain your information for as long as your account is active or as needed to provide you with services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, maintain the integrity of our chain of custody data, and enforce our agreements. 

Analytics  
You may choose to opt out of collection of automatically collected information, including cookies,  Google Analytics, and targeted advertising, by following the instructions given in Section 3(b) above, or by using the functionality in your browser to reject cookies. 

Accessing, correcting and deleting your information 
You have the right to ask us not to use your personal information for communication purposes. You also have the right to request a copy of the personal information that we hold about you and to have any inaccuracies rectified. Finally, you have the right to request that we delete your personal information. If required by law we will grant a request to delete information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, to ensure the integrity of data we hold on chain of custody  or for another one of our business purposes. 

Please address written requests and questions about your rights to [email protected]. You may submit a request for a copy of the personal information that we hold about you through our DSAR form here. 

Note that, as required by law, we will require you to prove your identity. We may conduct an identity verification by phone call or email. Depending on your request, we will ask for information such as your name, contact information. We may also ask you to provide a signed declaration confirming your identity. Following a request, we will use reasonable efforts to supply, correct or delete personal information about you in our files. 

Authorized Agent 
You may use an authorized agent to submit a request to access your information, delete your information. To designate an agent for these purposes: 

1. You must provide us with a copy of a written and signed permission given to your authorized agent; and
2. You must verify your own identity directly with us.  

Do Not Track Disclosure 
Certain web browsers may provide an option by which you may ask your browser to inform websites you visit that you do not wish your activities to be tracked by cookies or other persistent identifiers, commonly called “Do Not Track Signals”. , you may opt out of tracking activities by following the instructions in this Privacy Policy to opt out of web analytics and behavioural advertising. 

Important information about third party devices, ISPs, websites and applications
This Privacy Policy applies solely to information collected by the Better Cotton. Whenever you click on links and banners on any Better Cotton Websites that take you to a third-party website or you use, download or install third party software applications onto your Device, your use of those third-party websites and/or software will be subject to the third party’s privacy policies, not Better Cotton’s. Additionally, please note that when using Better Cotton Websites, third party mobile device manufacturers and internet service providers (ISPs) may collect personal information about you and your use of such third-party products and services will be subject to the third party’s privacy policies. 

In addition, our website includes links to other websites whose privacy practices may differ from those of Better Cotton. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit. 

Terms of Use 
Any dispute between you and us regarding the privacy of your personal information is subject to this Privacy Policy and the terms of use or terms of service applicable to our service you use, including limitation on damages and resolution of disputes. 

Contact Information
If you have questions or concerns about this Privacy Policy or our privacy practices, you may contact us by emailing at [email protected].  

Effective Date: Sept 1, 2022 
Updated on: May 24, 2023