Privacy Notice For Clients

Updated January 2024

We at Sustainability Core Advisors and our affiliated companies (“Sustainability Core Advisors”) are a professional consulting/advisory firm focused on delivering consulting services for our clients. We respect you and are committed to honoring and protecting your privacy and the reason we collect your personal data is to improve our services to you. This Client’s Privacy Notice describes our approach to privacy and our practices regarding why we collect your personal data, what data we are collecting, how we process it, and how you can manage and delete your personal data. If you have any questions or concerns about this privacy notice or your personal data, please contact us at: info@sustainabilitycoreadvisors.com

Where we determine the purpose and means of processing personal data, Sustainability Core Advisors will be a controller. Where we act as a processor in our capacity of providing services to a client, we will only process personal data in accordance with the instructions of the client. The client will be the data controller of that personal data and will be responsible to data subjects for the way in which their personal data is processed. Where applicable, in accordance with data protection laws we shall assist the data controller in effecting data subject rights.

What personal data we collect and how we collect it

Sustainability Core Advisors, may at times collect your personal data in one of the following ways:

By entering information such as your name, and email address, country of residence, company you represent, industry and details of an inquiry on the page titled Connect With Us, you enable us to respond to a general/ business inquiry made by you or on behalf of the company that you represent. If you wish to be contacted by telephone, we may also collect your work phone number.

Sustainability Core Advisors use cookies and web beacons to collect data on how you use our websites. This may include for example information with respect to what Sustainability Core Advisors websites you have visited, how long you stayed on them, which items you clicked on and your IP-address. To know more about our use of cookies, please visit https://sustainability Core Advisors.com/privacy/cookie-policy to see our Cookies Policy.

You may provide Sustainability Core Advisors with information when subscribing and using the Sustainability Core Advisors Subscription Center. This data may include for example your name, email address and the company you represent. The subscription center also keeps track of your communication preferences (over email or phone) and areas of interest (such as receiving newsletters, thought leadership content and/or marketing collateral) that you may have either opted into or opted out of. You can change your preferences or opt-out at any time by visiting our Preference Center.

E-mail Communications: If you are a recipient of our marketing communications, we will track whenever you receive, open, click a link, or share an e-mail you receive from Sustainability Core Advisors. To unsubscribe from Sustainability Core Advisors marketing communications, please visit our unsubscribe webpage at https://sustainabilitycoreadvisors.com/unsubscribe/form.

Information from Other Sources: Sustainability Core Advisors might receive information about you from other sources, such as public sources, social media, directories, registries to ensure the accuracy and completeness of your personal data.

Call recordings: Sustainability Core Advisors may record the conversations between you and Sustainability Core Advisors’ global voice solutions team when you contact our helpline phone number. Also, Sustainability Core Advisors tele nurture representatives may contact you to address any inquiries made by you or to further communicate with you about Sustainability Core Advisors service offerings. All such conversations will also be recorded for quality and training purposes and to facilitate resolution of any queries or complaints.

Information when you access Sustainability Core Advisors content on our Third-Party Partner Website(s): From time to time, Sustainability Core Advisors publishes thought leadership, marketing collateral and webinars on third-party website platforms. By accessing Sustainability Core Advisors content, Sustainability Core Advisors may collect your name, email address, contact number, designation/job role, company you represent, and any other Sustainability Core Advisors content/ links accessed.

Corporate Marketing and Thought Leadership Events: From time to time, Sustainability Core Advisors may host various sales, marketing and thought leadership events, either in person or virtual. Sustainability Core Advisors may collect your name, email address, contact number, designation/job role and the company you represent from such events. Additionally, Sustainability Core Advisors sales executives and business leaders may visit similar events conducted by other companies or forums. As part of these events, Sustainability Core Advisors sales executive and business leaders may receive business cards from you in order to establish a working relationship with you on behalf of the client you represent.

Information obtained from Third-Party Business Contact Directory and Services: Sustainability Core Advisors has carefully selected and contracted with third-party agencies providing business contact directory services to obtain the name, title, company you represent, work phone number, work email address and work address of potential business contacts.

Information obtained from our Business Leaders: Sustainability Core Advisors may receive information related to your name, company you represent, designation/job role and email address from Sustainability Core Advisors business leaders who have established professional/ personal connections with you.

Information obtained from public sources and professional networking platforms: Sustainability Core Advisors may also collect information related to your name, company you represent, designation/job role, and email address from public sources (where available) or professional network platforms such as LinkedIn.

Information received prior to/during fulfilment of contractual services: This may include for example your name, designation/job role, company you represent, telephone number and email address that you provide Sustainability Core Advisors with during the Request for Proposal stage, proposal discussions, contract negotiations and/or the duration of time for which Sustainability Core Advisors provides the client with services.

Information to facilitate visits, travel and lodging: From time to time, Sustainability Core Advisors also provides assistance to our clients’ representatives visiting our premises by facilitating travel and accommodation. In such cases, Sustainability Core Advisors would collect your name, date of birth, contact number, company you represent, email address, travel and accommodation preferences, passport and visa details. Sustainability Core Advisors may engage carefully selected third-party vendors or applications to collect and process these details, as permitted under applicable laws. Where third party applications are engaged, if you choose to sign up,

Sustainability Core Advisors may additionally have access to your login details such as username and social media account (if you choose to link them). Sustainability Core Advisors will inform you about this at the time of collection. These details will not be used for any other purpose other than to facilitate usage of the application, facilitate your visit and enhance your experience. Information processed by the third parties such as the application provider and social media services will continue to be processed as per their policies and privacy notices which will be communicated to you.

Purpose and Lawful Basis for processing personal data With your consent. Where we require your consent, you will find opt-in mechanisms and you have the ability to withdraw consent at all times. Where we need to perform the contract we are about to enter into or have entered into with you. For example, when we perform our services to you.

Where we need to comply with a legal or regulatory obligation. This will include maintaining records, compliance checks or screening and recording (e.g. anti-money laundering, financial and credit checks, fraud and crime prevention and detection, trade sanctions and embargo laws). This may include automated checks of personal data you provide about your identity against relevant databases and contacting you to confirm your identity or making records of our communications with you for compliance purposes.

Where it is necessary for our legitimate interests or those of a third-party and your interests and fundamental rights do not override those interests. Our legitimate interest will include for example, market research purposes, marketing purposes and appropriate controls to ensure our website, processes and procedures are running effectively for the prevention and detention of against fraud and for IT security purposes. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

To contact you in order to inform you of new products, services or promotions Sustainability Core Advisors may offer including to keep you appraised of Sustainability Core Advisors thought leadership and marketing collateral and to better assist your needs, in pursuit of Sustainability Core Advisors legitimate business interests and on occasion with your consent. If you are a prospective client, we will seek your consent before we contact you with such information.

To invite you to Sustainability Core Advisors hosted or sponsored events that may be of interest to you based on your role within the company and/or industry, in pursuit of our legitimate business interests. If you are a prospective client, we will seek your consent before sending such invite to you.

To conduct market research and to carry out marketing campaigns, in pursuit of Sustainability Core Advisors legitimate business interests. If you are a prospective client, we will seek your consent before conducting such market researches and carrying out such marketing campaigns.

To carry out the services for which Sustainability Core Advisors has been contracted by the client you represent to deliver, and to contact you for client care related purposes including regular communication regarding project status, notifying issues/concerns, sharing project deliverables and carrying out day-to-day project activities, in order to comply with Sustainability Core Advisors contractual obligations towards the client you represent.

As part of our email campaigns, Sustainability Core Advisors will track whenever you receive, open, click a link, or share an e-mail you receive from Sustainability Core Advisors. Sustainability Core Advisors will carry out automated profiling of such information to evaluate your interest towards Sustainability Core Advisors service offerings or promotions. This processing will enable Sustainability Core Advisors to identify and target potential clients or business partners, tailor Sustainability Core Advisors marketing and provide you with relevant and timely content based on your interests, in pursuit of Sustainability Core Advisors legitimate business interests.

Sustainability Core Advisors records all conversations/interactions between you and Sustainability Core Advisors global voice solution teams and/or tele nurture representatives for quality and training purposes, and in pursuit of Sustainability Core Advisors legitimate business interests. Also, Sustainability Core Advisors ensures you are notified about call recording, prior to the initiating any such conversations/interactions.

In certain cases, Sustainability Core Advisors may record the conversations/ interactions with you and Sustainability Core Advisors representatives during Request for Proposal/ Proposal discussions, trainings, transition workshops or project discussions that may be carried out over Voice over IP (VoIP) sessions for future reference and training. Sustainability Core Advisors will always inform you and obtain your verbal consent prior to recording any such sessions.

As part of Sustainability Core Advisors’ tele nurture program, Sustainability Core Advisors tele nurture representatives may call you to inform you about Sustainability Core Advisors’s service offerings or promotions and may record their feedback and observations of such conversations to help Sustainability Core Advisors identify and target potential clients and business partners in pursuit of Sustainability Core Advisors legitimate business interests. If you are a prospective client, we will seek your consent before we contact you.

Sustainability Core Advisors engages carefully selected third-party vendors to conduct surveys to receive feedback from you on the services currently provided by Sustainability Core Advisors to the company you represent. We may also share your information with such third-party vendors to conduct anonymous survey to understand your perception about our brand. Sustainability Core Advisors uses your responses to better understand our strengths and identify improvement areas. This will help Sustainability Core Advisors serve the company you represent better and improve our overall service offerings and business strategies, in pursuit of Sustainability Core Advisors legitimate business interests.

To develop new and improved products and services to help Sustainability Core Advisors serve the company you represent better and to improve Sustainability Core Advisors overall service offerings in pursuit of Sustainability Core Advisors legitimate business interests.

If processing of personal data is subject to any other laws, then the lawful basis of processing personal data may be different to that set out above and in those circumstances will be based on national laws.

Sustainability Core Advisors shall only process the received information pursuant to pursue our legitimate business interests, for example, inform you about new products and services, obtain feedback on the services we provide. We will seek prior consent, for example, to establish communication with prospective clients and personnel with general/ business inquiries..

You also have the option to subscribe/opt-in to receive newsletters, thought leadership content and/or marketing materials. You can always opt out by using our Preference Center or click here. Sustainability Core Advisors shall adhere to your preferences.

Security

Sustainability Core Advisors implements industry standard security measures to keep your personal data secure and confidential, including but not limited to:

Restriction of access to your personal data to Sustainability Core Advisors employees strictly on a need-to-know basis, such as responding to an inquiry or request.

Implementation of physical, electronic, administrative, technical and procedural safeguards that comply with all applicable rules, laws, legislation and regulations to protect your personal data from unauthorized or inappropriate access, alteration, disclosure and/or destruction. It is important for you to protect against unauthorized access to your password and to your computer. Be sure to sign off when you are done using a shared computer.

Sustainability Core Advisors employees who misuse personal data are subject to strict disciplinary action, as it is a violation of the Integrity Policy of Sustainability Core Advisors.

Who we may share your personal data with

The personal data Sustainability Core Advisors collects from you is stored in one or more databases hosted by third parties. These third parties do not use or have access to your personal data for any purpose other than cloud storage and retrieval. On occasion, Sustainability Core Advisors engages third-parties (Tele-nurture vendors) to respond to any queries raised by you or to establish business communications including marketing communication to prospective clients, hosting of virtual events (third-party virtual events or webinar organizers) or to carry out surveys (third-party survey vendors), or to facilitate your travel and accommodation (travel, lodging and immigration vendors) For information on the third-party vendors partnered with Sustainability Core Advisors, please visit https://website-files.Sustainability Core Advisors.com/downloadable-content/Sustainability Core Advisors-list-of-associated-partners-and-suppliers.pdf

Sustainability Core Advisors has offices and operations in several domestic locations (Headquarters in Denver, Colorado and a Midwest office in Chicago Illinois) and we share information between our group companies for business and administrative purposes. Please visit https://www.Sustainability Core Advisors.com/locations to see a list of the locations within our company.

Where required or permitted by law, information may be provided to others, such as but not limited to regulators, under legal process, enforceable government directives.

From time to time, Sustainability Core Advisors may consider corporate transactions such as a merger, acquisition, reorganization, asset sale, or similar. In these instances, we may transfer or allow access to information to enable the assessment and undertaking of that transaction. If we buy or sell any business or assets, personal data may be transferred to third parties involved in the transaction. In these instances Sustainability Core Advisors will continue to ensure your personal data is protected and private, and Sustainability Core Advisors will give any impacted data subjects notice before any personal data is transferred or subject to a different privacy policy.

Data Storage and Retention

Sustainability Core Advisors shall retain your personal data pursuant to business purposes and in line with our retention policies. We will only keep your personal data for as long as is reasonably necessary taking into consideration our purposes outlined above or complying with legal, accounting or reporting requirements under applicable law(s).

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of personal data, the purposes for which we process the personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

For more information on where and how long your personal data is stored, and for more information on your rights of erasure and portability, please contact our Data Protection Officer, details available in the contact section below.

Existence of Automated Profiling

Sustainability Core Advisors uses automated profiling in limited circumstances relating to email campaigns. As part of our email campaigns, we track when you receive, open, click a link, or share an e-mail you receive from Sustainability Core Advisors using a Sustainability Core Advisors managed automated solution. The automated solution profiles the information tracked to evaluate your interest in Sustainability Core Advisors’ service offerings and/or promotions. This enables us to identify and target potential clients and/or business partners and aims to provide you with relevant and timely content based on your indicated interests.

Data Subject rights

You may have certain rights in relation to your personal data pursuant to data protection laws in your jurisdiction. To exercise such rights, please contact: info@sustainabilitycoreadvisors.com

The rights for certain jurisdictions are explained in further detail below.

Residents of California and Virginia:

Please note that Sustainability Core Advisors does not sell or share personal information as defined in sections 1798.140(t) and 1798.140(ah)(1) of the California Client Privacy Act of 2018, as amended by the California Privacy Rights Act. Sustainability Core Advisors also does not sell personal information of children under age 16.

Depending on your state of residency, you may have the ability to exercise all or some of the following rights, subject to any exemptions or exceptions in applicable law:

The right to access what personal information has been collected about you by making a proper Verifiable Client Request (VCR). Through a VCR, you may request:

1. The categories of personal information collected about you in the preceding 12 months;
2. The categories of sources from which personal information is collected;
3. The business or commercial purpose for collecting personal information;
4. The categories of third parties with whom Sustainability Core Advisors shares personal information; and
5. Specific pieces of personal information collected about you.

The right to request deletion of personal information that has been collected about you, subject to certain exceptions.

The right to request that your personal information be transferred to a third party.

The right to correct inaccurate personal information, taking into account the nature of the personal data and the purposes of the processing of the personal data.

The right, if applicable, to restrict sensitive personal information processing.

The right to non-discrimination against you for exercising any of the rights listed above.

You may exercise your rights with respect to your personal information by submitting a VCR on Sustainability Core Advisors’ request portal here. You may also submit a request by calling 1(888) 914-9661 and entering in the following ID: 112797. You may designate an authorized agent to make a request on your behalf if necessary. We will use reasonable methods to verify your identity when receiving a request. If collecting new information is necessary to verify your identity, it will only be used for identity purposes; and will be deleted as soon as practical after processing the request and to comply with recordkeeping obligations. To the extent possible, we will provide you with your personal information in a format that you can share with other businesses.

For issues accessing Sustainability Core Advisors’ portal, please contact: info@sustainabilitycoreadvisors.com

Sustainability Core Advisors will respond to a VCR within 45 days. Should we require more time, Sustainability Core Advisors will notify you of the extension period and the reason for the extension in writing. In some situations and subject to certain exemptions, we may decline a request to exercise the rights above, particularly if we are unable to validate your identity. Depending on your state of residency, you may have the ability to appeal a decision we have made in connection with your VCR.

Contact us

If you have any questions or concerns as to how your data is being processed, you can contact our Data Protection Officer by writing via email to: info@sustainabilitycoreadvisors.com

Complaints

In the first instance, please contact us with concerns you may have. Data protection laws give you the right to lodge a complaint with a supervisory authority, in particular in the state where you work, normally live or where any alleged infringement of data protection laws has occurred.

Changes to our client’s privacy notice

This Client’s Privacy Notice was last updated in January 2024 and Sustainability Core Advisors will notify you of changes we may make to this privacy notice where required, however we would recommend that you look back at this notice from time to time to check for any updates.