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Privacy and cookies policy

Privacy and cookies policy

In this privacy and cookies policy (“privacy policy”), “you”, “your” and “yours” refers to you as an individual and, where applicable, to the company or legal entity on whose behalf you are viewing this privacy policy. Tungsten Network Limited shall be referred to in this policy as “Tungsten Network”, “us,” “we,” or “our.”

Tungsten Network is committed to respecting and protecting your privacy. We have structured our website so that, in general, you can visit it without identifying yourself or revealing any personal information.

Throughout Tungsten Network we will process personal information provided by you in accordance with this privacy policy and with data protection standards equivalent to the UK Data Protection Act 1998 or higher standards where required by applicable law.

Awareness: Tungsten Network provides this privacy policy to make you aware of our practices and of the choices you can make about the way your information (including your personal data) is collected and used when you access our website and/or our portal.

What we collect: On our website, you can register interest in the services we provide. The types of personal information collected at these pages are your name, organisation for whom you work, contact details and, in some instances, billing information. We may collect information about your computer, including, where available, your IP address, operating system and browser type for system information purposes and to report aggregate information for marketing purposes.

We may also obtain information to help us improve our website and to deliver a more personalised service by using cookies. 

We may receive information about you if you use any other websites that we (or members of our group, which means any of our subsidiaries, any of our holding companies, and any subsidiaries of our holdings companies, as defined in section 1159 of the UK Companies Act 2006, (“Group Companies” and each a “Group Company”)) operate or any other services or offerings that we, (or our relevant Group Company) provide, and in such case we (or our relevant Group Company) will have informed you when we collected that data that it may be shared internally and combined with data collected on this site. We are also working closely with third parties (including, for example, credit reference agencies) and may receive information about you from them.

The cookies we use are:

Country Cookie: This cookie sets the language of the screen when you visit the Tungsten Network website, prior to any login taking place. This cookie helps Tungsten Network determine the language of your browser and chooses the most appropriate language in which to display our website. This is an anonymous cookie and no personal data is stored. The website will still work with this cookie disabled; however you would need to select your preferred language every time you visit the website. This cookie persists after you leave our website.

Session ID Cookie: When you log into the portal Tungsten Network generates a session cookie so that we can control the routing of requests to the servers and to ensure a user only has a single active session. This is an anonymous cookie and no personal data is stored. The cookie is deleted after the user leaves the portal. The user cannot access the portal if this cookie is not permitted as this cookie is mandatory for use of the portal.

Portal Widget Cookie: The portal allows you to configure your home page by adding widgets and altering your location on the page. This cookie stores the widgets chosen, their location and configuration. This is an anonymous cookie and no personal data is stored. The cookie persists after you leave the portal. The user cannot access the portal if this cookie is not permitted as this cookie is mandatory for use of the portal.

Login Cookie: This cookie is a temporary cookie that is required to help us transition between the current and the new portal. We ask you to enter your email address and perform verification. This creates a cookie and stores your Tungsten Network account number on your PC. The next time you return to the Tungsten Network website we check the cookie to determine the version of the portal to which you should be routed. This is an anonymous cookie and no personal data is stored. The cookie persists after you leave the Tungsten Network website or portal. The user cannot access the portal if this cookie is not permitted as this cookie is mandatory for use of the portal.

Pardot and Marketo Cookies: These cookies collect information for marketing purposes. You may receive an email from Tungsten Network inviting you to visit our website. If you accept this invitation by clicking on the embedded link, you will be asked whether you consent to your browsing of the Tungsten Network website being tracked. You do not have to consent to this, but if you do, the Pardot and Marketo cookies will gather information for marketing purposes about the pages you visit and on any documents you download from the website. The Pardot and Marketo cookies may also use the information it gathers to contact you for marketing purposes. These cookies persists after you leave the Tungsten Network website.

The above cookies, including those which persist after you leave our website or portal, can be rejected or deleted by following the instructions for your browser. However, some of the functionality of the services on the website may be lost if you disable cookies on your browser – for example on Web Form. In addition, you will not be able to use the portal if you disable cookies on your browser.

Privacy policy does not cover third party websites Please note that this privacy policy does not apply to, and we are not responsible for, the privacy practices of third party websites which may be linked to this website.

Agreement to terms of privacy policy By using this website, the portal, any services accessible from it or the website and/or by providing your personal information to us, you consent to the collection and use of personal data by us as set out in this privacy policy.

How we use it: Tungsten Network uses your information as a source to answer any questions that you have and to better understand the people accessing our website and the organisations for which they work.

From time to time, we may also use your information to contact you for market research or to provide you with further information on the services or prospective services that we or one or more of our Group Companies may provide or other marketing information we think would be of particular interest. We may pass on your information to our Group Companies and/or to selected affiliated companies so that they may contact you with details of services and products that may be of interest to you. Where permitted by law, your use of our website and/or use of the portal is deemed consent to such use of your information and you must notify us if you do not wish your information to be used for such purposes.

We may use or disclose your personal information and other data provided by you for the following purposes:

  • analysing data, undertaking due diligence activities and making credit decisions on the basis of that data and due diligence where this is a condition of us entering into a contract with you, or where this is necessary for you to be considered for any other or ancillary service being offered by us and/or our Group Companies from time to time
  • assessing your suitability and eligibility to participate in any uncommitted funding program offered by us and/or our Group Companies from time to time and/or any other or ancillary service being offered by us and/or our Group Companies from time to time
  • processing credit card payments and providing customer service
  • to provide you with information about other goods or services we offer that are similar to those that you have purchased or enquired about
  • contacting you with publications and invitations to events and seminars that may be of interest to you (you may opt out/unsubscribe from such communications at any time by emailing [email protected] and putting "Unsubscribe" in the subject line together with the name of the publication you wish to unsubscribe from. All our marketing communications include an “unsubscribe” link)
  • to process any job application you may make to us (including any sensitive personal information you provide such as relating to your state of health or racial background)
  • to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us
  • to notify you about changes to our service
  • to ensure that content from our site is presented in the most effective manner for you and your computer
  • in the course of the provision of services
  • where required to do so by law or to meet the requirements of a regulator (including to meet any national security or law enforcement requirements)
  • where we merge, combine or divest a part or all of our business, we may pass your details to the prospective merger partner, purchaser or successor entity except where prohibited from doing so by law.

Who we share it with: Tungsten Network will not sell, rent, or lease your personally identifiable information to others except as described herein. Unless we have your permission or are required by law, we will only share the personal data and other data you provide to us with other Group Companies and/or business partners for the uses described in "how we use it." Such business partners may include but shall not be limited to, any person which is (or may potentially be) a party to, or an investor in, any financing or other transaction relating to any of your receivables which are to be included (or will potentially be included) as part of any uncommitted funding program offered by us and/or our Group Companies, and any officer, director, employee or affiliates of any such person, or any professional advisor, auditor, insurer, credit reference provider or ratings agent engaged by any such person, or any of our Group Companies or any regulatory or similar body of competent jurisdiction. We may also disclose your personal information to other third parties in the event that we buy or sell any business (including Tungsten Network itself, or the assets of Tungsten Network). We shall endeavor to ensure that Group Companies and/or business partners referred to above shall be bound by the appropriate confidentiality agreements and other contractual obligations regarding such information.

Data collected online may also be combined with information you provide when you register to use Tungsten Network services.

If you are currently subject to our Integrated Supplier Standard Terms and Conditions (“ISSTC”) then the parties listed in the preceding paragraph will be considered “authorized parties” for the purposes of the relevant clause(s) of your ISSTC, and we will be entitled to disclose your invoice data to such third parties, on a confidential basis, unless you notify us otherwise.

Accuracy & Access: Tungsten Network strives to keep your personally identifiable information accurate. We will provide you with access to your information, including making every effort to provide you with online access to your registration data so that you may view, update or correct your information at the Tungsten Network website where it was submitted. To protect your privacy and security, we will also take reasonable steps to verify your identity before granting you access or enabling you to make corrections. To access your personally identifiable information, return to the web page where you originally entered it and follow the instructions on that web page. Certain areas of Tungsten Network's website may limit access to specific individuals through the use of passwords and through providing personal data.

Links to third party websites are provided on this website solely as a convenience to you. If you use these links, you will leave this website. Tungsten Network has not reviewed all of these third party sites and does not control and is not responsible for any of these sites or their content. Tungsten Network does not endorse or make any warranties or representations about the other sites, or any information, software or other products or materials found there, any results that may be obtained from using them, or their privacy practices. If you decide to access any of the third party sites linked to this website, you do this entirely at your own risk.

Security: Tungsten Network is committed to ensuring the security of your information. To prevent unauthorized access or disclosure, maintain data accuracy and ensure the appropriate use of information, we have put in place appropriate physical, electronic and managerial procedures to safeguard and secure the information we collect online.

Transfer of Data: By consenting to the terms of this privacy policy, you agree that Tungsten Network may process some of your personally identifiable information in countries outside the European Union.

Changes to our Privacy Policy: Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by means of the portal or by email.

You have the right to ask us not to process your personal information for marketing purposes. If your personal information changes or you no longer wish to receive a particular communication from us please let us know and we will correct, update or remove your details. This can be done either by emailing [email protected] or by writing to: 

The Information Officer
Tungsten Network Limited
Pountney Hill House
6 Laurence Pountney Hill 
London EC4R 0BL
United Kingdom

EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield

Tungsten Network, Inc., its parent company, Tungsten Network Limited and Tungsten Network Limited's other Group Companies (“Tungsten Network Group”) are committed to respecting and protecting your privacy. Tungsten Network Group strives to uphold the highest ethical standards in business practices to collect, use and disclose personal information which is also in a manner consistent with the laws of the countries in which it does business.

To this end, Tungsten Network participates in and has certified its compliance with:

  • The EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield Framework set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information transferred from the European Union and Switzerland to the United States. Tungsten Network has certified to the U.S. Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield Principles and to view Tungsten Network’s certifications, please visit the Privacy Shield website.

PRIVACY PRINCIPLES

The privacy principles in this Policy are based on the Privacy Shield Principles.

For purposes of this Policy, the following definitions shall apply:

"Agent" means any third party that collects or uses personal information under the instructions of, and solely for, Tungsten Network Group or to which Tungsten Network Group discloses personal information for use on Tungsten Network Group's behalf.

"Personal information" means any information or set of information that identifies or is used by or on behalf of Tungsten Network Group to identify an individual. Personal information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public personal information.

"Sensitive" means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns health or sex life. In addition, Tungsten Network Group will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.

NOTICE: Where Tungsten Network Group collects personal information directly from individuals in the EEA or Switzerland, it will inform them about the purposes for which it collects and uses personal information about them and the choices and means, if any, Tungsten Network Group offers individuals for limiting the use and disclosure of their personal information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to Tungsten Network Group, or as soon as practicable thereafter, and in any event before Tungsten Network Group uses or discloses the information for a purpose other than that for which it was originally collected or discloses information to a non-agent third party.

Where Tungsten Network Group receives personal information from its Agents, collected directly from individuals in the EEA and Switzerland, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.

CHOICE: For personal information, Tungsten Network Group will offer individuals the opportunity to choose (opt-in) whether their personal information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

For sensitive personal information, Tungsten Network Group will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

Tungsten Network Group will provide individuals with reasonable mechanisms to exercise their choices.

TRANSFERS TO AGENTS: Tungsten Network Group will obtain assurances from its Agents that they will safeguard personal information consistently with this Policy. Examples of appropriate assurances that may be provided by agents include: a contract obligating the agent to provide at least the same level of protection as is required by the relevant Privacy Shield Principles, or EU Directive 95/46/EC (the EU Data Protection Directive), or Privacy Shield certification by the Agent, or being subject to another European Commission adequacy finding (e.g. companies located in Canada). Where Tungsten Network Group has knowledge that an Agent is using or disclosing personal information in a manner contrary to this Policy, Tungsten Network Group will take reasonable steps to prevent or stop the use or disclosure. Tungsten Network Group remains responsible and liable under the Privacy Shield Principles if its Agents process such personal information on Tungsten Network Group’s behalf in a manner inconsistent with the Privacy Shield Principles, unless Tungsten Network Group proves that it is not responsible for the event giving rise to such damage.

SECURITY: Tungsten Network Group will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

DATA INTEGRITY: Tungsten Network Group will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Tungsten Network Group will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current. We will only collect and store personal information that is relevant to fulfil the purpose of the request and will retain such information no longer than appropriate to fulfil the purpose of the request.

ACCESS: Upon request, Tungsten Network Group will grant individuals reasonable access to personal information that it holds about them. In addition, Tungsten Network Group will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.

ENFORCEMENT: Tungsten Network Group will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that Tungsten Network Group determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.

DISPUTE RESOLUTION: Any questions or concerns regarding the use or disclosure of personal information should be directed to the Tungsten Network Group Governance & Compliance Department at the address given below.

Tungsten Network Global Headquarters
Pountney Hill House
6 Laurence Pountney Hill
London EC4R 0BL
Tel: +44 (0)870 1657420
Email: [email protected]

Tungsten Network Group will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this Policy. Tungsten Network will respond to any such enquiries and complaints within forty-five (45) days.

For complaints that cannot be resolved between Tungsten Network Group and the complainant, Tungsten Network Group has agreed to work with relevant Data Protection Authority to resolve such matter.

An EU resident whose complaint has not been satisfactorily addressed may contact the panel established by the EU data protection authorities (DPAs) to resolve disputes. Please contact Tungsten Network to be directed to the relevant DPA contacts. Information can also be found on the European Commission - Data Protection website. Tungsten Network will comply with the information and advice provided to it by an informal panel of DPAs in relation to such unresolved complaints (as further detailed in the Privacy Shield Principles).

A Swiss resident whose complaint has not been satisfactorily addressed may contact the Federal Data Protection and Information Commissioner (FDPIC) of Switzerland using the information provided on their website.

As detailed in the Privacy Shield Principles, a binding arbitration option will also be made available to you in order to address complaints that cannot be resolved by other means.

Tungsten Network is also subject to the investigatory and enforcement powers of the United States Federal Trade Commission.

Changes to this Privacy Policy: Tungsten Network Group may amend this Policy from time to time with or without notice. Any modified policy will be posted on the Tungsten Network website.

This privacy and cookies policy was last modified in October 2017.