Privacy Policy

PLEASE READ THIS PRIVACY POLICY CAREFULLY

The Global Seafood Alliance (also d/b/a Best Aquaculture Practices (“BAP”) and Best Seafood Practices (“BSP”), and collectively referred to herein as “GSA,” “we,” “us,” and “our”) respects your privacy. This Privacy Policy describes our collection of personal information in connection with your use of our applications and websites, including those located at www.globalseafood.org, www.bapcertification.org, www.bspcertification.org, and GSA’s member portal (“Prism”) accessed at prism.globalseafood.org and GSA’s legacy member portal accessed at www.certificationportal.org (we refer to all of the foregoing collectively as the “Platform”). Additionally, this Privacy Policy describes how we use and share that information, and your rights and choices with respect to your information.

By continuing to use the Platform after having an opportunity to review this Privacy Policy, you have accepted the Privacy Policy in its entirety and without modification and consented to our collection, use, and sharing of your information, as described in this Privacy Policy. If you do not agree with this Privacy Policy, please exit and do not use the Platform.

We may revise this Privacy Policy periodically and will post any changes to the Platform. Changes to this Privacy Policy are effective at the time they are posted and your continued use of our Platform after posting will constitute acceptance of, and your consent to, those changes. We encourage you to review this Privacy Policy from time to time.

1. Personal Information We Collect

The personal information we collect depends on how you interact with our Platform and may include:

• Device Information: When you visit our Platform, we may learn information about your browser and operating system (e.g., name, version, settings, etc.), device type and settings, IP address, MAC address, mobile device identifiers, internet service provider, referring and exit pages, the date and time of your visit, and other similar details.
• Platform Usage Data: We may collect information about your interactions with our Platform, including the pages you visit, links or buttons you click, the search terms you enter, and other similar interactions with the Platform.
• Location Data: We may use various technologies to learn your geographic location, including by collecting your IP address or other Device Information, which may depend on your device’s settings for location services.
• Contact Information: We may collect your business or personal contact information, including your first and last name, postal address, telephone number, and email address, as well as your role, position, or title with respect to your employment.
• Payment Card Information and Payment Details: If you make payments to GSA via the Platform (e.g., fees associated with BAP or BSP Certification or GSA Membership), then we or our payment processor will collect your payment card information and payment details.
• Submitted Content: We collect the information you submit to us via our Platform, including, but not limited to, information submitted via forms on our Platform (e.g., our “Send Us a Message” or “Contact the Membership Team” pages); information submitted to our Platform’s online community forums; information submitted as part of an application, self-assessment, assessment, re-assessment, evaluation, questionnaire, or similar document or form required or requested by GSA in connection with your application to and/or maintenance of your entity’s BAP or BSP Certification; and information submitted in connection with your application for and maintenance of your GSA Strategic Partner, Individual, or Corporate Membership, or your status as a GSA Marketplace Partner or an approved Certification Body (“CB”).
• GSA Account Credentials: If you register an account with GSA (a “GSA Account”), we will collect your GSA Account credentials, which may include a username and password.
• Records of Communications: If you communicate with GSA (including by phone, email, or otherwise), we may keep records of those communications, including the information you provide to us in connection with such communications.
• Preferences: We may collect information about your preferences, such as your email preferences.

2. How We Collect Your Personal Information

We may collect the information described above directly from you, from third parties we partner with, or through the use of cookies or other automated means, as described below:

• Directly from You: We collect information directly from you, including when you contact us with questions or comments; provide Submitted Content via our Platform; create or update a GSA Account; or update your email preferences.
• From Third Parties: We work with third parties who provide services to us, including analytics companies, advertising and marketing companies, payment processors, email service providers, customer database service providers, and companies that assist with the operation and functionality of our Platform and our organization more generally. These third parties may share information they have collected with us. For example, when you make a payment via our Platform, any information you provide on the payment page will be collected and processed by our third-party payment processor, which may share certain payment details with us, but will not share your sensitive payment information with us.
• Automatically from Your Device or Browser: Certain information is automatically collected from your device or browser and analyzed when you visit our Platform, including Device Information, Platform Usage Data, and Location Data.
• Using Cookies: We may use cookies (small files stored on your device or browser), pixel tags (tiny graphic images embedded in a website or email), and other similar technologies to automatically collect information when you visit our Platform, including, for example, Device Information, Platform Usage Data, and Location Data. Through the use of cookies and similar technologies, we may link information about your interactions with our Platform, for example, which pages you visit, which links you use, and how long you stay on each page.
• In addition, when you use our Platform some of our third-party partners and service providers may use cookies, pixel tags, and similar technologies to automatically collect information from your device or browser and may share the information they have collected with us. For example, our data analytics providers (e.g., Google Analytics) may use the information they collect to provide us with aggregated information that helps us understand the operation, functionality, and use of our Platform. Likewise, our marketing and advertising partners (e.g., Google, Facebook) may, in addition to using the information they collect to provide GSA with services, use the information collected via their cookies and other technologies in order to provide you with targeted advertising based on your browsing activities and interests. Some of our Platform’s webpages “embed” posts from social media platforms (e.g., YouTube), which allows us to show you content, such as photos or videos, from our social media pages directly on our Platform. When you visit these webpages, certain data may be transmitted to these social media platforms via their cookies, pixel tags, or similar technologies. Information about how Google Analytics collects and uses your information can be found here.
• Publicly Available Sources: We may collect information offline and from publicly available sources (e.g., LinkedIn) and combine this information with information we collect via the Platform.

3. How We Use Your Personal Information

• Access to and Use of Our Platform: We use your information to facilitate your access and use of the Platform. In addition, we use your Device Information, Platform Usage Data, and Location Data to monitor and evaluate the performance and functionality of our Platform, including as part of our analytic practices, and otherwise to maintain or improve the content, security, and services offered through our Platform. Likewise, we use your GSA Account information and other information to operate the GSA Accounts, including by making certain information and services available to GSA Account users.
• Managing Your Relationship with GSA: We use your information (including Submitted Content and Contact Information) to process your application for certification, Marketplace Partner or approved-CB status, and membership, and to maintain your status as a BSP or BAP Certified entity, Marketplace Partner, approved CB, or GSA Member.
• Communications: We use the information you provide to us to communicate with you, including by responding to your requests and asking for your feedback through surveys, reviews, or other messages.
• Payment Processing: We use your Payment Card Information and Payment Details to process any payments to GSA, including, for example, fees associated with BSP or BAP Certification, Marketplace Partnership, approved CB programs, or GSA Membership.
• Advertising and Marketing: We may use your information for purposes of advertising and marketing our services online, via email and direct mail, and other communication channels, including through partnerships with social media platforms and internet search engines. We may also use your expressed preferences and other collected information to personalize your experience using our Platform, and to recommend other products, services, or information that we believe you may be interested in.
• Understanding Our Platform Users and Customers: We use your Device Information, Platform Usage Data, and Location Data to analyze your activity with us (including your interactions with our Platform and our emails or other forms of communication). We may keep track of the pages you visit and the manner in which you use the Platform to determine what services are most popular and whether to make changes to the Platform. We may, from time to time, review your information and the information of other Platform users to help us analyze trends, patterns, and preferences.
• Security: We use your information to protect GSA and our users and customers from fraud, security threats, and other illegal or harmful activity.
• Legal Obligations and Rights: We may use your information to help us comply with legal and regulatory requirements, to respond to requests from courts, law enforcement agencies, or other government bodies, and to exercise or defend our legal rights.
• As Otherwise Set Forth in an Agreement: To the extent that GSA has collected your personal information in connection with or pursuant to a Certification Agreement, a Marketplace Partner Agreement, or another agreement you’ve entered into with GSA, then we may use your information for the purposes set forth in those agreements.

4. How We Share Personal Information with Third Parties

We may share your information with third parties for certain purposes, as described below:

• Service Providers: As noted above, we partner with third-party service providers to assist with many aspects of our organization, including the auditing and monitoring of our BSP and BAP Certified facilities and vessels, communicating with our users and customers (e.g., email service providers), and operating and providing certain functionalities for our Platform (including your GSA Account) and our organization more generally. These third parties may provide services related to any of the purposes described in section 3 (“How We Use Your Personal Information”), and we may share with them the types of information described in section 1 (“Personal Information We Collect”). Your information may also be collected and processed by third parties, such as the payment providers you select, who will process your information independently in accordance with their own privacy notices.
• Marketing and Advertising Agencies and Data Analytics Providers: We partner with third parties to assist with the advertising and marketing of our business and to perform business and website analytics, including to analyze your interests and activity on our Platform (e.g., Google Analytics). We may share with them the types of information described in section 1 (“Personal Information We Collect”), which they may use for their own commercial purposes.
• GSA Affiliates and Partners: We may disclose certain information to our GSA affiliates and partners for their use, including, for example, when we share your Contact Information with our partner organizations and GSA affiliates.
• As Otherwise Set Forth in an Agreement: To the extent that GSA has collected your information in connection with a Certification Agreement, a Marketplace Partner Agreement, or another agreement with GSA, we may share your information with third parties as set forth in those agreements.
• Successors in Interest: Your information may be transferred to another entity that succeeds or intends to succeed to all or part of GSA’s business in connection with a sale, reorganization, consolidation, or merger.
• Other Third Parties: We and our business partners partners and service providers may disclose specific individual information if we or they reasonably believe it is necessary: (i) to comply with applicable law; (ii) to investigate any suspected misuse of the Platform; (iii) to protect or defend the rights, property, and interests of GSA, our Platform users, or the interests of our business partners or service providers; or (iv) under exigent circumstances, to protect the personal safety of GSA staff or members, Platform users, or the public. 

5. Your Privacy Choices

You can control the information we collect and use in the following ways:

• Automatically Collected Location Data: You can disable location-based services on your mobile device or web browser by adjusting the settings on your device or browser. This will prevent our Platform from automatically accessing your device’s location information. Note that some services may not be available if you disable location-based services.
• Emails: You can unsubscribe from marketing emails by clicking the “unsubscribe” link in the footer of such email. Note, however, that you may be required to maintain an email address on file with GSA in order to receive email communications concerning, for example, your entity’s certification or membership status and related requirements.
• GSA Accounts: You can keep your information (including your certification- and membership-related information) and payment methods accurate and up to date by logging into your GSA Account on our Platform. If you wish to cancel your GSA Account, please contact us using one of the methods provided in the “Contact Us” section below. Note, however, that you may be required to maintain a GSA Account to comply with the terms of an applicable Certification Agreement or other agreement. For more information about these requirements, please contact us using one of the methods provided in the “Contact Us” section below.
• Cookies: You may opt out of certain third-party cookies by following your browser’s instructions or by using the opt-out tools provided by the following industry groups:
  • Digital Advertising Alliance (DAA): http://www.aboutads.info/choices/
  • Network Advertising Initiative (NAI): http://optout.networkadvertising.org
  • Your Online Choices youronlinechoices.eu

If you do not accept cookies, you may experience some inconvenience in your use of the Platform.

Likewise, you can opt out of Google Analytics’ cookies by following the instructions provided here.

• User Requests: You can contact us at any time using our toll free number: +1-603-317-5000 or by email: info@globalseafood.org to request we do any of the following: (i) erase or delete all or some of your personal information; (ii) change, update, or correct your personal information; (iii) restrict how we use all or some of your personal information; (iv) access your personal information and, where applicable and feasible, request to receive that personal information in a commonly used electronic format (or ask for this information to be provided in that format to a third party); or (v) disclose what personal information we collect, use, or disclose. You may also request that we stop sharing your personal information with third parties for certain purposes by contacting us at the above phone number or email address. We will consider and respond to any such requests promptly, and otherwise in accordance with applicable laws.

If you are a resident of the EAA or the UK, you may have other rights with respect to our collection and processing of your personal data. Please see section 12(a) (“Notice to EEA and UK Residents”).

If you are a resident of Japan, you may have other rights with respect to our collection and processing of your personal information. Please see section 12(b) (“Notice to Residents of Japan”).

If you are a resident of Canada, you may have other rights with respect to our collection and processing of your personal data. Please see section 12(c) (“Notice to Residents of Canada”).

If you are a resident of Brazil, you may have other rights with respect to our collection and processing of your personal data. Please see section 12(c) (“Notice to Residents of Brazil”).

6. Children

The Platform is not directed to persons under the age of sixteen (16), and we do not knowingly or purposefully request or collect personal information from any person under the age of sixteen (16). If you believe that your child under the age of sixteen (16) has submitted personal information to GSA in connection with our Platform, please contact us at info@globalseafood.org.

7. Security

Although we use reasonable measures to protect your personal information from loss or unauthorized access, we cannot guarantee the security of information provided over the Internet or stored in our databases. Your transmissions are, therefore, at your own risk. You can help protect your information by selecting strong, unique passwords for your GSA Account and any associated email accounts.

8. Supported Web Browsers and Do Not Track Signals

We recommend that you use the latest web browser versions to optimize your experience. Older web browser versions may not be able to access or utilize all pages on our Platform as intended. We may not be able to receive or honor web browser “Do Not Track” signals and our Platform may continue to collect information in the manner described within this Privacy Policy.

9. Platform Terms of Use

GSA’s Platform Terms of Use, which govern your access to and use of the Platform, are located here.

10. Links to Other Websites; Social Media Platforms

The Platform may, from time to time, contain links to websites owned and operated by third parties (“Third-Party Sites”). We encourage you to review the privacy policies of such Third-Party Sites so that you understand how those websites collect, use, and share your information. We are not responsible for the privacy policies or other content on Third-Party Sites.

Similarly, this Privacy Policy does not cover the privacy practices of social media platforms on which GSA maintains its social media pages. Please review the terms, policies, and settings of those social media platforms if you have questions about how they collect, use, and share your information.

11. Contact Us

We welcome your comments and questions. Please contact us at:

Phone: +1-603-317-5000

Email: info@globalseafood.org

Address:

Global Seafood Alliance, Inc.

85 New Hampshire Avenue, Suite 200

Portsmouth, NH 03801 USA

12. Additional Notices

• Notice to EEA and UK Residents

Although GSA is based in the United States, we may, from time to time, process “personal data” of people who reside in the European Union, Iceland, Liechtenstein, Norway, or the United Kingdom, which processing may be subject to the European Union’s General Data Protection Regulation (also called the “GDPR”) or the United Kingdom General Data Protection Regulation (also called the “UK-GDPR”). “Personal data” is defined in the GDPR and the UK-GDPR as “any information related to an identified or identifiable natural person,” and, for purposes of this Privacy Policy, references to “personal data” in this section include the categories of information set forth in Section 1 above, if applicable.

We will only process your personal data to the extent applicable law allows us to do so.

The United States has not sought nor received a finding of “adequacy” from the European Union or the United Kingdom under article 45 of the GDPR or article 45 of the UK-GDPR. Therefore, we rely on derogations for specific situations as set forth in article 49 of the GDPR and article 49 of the UK-GDPR. In particular, we collect and transfer to the U.S. personal data only: with your consent; to perform a contract with you; or to fulfill a compelling legitimate interest in a manner that does not outweigh your rights and freedoms.

If you are a resident of the EU, Iceland, Liechtenstein, Norway, or the United Kingdom, you have certain rights under applicable law, including the right to:

• Request that we provide you with access to the personal data that we maintain about you;
• Request to correct, revise, or update any of the personal data we maintain about you;
• Request that we erase the personal data we maintain about you;
• Object to our processing of your personal data on the basis that the processing has a disproportionately detrimental impact on your interests, rights, and freedoms;
• Request that we restrict our processing activities related to your personal data;
• Withdraw your consent to our processing of your data at any time, however, such a withdrawal will not affect the lawfulness of our processing based on your consent prior to the withdrawal. Please note that where we rely on your consent in order to process your personal data and you then withdraw that consent, it may affect our provision of services to you, and may mean that we are unable to provide our services (either in part or in full) to you;
• Request to have your personal data reproduced in a structured, commonly used, and machine-readable format, whether such request relates to the transmission of the personal data to another party; and
• Request us to stop sending you marketing communications.

Residents of the EU, Iceland, Liechtenstein, Norway or the United Kingdom may initiate any of the above requests, objections, or requirements by sending us an email at info@globalseafood.org and writing “GDPR Request” in the subject line. You may also write to us at the postal address provided in Section 11 above.

Finally, you have the right to raise a concern about our collection and processing of your personal data with your local supervisory authority, available here (EAA) or here (UK) and you may do so without prejudice to any other rights you may have.

• Notice to Residents of Japan

Although GSA is based in the United States, we may, from time to time, process “personal information” of people who reside in Japan, which processing may be subject to the Act on the Protection of Personal Information (the “APPI”). “Personal information” means information about a living individual from which the identity of the individual can be ascertained (including information which enables identification by easy reference to, or in combination with other information), and information containing an individual identification code. For purposes of this Privacy Policy, references to “personal information” in this section include the categories of information set forth in Section 1 above, if applicable.

We will only process your personal information to the extent applicable law allows us to do so.

The United States has not sought nor received designation as an “equivalent country” from Japan’s data protection authority. You understand and agree that we may transfer your personal information to the United States for processing. The laws of the United States may not afford the same protection as the APPI, however, GSA will use reasonable measures to protect your personal information from loss and unauthorized access while in the United States. In the event that GSA transfers your personal information or “person-related information” to a third party in the United States, we will do so only with your consent or otherwise as required or permitted by applicable law, and we will take reasonable measures to ensure your personal information is protected by such third party.

If you are a resident of Japan, you may request that GSA provide you with additional information about our processing of your personal information (including the security measures we take to protect your information), and you may:

• Request that we provide you with access to the personal information that we maintain about you, including our record of transfers to third parties;
• Request to correct, amend, or delete the personal information we maintain about you; and
• Request that we cease processing your personal information in certain circumstances.

Residents of Japan may initiate any of the above requests, or raise a concern about our processing of your personal information, by sending us an email at info@globalseafood.org and writing “APPI Request” in the subject line. You may also write to us at the postal address provided in Section 11 above.

• Notice to Residents of Canada

Although GSA is based in the United States, we may, from time to time, process “personal data” of people who reside in Canada, which processing may be subject to the Personal Information Protection and Electronic Documents Act (“PIPEDA”). “Personal data” means information about an identifiable individual. For purposes of this Privacy Policy, references to “personal data” in this section include the categories of information set forth in section 1 above, if applicable.

We will only collect and process your personal data when we have a lawful basis for doing so. This lawful basis includes when you provide us with express consent, when consent is implied, or when we have a legal or contractual obligation to collect or process the information. By using the Platform or by providing us with your personal information by other means covered by this Privacy Policy, you have impliedly consented to our collection, use and disclosure of your personal information as explained in this Privacy Policy.

You may request to see, correct, or delete the personal information that we hold about you, or request to change or withdraw your consent to our collection and processing of your personal data. If you wish to request access to your personal data, or request that we correct or delete your personal data, or to change or withdraw your consent to our collection or processing of your personal data, please submit your request by sending us an email at info@globalseafood.org that includes your full name, email address, and home address, and clearly indicates you are changing or withdrawing your consent to our processing, or you are requesting access to, or correction or deletion of, your personal information pursuant to PIPEDA.  The information collected through this process will be used only to respond to your request. Please note that your right to access, correct, or delete the personal data that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse your request. In addition, the personal data may have been destroyed, erased, or made anonymous in accordance with our record retention obligations and practices.

In the event that we cannot provide you with access to, or rectification or deletion of your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.

You may also submit complaints or inquiries about our personal data collection and processing policies and practices by sending us an email at info@globalseafood.org. If you’d like to submit a complaint to Canada’s Office of the Privacy Commissioner, you can learn more about how to do so here.

We may transfer the personal information we collect about you to countries other than the country in which the information was originally collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to other countries, we will protect that information as described in this Privacy Policy.

• Notice to Residents of Brazil

Although GSA is based in the United States, we may, from time to time, process “personal data” of people who reside in Brazil, which processing may be subject to the Brazilian General Data Protection Law (“LGPD”).

We only collect and process your personal data when we have a lawful basis for doing so. This lawful basis includes when you provide us with express consent, when consent is implied, or when we have a legal or contractual obligation to collect or process your personal data. By using the Platform or by providing us with your personal data by other means covered by this Privacy Policy, you have impliedly consented to our collection, use and disclosure of your personal data as explained in this Privacy Policy.

If your personal data is subject to the LGPD, you may have certain privacy rights with regard to that information; however, these rights are not absolute and are subject to certain limitations provided by law. You may have the right to request that we:

• Confirm whether we are holding, processing, or disclosing your personal data;
• Provide access to your personal data;
• Correct incomplete, inaccurate, or out-of-date personal data;
• Anonymize, block, or delete unnecessary or excessive personal data or personal data processed in noncompliance with the provisions of the LGPD;
• Delete personal data collected with your consent, unless there is another legal basis for our processing of such personal data;
• Transfer your personal data to another product or service provider;
• Provide information about how we have used your personal data and about the third-party entities with which we have shared your personal data;
• Provide information regarding whether you may decline to consent to our processing of your personal data and about the consequences of such a declination; and

You may also revoke your consent to our collection of your personal data, subject to legal or contractual restrictions and reasonable notice, however, our processing of your personal data provided pursuant to your previously expressed consent remains valid unless you request deletion of such personal data.

Subject to commercial and industrial secrets, you or your legal representative may submit a request to exercise your rights under the LGPD at any time by sending us an email at info@globalseafood.org that includes your full name, email address, and home address, and clearly indicates which right or rights under the LGPD you wish to exercise.  The information collected through this process will be used only to respond to your request. You may also submit complaints or inquiries about our personal data collection and processing policies and practices using the same email address.