Gateway User Terms and Conditions 4.0 Jan 2022

ZDHC GATEWAY USER TERMS AND CONDITIONS
Content Overview
1. Introduction
2. Definitions
3. Use of Information System
4. Data disclosure
5. Scoring
6. Breach of Terms and Conditions
7. Terms and Termination
8. Fees and Payments
9. Verification
10. Maintenance and Support
11. Intellectual Property rights/Third Party rights
12. Disclaimer
13. Limitation of Liability
14. Non-Disclosure
15. Notices
16. Additional provisions
Annex 1: ZDHC Privacy Policy

Annex 2: Fees and Services
Annex 3: Data disclosure scheme
1. Introduction
This Information System, known as the ZDHC Gateway, is provided and

maintained by Stichting ZDHC Foundation (ZDHC) a not for profit organisation that
facilitates the ZDHC Roadmap to Zero Programme to advance towards zero
discharge of hazardous chemicals in the textile, apparel and footwear industries
through the widespread implementation of sustainable chemistry and best
practices to protect consumers, workers and the environment.
Please read these User Terms and Conditions (‘Terms and Conditions’) carefully.
By using the Information System you agree to the Terms and Conditions and to be
bound by all the provisions stated herein.
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ZDHC Gateway User Terms and Conditions Version 4.0 January 2022
Last Update: 01 January 2022

Consent to Processing of Personal Data:

As far as Personal Data are provided in the course of System Registration or use
of the Information System the person to which the Personal Data is related gives
its explicit consent to the processing of the Personal Data. The consent may be
withdrawn at any time which will not affect the lawfulness of the processing before
the consent was withdrawn.
ZDHC declares that all Personal Data will be stored and processed in accordance
with of Regulation (EU) 2016/679 on the protection of natural persons with regard
to the processing of personal data and on the free movement of such data.
For more details see the ZDHC Privacy Policy (Annex 1), in particular Appendix A.
2. Definitions
2.1. Brand/Retailer means any company that designs, and/or produces and/or
buys and/or sells textile, leather, apparel, footwear products and/or
accessories, whether branded or not.
2.2. Certification Organisations means an independent certification body that
is accepted by ZDHC as an indicator of ZDHC MRSL Conformance and has
access to the ZDHC Gateway in order to verify (approve or decline) the
status of chemical product certifications.
2.3. Confidential Information means all information owned, possessed or used
by ZDHC or User, which is not known to the public, that is communicated to,
learned, developed or otherwise acquired by the other party or their
Representatives (a) in the performance of the Information System, or
(b) through any form of written, verbal or electronic communication where the
party receiving the information knows or should know that such information is
confidential. Confidential Information includes but is not limited to trade
secrets, methodologies, financial data (including costs and price data),
personnel information, records, projections, sales and marketing data,
technical processes, product designs or other information regarding business
operations, suppliers, customers or computer systems.
2.4. Content means the audio and visual information, documents, software,
products and services contained or made available to User in the course of
using the Information System.
2.5. Data means electronic data and information submitted by or for User to the
Information System and/or collected and processed by and/or for User using
the Information System.
2.6. Data Subject means identified or identifiable natural person Personal Data
is relating to.
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2.7. Emergency Outage means downtime of the Information System and/or

services outside of a planned outage or maintenance window in order to
mitigate an imminent event outside of the reasonable control of ZDHC.
2.8. Formulator means any person or business entity in the chemical industry
that manufactures chemical products and are the original manufacturer of
the chemicals.
2.9. Information System means the combination of hardware, software,
infrastructure and trained personnel developed and used for the ZDHC
Gateway.
2.10. Intellectual Property Rights means unpatented inventions, patent
applications, patents, design rights, copyrights, trademarks, service marks,
trade names, domain name rights, mask work rights, know-how and other
trade secret rights, and all other intellectual property rights, derivatives
thereof, and forms of protection of a similar nature anywhere in the world.
2.11. ZDHC Accepted Laboratory means any laboratory accepted by ZDHC and
used for analysis for the purposes of submitting data on behalf of the
suppliers to the Information System.
2.12. MRSL Conformance means conformity of processes with the ZDHC
Manufacturer Restricted Substance List (MRSL).
2.13. Personal Data means Data within the meaning of Art. 4 (1) of Regulation
(EU) 2016/679.
2.14. Planned Outage means the Information System is unavailable for the
specified timeframe to permit ZDHC to perform regular maintenance
activities.
2.15. Representative means User’s employees, consultants, contractors or
agents who are authorised to use the Information System and who have
been supplied the means to securely access the Information System by
User (or by ZDHC at User’s request).
2.16. Supplier means a production unit where actual manufacturing processes
and activities take place.
2.17. System Registration means the process by which data, information,
payment and necessary approvals are collected from the User in order to
provide User access to the Information System.
2.18. User means an entity having registered for use of the Information System
and agreeing to these Terms and Conditions, including User’s affiliates and
Representatives.
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3. Use of Information System

3.1. Access to and Use of Information System. ZDHC hereby grants to User
a limited, non-exclusive, non-transferable, non-sub-licensable right to use
the Information System. ZDHC shall provide User with the means to access
the Information System and its Content. Access may include uploading or
downloading of data, approval or rejection of data or doing research within
the Information System’s data stock as to the concept of the Information
System.
3.2. Limitations. User agrees not to use data obtained from the Information
System for other than their business purposes in relation with the
implementation of sustainable chemistry and best practices to protect
consumers, workers and the environment. In particular, User shall not use
data for any purpose which is unlawful, prohibited by any applicable law or
regulation or is inconsistent with the aims of the operation of the Information
System in any way. User shall not: (i) license, sublicense, sell, resell,
transfer, assign, distribute or otherwise commercially exploit the Information
System or the Content in any way; (ii) modify or make derivative works
based upon the Information System or the Content; (iii) create Internet
"links" to the Information System or "frame" or "mirror" any Content on any
other server or wireless or Internet-based device without the express written
agreement of ZDHC; or (iv) reverse engineer, access, or provide access to
the Information System, including in order to (a) build a competitive product
or service, (b) build a product using similar ideas, features, functions or
graphics of the Information System, or (c) copy any ideas, features,
functions or graphics of the Information System. User understands that
User’s access to certain Content may change during the Term of use,
including if ZDHC no longer has the right to use and distribute Content.
3.3. Correctness of User’s company details. User assures that company
and/or personal details collected in the registration process are true and
correct. User in particular assures that the organisational and/or personal
data submitted during registration is based on is not a false or fake identity.
3.4. Password protection. User agrees to maintain the privacy of usernames
and passwords associated with the use of the Information System. User is
fully responsible for all activities that occur under User’s password or
Information System account, including all Representative accounts. User
will implement reasonable controls to ensure that the Information System is
only accessed and used by the then-currently authorised Representatives
and to ensure that each Representative’s access to and use of the
Information System is in compliance with these Terms and Conditions. User
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agrees to immediately notify ZDHC of any unauthorised use of User’s or a

Representative’s password or account or any other breach of security.
3.5. Discontinuation of Access: ZDHC will have the right to immediately
discontinue a Representative’s access to and use of the Information System
if such Representative breaches these Terms and Conditions or otherwise
impedes or disrupts any other user’s use of the Information System. Where
reasonably possible, ZDHC will deliver notice to User of the termination of a
Representative’s access to and use of the Information System.
3.6. Modifications and Enhancements of the Information System.
Modifications and enhancements such as upgrades to the user’s
interface/experience, functional enhancements, new features, and database
modifications may be implemented at the sole discretion of ZDHC.
4. Data disclosure. As far as the Information System enables Users to disclose or

obtain Data the following principles shall apply:
4.1. Data ownership. Data ownership i. e. the legal entitlement to and control
over Data remains with the User providing it to the Information System. The
User providing Data warrants that it has the right and/or license to enter the
Data into the Information System and that it may freely transmit all Data to
the Information System or will obtain all necessary consents to do so.
4.2. Data accuracy. Responsibility for ensuring that the Data entered is accurate
and reflects the requirements for use within the Information System lies
solely with the party entering (or having entered) the data into the
Information System unless otherwise indicated. User understands that
ZDHC does not guarantee or verify that Data entered into the Information
System are accurate or reliable and that, while all users must agree to only
enter accurate information into the Information System, User understands
and agrees that sole reliance upon the Data is at User’s own risk. User
warrants Data entered into the Information System is accurate and reliable
to the best of User’s understanding and knowledge and agrees not to
knowingly enter false or inaccurate Data into the Information System.
4.3. Extent of Data disclosure. Pursuant to the concept of the Information
System the extent of Data disclosure may vary:
• Data marked private. Data provided by the User to and/or stored in

the Information System but marked or designated as private (where
provided for) will not be made available to other users or any third
party.
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• Disclosure to selected Users. Data provided to and/or generated

by/stored in the Information System may be disclosed to selected
Users only (depending on the options available or pursuant to the
Information System’s logic). User hereby agrees that ZDHC will use
those Data in connection with the provision of services to the selected
Users.
• Disclosure to all Users. Data provided to and/or generated by/stored
in the Information System may be disclosed, also in an aggregated,
high-level format, to all Users qualifying for category of Users
authorised to obtain the Data pursuant to the concept of the
Information System. User agrees that ZDHC will use the Data in
connection with the provision of services to the Users.
• Public disclosure. Data provided to and/or generated by/stored in
the Information System may be disclosed to the public.
• A diagram showing the data disclosure scheme within the Information
System is attached as Annex 3. Regardless of the extent of disclosure
User understands and agrees that ZDHC will use all Data provided to
the Information System in an aggregated unidentifiable format for
benchmarking, research and data analysis.
4.4. Data Sharing. User’s approval to the use of Data within the system includes
the right of ZDHC to make Data available to third party organisations
(commercial as well as non-commercial) using those data for the same
purposes and to the same extent as ZDHC. Such sharing will occur in order
to advance communication and processes within the industry, in particular
to improve transparency, reduce duplication in supply chain communication
and reporting and increase scale and impact on advancing the
implementation of sustainable chemistry and best practices to protect
consumers, workers and the environment.
5. Scoring. User agrees that, by using the Information System, it might be subject to
a scoring scheme as defined by ZDHC (where provided for). The scoring results
might be published to other Users.
6. Breach of Terms and Conditions. Any breach of User’s obligations or

unauthorised use of the Information System will be deemed a material breach of
these Terms and Conditions. In case of such material breach ZDHC, in its sole
discretion and irrespective of any other of ZDHC’s rights from these Terms and
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Conditions, may immediately withhold or terminate User’s access to the

Information System.
7. Term and Termination.

7.1. Initial Term. The term for Information System access shall commence on
the date User registers for access to the Information System and agrees to
the Terms and Conditions herein. The term of use shall continue for the
period of time elected and paid for by User during System Registration.
7.2. Subsequent Term(s). To renew the access to the Information System for
subsequent term(s), User must update their System Registration, select the
term for registration, and agree to the Terms and Conditions at that time.
Failure to renew or extend the access prior to the expiration of the Initial
Term or subsequent terms shall result in an interruption of system access
until renewal or extension of registration is executed
7.3. Termination Upon Expiration of Term. Access to the Information System
will terminate at the end of the Term unless User updates System
Registration. Upon termination, User will no longer have access to the
Information System. ZDHC will have no obligation to retain or provide
access to User Data.
7.4. Breach of Contract. Any breach of User’s payment or other obligations or
unauthorised use of the Information System or any Service will be deemed
a material breach of these Terms and Conditions. In case of such a material
breach ZDHC, in its sole discretion, may withhold access to the Information
System, terminate User’s password, account or use of the Information
System. In particular, any violation of Intellectual Property Rights of other
users or any third party by User will result in immediate termination of the
use of the Information System. If termination of use is the result of a material
breach by User, User agrees and acknowledges that ZDHC has no
obligation to retain or provide User access to the User Data.
7.5. Effect of Termination. Upon termination for any reason, User shall cease
all use of the Information System, and User shall be entitled to receive an
electronic copy of the User Data it has input into the Information System; as
long as not otherwise requested by the User disclosure of Data and ZDHC’s
right to use and share Data as to Section 4 shall survive the expiration or
termination of use of the Information System. ZDHC will also provide all
documentation and deliverables that have been completed and paid for until
the date of Termination.
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8. Fees and Payments.

8.1. Fees. ZDHC will charge fees to Users as set out in these Terms and
Conditions and the price list annexed. The fees are due and payable in
advance of using the Information System.
8.2. Fee Modifications. ZDHC reserves the right to modify its fees and charges,
as well as introduce new charges that will take effect upon acceptance of
the amended Terms and Conditions.
8.3. Payment. User will pay the amounts set forth by ZDHC on the Information
System. Fees are exclusive of taxes, levies, duties, governmental charges
or expenses, including wire or bank expenses for payment. In addition to the
Fees and expenses specified in these Terms and Conditions and the price
list annexed, User is solely responsible for and will pay (or reimburse ZDHC
for) all withholding, value added and sales taxes due, except for taxes on
ZDHC’s income.
8.4. Suspension of Information System. In addition to any other rights granted
to ZDHC herein, ZDHC reserves the right to suspend or terminate User’s
access to the Information System if User does not make due payment or
does not agree to amendments of these Terms and Conditions. If ZDHC
initiates termination of use for violation of these Terms and Conditions or
failure to make payment, or for other cause, User will not be refunded any
prorated portion of the Fee from the time of termination until the end of the
current Term.
9. Verification and Data Quality. ZDHC may, at its expense, audit User’s use of the
Information System, provided that any such audit shall not materially interfere with
User’s business activities. ZDHC shall also be permitted to conduct automated
audits at its discretion, provided that such automated audits take place without
accessing User’s internal information technology networks and do not materially
interfere with User’s use of the Information System. If an audit reveals that User
has underpaid fees to ZDHC, User shall pay ZDHC such underpaid fees and if any
such underpayment exceeds five percent (5%) of the amounts due, User shall pay
ZDHC the reasonable costs of the audit. If necessary, User shall cooperate with
ZDHC to provide passwords and other information necessary for ZDHC to conduct
such audits. ZDHC’s right to audit includes the right to carry out data quality checks
and – if necessary also without the cooperation of the user – to take appropriate
measures to maintain and/or improve the quality of the data stock.
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10. Maintenance and Support

10.1. Scope of Maintenance. ZDHC is responsible for the operation,
maintenance and management of the Information System.
10.2. Maintenance. ZDHC will ensure regular and ongoing maintenance of the
Information System to correct bugs or other errors in the Information
System. Maintenance will be scheduled so as to cause as minimal
interference with User usage as reasonably possible. During the
maintenance, User may experience slowdowns or outages. Reasonable
efforts will be made to complete maintenance within the designated
maintenance window.
10.3. Planned Outage. ZDHC will ensure regular maintenance which will at times
require Planned Outage of the Information System. Minimum 24 hours’
notice will be provided to User of any such Planned Outage.
10.4. Emergency Outage. ZDHC may need to perform an Emergency Outage
for system maintenance. ZDHC will use commercially reasonable efforts to
notify User prior to any such Emergency Outage or as soon as reasonably
possible after beginning an Emergency Outage.
10.5. User Notification. User shall notify ZDHC immediately of any unexpected
outages or system malfunctions.
10.6. Errors. Under no circumstances does ZDHC warrant or represent that all
system errors or bugs can or will be corrected.
10.7. Out-of-Scope. If ZDHC determines that a reported problem is not a system
error, ZDHC will inform User and work with User to attempt to identify the
problem. For problems not solely caused by ZDHC or problems that are not
system errors, including problems caused by User's or third party equipment
or environment, then ZDHC may charge User reasonable fees for services
performed to diagnose and efforts to repair such problem. Without limiting
the foregoing, the following support services are outside the scope of
support as set out in this section 10: (a) support provided outside of mutually
agreed upon business hours or timeframes; (b) support which becomes
necessary due to failure of computer hardware, equipment or programs not
provided by ZDHC, negligence of User, error by User in operation of the
Information System, or improper modification or use of hardware or software
by User; (c) maintenance and support of hardware, software programs, or
data connections owned, operated or develop by User; and/or (d)
development, customisation, coding, installation, integration, consulting,
and training.
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10.8. EXCLUSIONS. Notwithstanding any other provisions of these Terms and

Conditions, ZDHC shall not be responsible for any failure to meet the service
level or support commitments set forth above if such failure is due to:
• User acts or omissions, including any User misuse or abuse of the
Information System or use in violation of the Terms and Conditions;
• Any force majeure event;
• Third party or User software, content or services;
• Viruses not prevented by ZDHC's application of industry standard anti-
virus software;
• User's or any third party’s violation of the Terms and Conditions;
• Malicious attacks on the Information System not prevented by ZDHC's
application of industry standard intrusion prevention software;
• Any increase in system utilisation by User beyond the agreed upon
hosting capacity.
10.9. Sole Remedy. The foregoing constitutes User’s sole and exclusive remedy
and ZDHC’s entire liability for system downtime.
11. Intellectual Property Rights/Third Party Rights.

11.1. Intellectual Property Rights. Without limiting the generality of the
provisions included in these Terms and Conditions, ZDHC shall at all times
solely and exclusively own all rights, title, and interest in and to the
Information System and any and all improvements, enhancements,
derivative works and extensions thereof, and all intellectual property rights
therein. User shall not remove, modify, or obscure any ZDHC or other
copyright, trademark, and other proprietary notices affixed to or displayed
on the Information System, and shall not allow any third party to take any
such action.
11.2. Third Party Rights. User understands and agrees that the Information
System is not legally affiliated with any brands or verification marks
mentioned therein. The Information System is not necessarily endorsed or
sponsored by any of those brands or verification marks and all brand names
contained therein are trademarks for their respective owners.
12. Disclaimer. THE INFORMATION SYSTEM IS PROVIDED "AS IS" WITHOUT

ANY WARRANTY, AND USER’S USE OF THE INFORMATION SYSTEM IS
SOLELY AT USER’S OWN RISK. ZDHC DOES NOT WARRANT THAT THE
INFORMATION SYSTEM WILL MEET USER’S REQUIREMENTS OR THAT THE
OPERATION WILL BE UNINTERRUPTED OR ERROR-FREE. TO THE FULLEST
EXTENT PERMISSIBLE UNDER APPLICABLE LAW, ZDHC DISCLAIMS ALL
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REPRESENTATIONS AND WARRANTIES, EXPRESS, IMPLIED, AND

STATUTORY, CONCERNING THE INFORMATION SYSTEM OR OTHERWISE
RELATED TO THESE TERMS AND CONDITIONS, INCLUDING, BUT NOT
LIMITED TO, THE IMPLIED WARRANTIES OF MERCHANTABILITY AND
FITNESS FOR A PARTICULAR PURPOSE OR ARISING FROM A COURSE OF
DEALING OR USAGE OF TRADE, AND ANY STATUTORY WARRANTIES OF
NON-INFRINGEMENT.
13. Limitation of Liability.

EXCLUDING DAMAGES ARISING FROM OR OUT OF GROSS NEGLIGENCE,
WILLFUL MISCONDUCT OR FRAUD, IN NO EVENT SHALL ZDHC’s LIABILITY
EXCEED €150,000 (one hundred and fifty thousand Euros). EXCLUDING
DAMAGES ARISING FROM OR OUT OF GROSS NEGLIGENCE, WILLFUL
MISCONDUCT OR FRAUD, TO THE FULLEST EXTENT PERMISSIBLE UNDER
APPLICABLE LAW IN NO EVENT SHALL ZDHC BE LIABLE TO ANYONE FOR
ANY INDIRECT, PUNITIVE, SPECIAL, EXEMPLARY, INCIDENTAL, OR
CONSEQUENTIAL DAMAGES OF ANY TYPE OR KIND (INCLUDING LOSS OF
DATA, REVENUE, PROFITS, USE OR OTHER ECONOMIC ADVANTAGE)
ARISING OUT OF, OR IN ANY WAY CONNECTED WITH THE INFORMATION
SYSTEM, INCLUDING BUT NOT LIMITED TO THE USE OR INABILITY TO USE
THE INFORMATION SYSTEM, OR FOR ANY CONTENT OBTAINED FROM OR
THROUGH THE INFORMATION SYSTEM, OR ANY INTERRUPTION,
INACCURACY, ERROR OR OMISSION, REGARDLESS OF CAUSE, IN THE
CONTENT, EVEN IF THE PARTY FROM WHICH DAMAGES ARE BEING
SOUGHT OR SUCH PARTY'S LICENSORS HAVE BEEN PREVIOUSLY
ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.
14. Non-Disclosure. Notwithstanding any other provisions in these Terms and

Conditions all Confidential Information disclosed hereunder will remain the
exclusive and confidential property of the disclosing Party. The receiving Party will
not disclose the Confidential Information of the disclosing Party and will use at least
the same degree of care, discretion and diligence in protecting the Confidential
Information of the disclosing Party as it uses with respect to its own confidential
information, but in no case less than reasonable care. The receiving Party will limit
access to Confidential Information to its affiliates, employees and authorised
representatives with a need to know and will instruct them to keep such information
confidential and will only use Confidential Information in connection with the use of
the Information System. Notwithstanding the foregoing, the receiving Party may
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disclose Confidential Information of the disclosing Party (a) to the extent necessary
to comply with any law, rule, regulation or ruling applicable to it, (b) as appropriate
and with prior notice where practicable, to respond to any summons or subpoena
or in connection with any litigation, and (c) relating to a specific employee, to the
extent such employee has consented to its release. Upon the request of the
disclosing Party, the receiving Party will return or destroy all Confidential
Information of the disclosing Party that is in its possession. The obligations and
restrictions contained in this Section do not apply to information: (i) which is now or
subsequently becomes publicly available other than by breach of these Terms and
Conditions; (ii) which was already in the recipient’s possession and at its free
disposal at the time of disclosure and was not obtained directly or indirectly from
discloser; or (iii) which is independently developed by the recipient without use of
the other Party’s Confidential Information.
15. Notices. Any notices given by either Party hereunder will be in writing and will be
given by personal delivery, national overnight courier service, by email, receipt
requested, or by postal service, certified or registered, postage prepaid, return
receipt requested, to ZDHC at the address specified below or to User at the
address specified during System Registration. All notices will be deemed effective
upon personal delivery, return receipt received for emails, or two (2) business days
following delivery confirmation with any overnight courier services. All notices
related to the use of the Information System shall be addressed to the following:
To ZDHC:
Stichting ZDHC Foundation
Watersteeg 3
1012NV Amsterdam
The Netherlands
E-Mail: media@zdhc.org
16. Additional Provisions.

16.1. Governing Law and Jurisdiction. The use of Information System shall be
governed by Dutch Law, without regard to the choice or conflicts of law
provisions of any jurisdiction, and any disputes, actions, claims or causes of
action arising out of or in connection with the use of Information System shall
be subject to the exclusive jurisdiction of the courts located in the
Netherlands.
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16.2. Transfer of operation. ZDHC reserves the right to transfer the operation in
whole or in part of the Information System at any time to any
organisation/legal entity affiliated to ZDHC which is either owned by ZDHC
entirely or owned by a ZDHC majority.
16.3. Authority. User hereto represents and warrants to ZDHC that the person
executing the registration is duly authorised to execute and deliver this
registration, and by so executing the registration, User is formally bound to
the provisions of these Terms and Conditions and is a validly existing entity
with full right and authority to enter into these Terms and Conditions and
perform hereunder.
16.4. Total Agreement. These Terms and Conditions constitute the entire
agreement and understanding between the parties with respect to the
subject matter hereof and supersedes all prior or contemporaneous
agreements, any representations or communications with respect to
accessing the ZDHC Information System. The Terms and Conditions may
be amended by ZDHC and User will receive notification of such amendment.
In order to access the Information System, User will need to click “Agree” to
the amended Terms and Conditions.
16.5. Non-Waiver. No waiver by either party of any breach or default of any
covenant or agreement set forth in these Terms and Conditions shall be
deemed a waiver as to any subsequent and/or similar breach or default.
16.6. Severability. In the event that any of the provisions contained in these
Terms and Conditions is held to be invalid, illegal, or unenforceable in any
respect, such invalidity, illegality or unenforceability shall not affect any other
provisions of these Terms and Conditions, and these Terms and Conditions
shall be construed as if the invalid, illegal, or unenforceable provisions had
never been contained in it.
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Annex 1 – Privacy Policy
Introduction
ZDHC Group1 (ZDHC Group) is taking the opportunity to update its privacy policy2 for
services to make it easier to understand what information and data3 ZDHC Group
collects and why (Policy). For ‘personal data’ (see below) this policy takes into account
requirements of the EU General Data Protection Regulation (known as GDPR) and as
provided for in the ZDHC Group Privacy Notice (Appendix A). This policy is included as
part of the applicable User Terms and Conditions relating to ZDHC Group Services and
is shared on relevant web-based Services.
This Policy is for users of ZDHC Group web-based platforms, products and services
including and not limited to the ZDHC Gateway, ZDHC Academy, ZDHC Intranet
(Contributors only), Implementation HUB Supplier Platform including Supplier to Zero
Platform, ZDHC Group event registration tool (together called Services) and is
intended to clarify the following:
1) the types of information collected by ZDHC Group;
2) how ZDHC Group uses, stores and processes collected information; and
3) how individuals (for personal data) and organisations can have their information
reviewed, updated, or removed.
About ZDHC Group

The ZDHC Group works to enable the textile, apparel, and footwear (including leather)
industries (the ‘Industry’) to implement sustainable chemical management best practice
across the value chain, with the vision of the widespread implementation of sustainable
chemistry, driving innovations and best practices in the Industry to protect consumers,
workers and the environment. ZDHC Group believes that, providing guidelines,
platforms and solutions, fostering collaboration and driving joint implementation among
Industry stakeholders across the value chain, leads to improved chemical management
in the Industry, and ultimately improves the livelihoods of consumers and workers, and
the environment. ZDHC Group also carries out activities to drive implementation in
the Industry of sustainable chemicals management guidelines, platforms, solutions and
processes by offering training, consulting, awareness raising and advisory services.
1
ZDHC Group includes Stichting ZDHC Foundation, Implementation Hub B.V. and any other wholly or majority owned legal entities
of either.
2
This privacy policy covers a range of information and data types and including ‘personal data’ within the meaning of the EU General
Data Protection Regulation.
3
Throughout this policy ZDHC Group uses the words ‘information’ and ‘data’ interchangeably and to mean the same thing.
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ZDHC Gateway User Terms and Conditions Version 4.0 January 2022 Last Update: 01 January 2022
In connection with these activities, ZDHC Group collects and processes different kinds
of information and data from a range of different stakeholders including ZDHC
Contributors, third party organisations that have an official (approved) role within our
systems and platforms, Industry partners, users of ZDHC platforms and individuals
acting on behalf of these organisations.
1. Types of Information Collected By ZDHC Group
ZDHC Group collects the following four types of information (including data)
(Information).
1.1. Personal Information

Many of ZDHC Group Services require the user to sign up for an account. To create an
account ZDHC Group may ask for personal Information such as name, email address,
phone number.
1.2. Organisational Information

In the case where an individual signs up on behalf of an organisation (legal entity) such
as a corporation, association or other organisation, ZDHC Group may ask for
organisational information such as legal entity, place of business, registered address,
address and contact details, bank and tax details etc.
1.3. Operational Information

Some of the Services provided by ZDHC Group relate to operational information such
as general product information, test reports, and chemical management, sustainability
and environmental information; users may be requested or required to upload such
information.
1.4. Meta Information

While using ZDHC Group’s Services or viewing content provided by ZDHC Group,
ZDHC Group will automatically collect and store certain information in server logs;
ZDHC Group files information such as internet protocol (IP) addresses, browser type,
internet service provider (ISP), referring/exit pages, platform type, date/time stamp or
number of clicks.
2. How Does ZDHC Group Use Information That Is Collected?
In general, all information collected by ZDHC Group aims at and is limited to

providing/maintaining/improving Services or developing new Services in connection
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with ZDHC Group goals and activities (see About ZDHC Group). In pursuing this
objective ZDHC Group may use the different types of Information as set out below.
2.1. Personal and Organisational Information

Both personal Information and organisational information are used exclusively to grant
access to ZDHC Group’s Services and to allocate any operations and/or transactions
within these Services to a specific user. We always ask explicit consent, having given
clear, transparent insight into what information will be used and how. For rights granted
to data subjects in relation to personal data pursuant to GDPR please see Appendix A
- ZDHC Group Privacy Notice.
2.2. Operational Information

Operational Information is used only to provide Services that enable and support ZDHC
Group to pursue its mission and vision (see About ZDHC Group). In this context, ZDHC
Group may use operational information for benchmarking and statistical purposes.
Operational information is only disclosed to third parties to the extent that the
information provider has agreed in advance to such disclosure e.g. by explicitly
accepting applicable user terms and conditions. In that case, ZDHC Group will impose
the obligation on the third party (to whom the information is disclosed) to only use the
information for purposes related to the goals and objectives of ZDHC Group and with
full recognition of the data providers intellectual property rights.
2.3. Meta Information

Meta information is not linked to any identifiable information whether personal,
organisational or operational. It is used exclusively to understand meta information and
trends e.g. by producing statistical reports, monitoring Services and analysis.
Meta information will not be used for purposes other than those set out above unless
one of the following circumstances applies:
• The data provider/subject provides its express consent.

• External processing: ZDHC Group provides information to its affiliates or other
trusted businesses or persons to process it, based on ZDHC Group’s
instructions and in compliance with ZDHC Group Privacy Policy and any other
appropriate confidentiality and security measures.
• Legal reasons: ZDHC Group will share information with companies,
organisations (including governmental authorities) or individuals outside ZDHC
Group if ZDHC Group has a belief in good faith that access, use, preservation
or disclosure of the information is reasonably necessary to meet any applicable
3

law, regulation, legal process or enforceable governmental request, including
outside of the EU. ZDHC Group would use meta Information to
• enforce applicable user terms of service, including investigation of
potential violations
• detect, prevent or otherwise address fraud, security or technical issues
• protect against harm to the rights, property or safety of ZDHC Group, the
Services users of the Services or the public, as required or permitted by
law.
3. How Can Users Access, Review and Update Information That ZDHC Group
Has Collected?
ZDHC Group strives to enable users of Services who deliver proof of their identity and
authorisation to access, review and update Information that has been provided by them
quickly and effectively unless this infringes the fundamental operating principles or
objectives behind the Services in question.
For personal data the data subject should refer to the procedures outlined in the ZDHC
Group Privacy Notice (Appendix A).
4

Appendix A
ZDHC GROUP PRIVACY NOTICE
Version 1.0 May 2020

Last Update: 11 May 2020
Important Note: The current version of this Privacy Notice will always be available
on https://www.roadmaptozero.com/privacy-notice/. In the event of a discrepancy
between the version in this Appendix the version online shall apply.
Introduction
This Privacy Notice explains the types of personal data4 we may collect about you when
you interact with us at the ZDHC Group5 (ZDHC Group). It also explains how we store
and handle personal data and keep it safe.
We know that there’s a lot of information here, however aim is to fully inform you on
what personal data ZDHC Group collects, how ZDHC Group uses your data and
importantly your rights in connection with your personal data. We hope the following
sections will answer any questions you have but if not, please get in touch with us. See
What Are Your Rights? section below for details of how to contact us.
It’s likely that we’ll need to update this Privacy Notice from time to time. We’ll notify you
of any significant changes, and you’re welcome to come back and check it whenever
you wish.
The ZDHC Group works to enable the textile, apparel, and footwear (including leather)
industries (the ‘Industry’) to implement sustainable chemical management best practice
across the value chain, with the vision of the widespread implementation of sustainable
chemistry, driving innovations and best practices in the Industry to protect consumers,
workers and the environment. ZDHC Group believes that, providing guidelines,
platforms and solutions, fostering collaboration and driving joint implementation among
Industry stakeholders across the value chain, leads to improved chemical management
4
Throughout this Privacy Notice we use the words data and information interchangeably and to mean the
same thing.
5
This Privacy Notice applies to the activities of the ZDHC Group including Stichting ZDHC Foundation,
Implementation Hub B.V. and any other wholly or majority owned legal entities of either.
5

in the Industry, and ultimately improves the livelihoods of consumers and workers, and
the environment. ZDHC Group also carries out activities to drive implementation in
the Industry of sustainable chemical management guidelines, platforms, solutions and
processes by offering training, consulting, awareness raising and advisory services.
In connection with these activities, ZDHC Group collects and processes different kinds
of information and data from a range of different stakeholders including ZDHC
Contributors, third party organisations that have an official (approved) role within our
platforms and solutions, Industry partners and individuals acting on behalf of those
organisations.
With regard to the personal data we collect, we act as a controller of data processing.
As such we are fully responsible for the adherence to the requirements of Regulation
(EU) 2016/679 on the protection of natural persons with regard to the processing of
personal data and on the free movement of such data (General Data Protection
Regulation – GDPR).
Our full contact details are:
Stichting ZDHC Foundation

Watersteeg 3
1012 NV, Amsterdam
The Netherlands
E-Mail: media@zdhc.org
1. Our Basis for Holding Personal Data

The law on data protection sets out a number of different reasons for which an
organisation may collect and process your personal data, including:
1. Consent
In specific situations, we can collect and process your data with your consent. For
example, when you tick (check or select) a box to receive email newsletters. When
collecting your personal data, we’ll always make clear for you which data is necessary
in connection with particular activities, platforms and solutions. You can also opt out at
any time.
2. Contractual obligations
6

In certain circumstances, we need your personal data to comply with our contractual
obligations. Information such as your name, contact details or place of work may be
needed as part of creating a contract with a ZDHC Group entity.
3. Legal compliance
If the law requires us to, we may need to collect and process your personal data. For
example, we may need to hold onto your name, address, organisation data, and
payments made to any ZDHC Group entity for auditing and tax purposes.
4. Legitimate interest
In specific situations, we require your data to pursue our legitimate interests in a way
which might reasonably be expected as part of operating the activities of the ZDHC
Group and any related activities and services and which does not materially impact
your rights, freedom or interests.
For example, if you set up an account in our event registration tool and purchase an
event ticket from us:
● We will collect your address details and VAT number to generate your invoice;
● We will pass your name and job title onto a printer for printing an event name badge
for attending an event we are hosting;
● We will use your email address details to send you the event agenda and any
updates on the event
● We may ask for feedback on the event.
2. When Do We Collect Your Personal Data?

We collect your personal data in a range of circumstances amongst others:
• When you visit our websites and platforms, and use your user account to:
o Participate in ZDHC Group offered programmes, platforms and solutions
e.g. assessment platforms such the Leader to Zero Programmes;
stakeholder management platforms for Contributors and laboratories; and
collaboration/engagement platforms such as the ZDHC Intranet or the
MRSL Submission Platform and supplier platforms such as the
Implementation HUB Supplier Platform.
o Buy tickets to an event or meeting for example the ZDHC Annual Meeting,
other ZDHC Group Meetings or events.
• When you create an account with us on our platforms (or other systems) and/or
when you need personal details changed or updated.
7

• When your organisation applies to become and, if approved becomes, one or more
of the following types of organisations, we request personal contact information
which is in support of the organisational information and which is necessary for
efficient management:
o A ZDHC Contributor or Friend of ZDHC.
o A ZDHC Accredited Training Provider (ATP).
o A ZDHC Certification Organisation within the ZDHC Gateway - Chemical
Module.
o A ZDHC Accepted Laboratory within the ZDHC Gateway - Wastewater
Module.
o An Implementation HUB approved or accepted third party solution or service
provider listed and/or profiled on https://www.implementation-hub.org/
• When you download or install any apps we work with.
• When you register to attend a ZDHC hosted webinar or other virtual meeting or
event being hosted remotely, digitally.
• When you contact us by any means with queries, complaints etc.
• When you ask one of our team or other relevant stakeholders to send you
information or answer a query on ZDHC Group activities including and not limited
to ZDHC Roadmap to Zero Programme or Implementation Hub activities, platforms
and solutions.
• When you choose to complete any ZDHC Group surveys we send to you and
request you to complete.
• When you agree to collaborate on creating a case study or any other marketing
material, or participate in a pilot.
• When you download the official ‘Detoxing the Fashion Industry for Dummies’ book.
Before we get into more detail we want to be clear that we do not:

• Collect the following personal data:
o When you engage with us on our social media channels.
o About children.
o The great majority of personal data falling with the following categories of
sensitive data: physiological data, mental identity, economic identity, social
identity, racial or ethnic origin, political opinions, religious or philosophical
beliefs, trade union membership, health, sex life, sexual orientation, genetic
data, biometric data or criminal offences/convictions.
• Sell personal data to any third parties.
8

3. What Personal Data Do We Collect?
If you have a web account with us, e.g. on any ZDHC Group platform, the ZDHC
Intranet or our event registration tool, we will collect: your name, billing/delivery
address, email and telephone number. For your security and to reset your password
(when requested by you) we also keep an encrypted record of your login password.
Details of your interactions with us through email, face to face, telephone/conference

calls/webinars/virtual meetings and events will be stored on our customer relationship
management system.
When you make a purchase on our event tool we will see some encrypted information
on your credit or payment card number.
Where the law requires this, copies of documents you provide to us to prove your age
or identity for example your passport / driver's licence. This is likely to include details of
your full name, address, date of birth and a facial image, gender and nationality. All
such provided data is not stored by us and is deleted after we have used it only for this
legally required purpose.
Details of your visits to our websites or apps by way of an IP address.
Information gathered by the use of cookies in your web browser.
Of course, it’s always your choice whether you share such personal data with us.
4. How and Why Do We Use Your Personal Data?

We want to give you the best possible experience of dealing with the ZDHC Group.
One way to achieve that is to create the richest picture we can of you by combining the
data we have on you. We then use this to offer you opportunities to engage and/or
collaborate that are most likely to interest you. For example, perhaps you don’t want to
become a ZDHC Contributor, and would rather engage in the ZDHC Gateway or
perhaps become a ZDHC Accredited Training Provider or another third party approved
solution/services provider for implementation activities. By gathering a certain amount
of information, we can communicate and engage with you more effectively. The data
privacy law allows this as part of our legitimate interest in understanding our
stakeholders and providing the highest levels of service.
Of course, if you wish to change how we use your data, you’ll find details about how to
do that in the ‘What Are Your Rights?’ section below.
9

Remember, if you choose not to share your personal data with us, or refuse certain
contact permissions, we might not be able to provide some services you’ve asked for.
For example, if you’ve asked us for updates on events, but withdrawn your email
address data, we may not be able to provide this kind of information. Or if you have
registered to attend a ZDHC Group webinar or digitally hosted meeting or event and
then removed contact details through which we would send you the link to join it.
Here are some more specific information on how we’ll use your personal data and why:
1. To process any orders you make to attend a ZDHC Group hosted or co-hosted
paid for event by using ZDHC Group event registration tools. If we don’t collect
your personal data during checkout, we won’t be able to process your order and
comply with our legal obligations. Your details may need to be passed to a trusted
third party to provide a payment gateway for you to purchase an event ticket. We
may keep your details for a reasonable period afterwards only to fulfil any
contractual obligations such as refunds.
2. To respond to your queries, refund requests and complaints. Handling the
information you send enables us to respond. We may also keep a record of these
to inform any future communication with us and to demonstrate how we
communicated with you throughout. We do this on the basis of our contractual
obligations to you, our legal obligations and our legitimate interests in providing you
with the best service and understanding how we can improve our service based on
your experience.
3. To protect our business and your account from fraud and other illegal activities.
This includes using your personal data to maintain, update and safeguard your
account. We’ll also monitor your browsing activity with us to quickly identify and
resolve any problems and protect the integrity of our websites. We’ll do all of this
as part of our legitimate interest.
4. To process payments and to prevent fraudulent transactions. We do this on the
basis of our legitimate business interests. This also helps to protect our customers
from fraud.
5. If we discover any criminal activity or alleged criminal activity, we will process this
data for the purposes of preventing or detecting unlawful acts.
6. We always strive to protect the brand equity of any organisations who support the
work of the ZDHC Group and will act immediately in the event of a breach of ZDHC
Group guidelines thereof.
10

7. With your consent, we will use your personal data, preferences and details of your
transactions to keep you informed by email, web, telephone or otherwise about
relevant events, meetings, sponsorships and so forth that may be of interest to you.
8. To send you communications required by law or which are necessary to inform you
about our changes to the services we provide you. For example, updates to this
Privacy Notice, and legally required information relating to your activities with the
ZDHC Group. These messages will not include any promotional content and do not
require prior consent when sent by email or text message. If we do not use your
personal data for these purposes, we would be unable to comply with our legal
obligations.
9. To develop, test and improve the systems, services and offerings we provide to
you. We’ll do this on the basis of our legitimate business interests. For example,
we’ll record your browser’s Session ID to help us understand more when you leave
us online feedback about any problems you’re having.
10. To comply with our contractual or legal obligations to share data with law
enforcement. For example, when a court order is submitted to share data with law
enforcement agencies or a court of law.
11. To send you survey and feedback requests to help improve our services and
activities. These messages will not include any promotional content and do not
require prior consent when sent by email. We have a legitimate interest to do so
as this helps make our products or services more relevant to you.
Of course, you are free to opt out of receiving these requests from us at any time by
updating your preferences in your online account.
To build a rich picture of who you are and what you like, and to inform our business
decisions, we’ll combine data captured from across the ZDHC Group and third parties
such as our data processors and as we have described in the section 'What Personal
Data Do We Collect?'. We do this on the basis of our legitimate business interest.
For example, by combining this data, this will help us decide which activities or content
to share with you.
Sometimes, we’ll need to share your details with a third party who is providing a service
(such as a payment gateway). We do so to maintain our (contractual) obligation to you
– for example to host and deliver a paid for event. Without sharing your personal data,
we’d be unable to fulfil your request.
11

5. Combining Your Data For Personalised Direct Marketing
We want to bring you information most relevant to your interests at particular times. To
help us form a better, overall understanding of your needs, we combine your personal
data gathered across ZDHC Group as described above, for example your event ticket
purchasing history. For this purpose, we combine the data that we collect directly from
you with data that we obtain from third parties to whom you have given your consent to
pass that data onto us. By doing so we practice automated decision-making within the
meaning of GDPR.
6. How We Protect Your Personal Data

We know that data security matters to all our stakeholders. We treat your personal data
with the utmost care and take all appropriate steps to protect it.
We secure access to all transactional areas of the ZDHC intranet and apps using ‘https’
technology.
Access to your personal data is password-protected, and sensitive data such as

payment card information is secured and tokenised to ensure it is protected.
We monitor our system for possible vulnerabilities and attacks, continuously enhance
our data protection processes and carry out penetration testing to identify ways to
further strengthen security.
7. How Long Will We Keep Your Personal Data?
Whenever we collect or process your personal data, we’ll only keep it for as long as is
necessary for the purpose for which it was collected. Put another way, we will not hold
onto or store personal data that is no longer needed.
At the end of an appropriate and reasonable retention period, your data will either be
deleted completely or anonymised, for example by aggregation with other data so that
it can be used in a non-identifiable way for statistical analysis and business planning.
Here are some examples of customer data retention periods:
• Event Tickets - when you buy an event ticket, we’ll keep the personal data you give
us for a maximum of one year so we can comply with our legal and contractual
obligations.
12

• Newsletter Subscriptions - when you have a regular subscription with ZDHC Group,
we’ll keep the personal data you give us for a maximum of three years so we can
comply with any legal and contractual obligations.
8. Who Do We Share Your Personal Data With?

We sometimes share your personal data with trusted third parties such as contracted
data processors. For example, payment gateways. Here’s the policy we apply to these
organisations to keep your data safe and protect your privacy:
• We provide only the information they need to perform their specific contractually
agreed services.
• They may only use your data for the exact purposes we specify in our contract
with them.
• We work closely with them and monitor their activities to ensure your privacy is
respected and protected at all times.
• If we stop using their services, any of your data held by them will either be
deleted or rendered anonymous.
Examples of the kind of third parties we work with are:
• IT companies who support our websites, platforms and other business systems.
• Operational companies such as delivery couriers.
• Companies who help us manage our electronic communications with you or
through whom we deliver virtually hosted online ZDHC Group meetings and
events.
• Payment gateway providers to facilitate handling payments for event tickets and
other payments within our platforms and services.
We generally do not share your data with third parties for their own purposes and when
we do it’s in very specific circumstances, for example:
• With your consent, given at the time you supply your personal data, we may
pass that data to a third party such as a collaboration partner for their direct
marketing purposes.
• For example, if we run a joint event with another party, and you agree to receive
direct communications from them e.g. following the SAC-ZDHC Manufacturer
Forums.
13

• For fraud management, we may share information about fraudulent or potentially
fraudulent activity in our premises or systems. This may include sharing data
about individuals with law enforcement bodies.
• We may also be required to disclose your personal data to the police or other
enforcement, regulatory or Government body, in your country of origin or
elsewhere, upon a valid request to do so. These requests are assessed on a
case-by-case basis and take your privacy into consideration.
To help personalise your journey through our websites and platforms we currently use
the following companies and/or products that will process your personal data as part of
their contracts with us:
ADEC Innovations; Amfori; consulting 1x1 GmbH; Google; Mailchimp; matomo

Analytics; Concord; Copper; Poll Everywhere; SmartSheet; Stripe; Survey Monkey;
Van Tunen & Partners; webflow; WeTransfer; Zoom; 6Connex.
In this context we may transfer your personal data to IT infrastructure located in the
United States of America. The transfer is covered by adequacy decision (EU)
2016/1250 as of 12th July 2016. ZDHC’s partners processing the personal data
complies to the Privacy Shield Agreement.
9. What Are Your Rights?

You have the right to request:
1. Access to the personal data we hold about you, free of charge.
2. The correction of your personal data when incorrect, out of date or incomplete. For
example, when you withdraw consent, or object and we have no legitimate
overriding interest, or the purpose for which we hold the data has come to an end
(such as the end of an event).
3. That we stop using your personal data for direct marketing (either through specific
channels, or all channels).
4. That we stop any consent-based processing of your personal data after you
withdraw that consent. Whenever you have given us your consent to use your
personal data, you have the right to change your mind at any time and withdraw
that consent.
5. Review by a ZDHC Group staff member of any decision made based solely on
automatic processing of your data (i.e. where no human has yet reviewed the
outcome and criteria for the decision).
6. In cases where we are processing your personal data on the basis of our legitimate
interest, you can ask us to stop for reasons connected to your individual
14

situation.We must then do so unless we believe we have a legitimate overriding
reason to continue processing your personal data.
You always have the right to request a copy of any information about you that ZDHC
Group holds at any time, and to have that information corrected if it is inaccurate.
To ask for your information or request it to be amended, please email media@zdhc.org,

or update the setting in your online account.
If we choose not to action your request we will explain to you the reasons for our refusal.
You have the right to stop the use of your personal data for direct marketing activity
through all channels, or selected channels. We must always comply with your request.
To protect the confidentiality of your information, we will ask you to verify your identity
before proceeding with any request you make pursuant to this Privacy Notice. If you
have authorised a third party to submit a request on your behalf, we will ask them to
prove they have your permission to act.
10. How Can You Stop The Use Of Your Personal Data For Direct
Communications?
There are several ways you can stop receiving direct communications e.g. our
newsletters from us:
• Click the ‘unsubscribe’ link in any email communication that we send you. We
will then stop any further emails from us.
• Please note that you may continue to receive communications for a short period
after changing your preferences while our systems are fully updated.
11. Contacting the Regulator

Finally, if you feel that your personal data has not been handled correctly by ZDHC
Group, or you are unhappy with our response to any requests you have made to us
regarding the use of your personal data, you have the right to lodge a complaint with
the Dutch Data Protection Authority (Dutch DPA):
15

Postal address
Autoriteit Persoonsgegevens
Postbus 93374
2509 AJ DEN HAAG
Telephone number: (+31) (0)70 888 85 00

Fax: (+31) (0)70 888 85 01
If you are based outside the Netherlands, you have the right to lodge your complaint
with the relevant data protection regulator in your country of residence.
12. Further queries?

We hope this Privacy Notice has been helpful in setting out the way we handle your
personal data and your rights to control it.
Email us at media@zdhc.org
Or write to us at ZDHC Foundation, Watersteeg 3, 1012 NV, Amsterdam, The
Netherlands
16

Annex 2 – Fees and Services
1. Annual Subscription and Product Fee
(The pricing table below is effective since January 2022 but it is subject to changes)
Annual Access and Annual Product Fees are applicable to Formulators.
Subscription
Trial Pro Enterprise
Package
Conditions
Term 30 business days 1 year 1year
Tailor-made offer –
Access Fee 0 EUR (€) See Table 2 please contact
ZDHC
21 EUR (€) for

Registered
Products and
Level 1 MRSL Tailor-made offer –
Product Fee 0 EUR (€) Conformant please contact
Products and 0 ZDHC
EUR (€) for Level
2 and Level 3
MRSL Conformant
Products
Table 1
Number of Total Products Annual Access Fee (EUR)

to Publish (€)
0 - 49 1.100
50 -149 1.600
150 - 499 2.100
500 - 1499 2.700
1500 - 3000 3.800
>3001 6.000
Table 2
Special Offers are provided to ZDHC Contributors and may be provided to ZDHC
Associate Contributors.
1

2. Annual Reporting Fee
For the wastewater data upload an ‘Annual Reporting Fee’ of 225 EUR (€) is
charged. The Supplier is legally liable for this fee and can allow a ZDHC Accepted
Laboratory that has a contractual/commercial relationship with, to alternatively pay for
this fee.
This fee is:

● paid for each Supplier (manufacturing facility) before the Supplier or the ZDHC
Accepted Laboratory (provisional) start submitting the test data in the ZDHC
Gateway
● valid for one year commencing on the date of the payment of the Annual
Reporting Fee.
● includes an unlimited number of data submissions within one year, including
historic data1 as long as wastewater testing is done based on the ZDHC
Wastewater Guidelines.
In any given year where the annual reporting fee for a Supplier (manufacturing
facility) has been paid, for example by a different ZDHC Accepted Laboratory and it is
still within the validity period of one year the new laboratory does not need to pay that
fee again.
2

Annex 3 – Data Disclosure Schema
1. Personal and Organisational Data Disclosure
The terms Personal and Organisational Data are introduced in Annex 1 – Privacy
Policy.
1

2. Operational Data Disclosure ZDHC Gateway
2.1. ZDHC Gateway – Chemical Module
The term Operational data is introduced in Annex 1 – Privacy Policy.
2.2. ZDHC Performance InCheck
The term Operational data is introduced in Annex 1 – Privacy Policy
2

2.3. ZDHC Gateway – Wastewater Module
The term Operational data is introduced in Annex 1 – Privacy Policy.
3

Upload of Unverified Wastewater Reports by Suppliers (Green)
Any of the organizations Supplier Admin (#1) logs into Gateway. The system
checks to see if the Supplier Admin has accepted Terms and Conditions (T&C)
4.0 (#2).
4

If the Supplier Admin has not accepted (#3) the T&C then the system presents
the T&C. If the Supplier Admin accepts the T&C, (#4) the Supplier Organization
is defined as 'Accepted T&C' (#5) for the entire Supplier Organization, not just
the single Admin.
If the Supplier uploads unverified test reports (#6) and the Supplier Organization
(#5) has accepted the T&C, the unverified test report is publicly displayed on
Detox.live (#8). If the T&C are not accepted the Unverified Data is not displayed
publicly (i.e. on Detox.live) (#9).
Upload of Verified Wastewater Reports by Labs (Orange)
The Lab Admin logs into Gateway (A) and the Lab Admin has already accepted
the T&C 4.0 (B) and uploaded verified test reports with a Status of pending (C).
The Supplier reviews the verified test report (D).
If the Supplier accepts the report (G) and has accepted the T&C 4.0 (#7), the
verified test reports will be publicly displayed on Detox.live (K). If the Supplier
has not accepted the T&C 4.0, the verfied test reports will not be displayed
publicly (i.e. on Detox.live) (L).
If the Supplier declines the report (E) the declined status of the report and
reason for declining will be displayed on Gateway (F).
If the verified test report is for 20 Business days in the pending status, (H) the
system will automatically set the status to Published (I) and the verified test
reports will be displayed on the Gateway (J). If the Supplier has accepted the
T&C 3.0 (#7), the verified test reports will be publicly displayed on Detox.live
(K). If the Supplier has not accepted the T&C 4.0, the verfied test reports will
not be displayed publicly (i.e. on Detox.live) (L).
5

2.4. Connections
A Brand or a Supplier can request a ‘Connection’ via the “Search” function, the
Brands / Suppliers profile or the bookmark function (Brands only). Once the
request is sent, the Brand / Supplier receives an email notification, that the
Brand / Supplier wants to connect. The Brand / Supplier can accept or decline
the request.
If the Brand accepts the request, the Brand can download the Suppliers
Performance InCheck, ClearStream and Wastewater data, and Supplier to
Zero Certificates if available. Both, the Brand and the Supplier can disconnect
the ‘Connection’ and disable the function. Once the function is disabled the
Brand / Supplier receives a notification. After the ‘Connection’ is made the
Brand and only the Brand has the possibility to publish the ‘Connection’ to
public, on Detox.live. This ‘Connection’ is then visible to the public. Brand and
Supplier can both unpublish the ‘Connection’, but only the Brand can publish
1

or republish the ‘Connection’. A respective notification is sent out to the Brand
/ Supplier.
If a Brand or a Supplier declines the request, the Brand cannot access the
Performance InCheck, ClearStrream and Wastewater data and Supplier to
Zero Certificates of the Supplier and has not the possibility to publish a
‘Connection’ to public, on Detox.live. Once a request is declined a respective
notification is sent out. The Brand / Supplier can resend the request if desired.
2

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ZDHC GATEWAY USER TERMS AND CONDITIONS

Annex 1: ZDHC Privacy Policy

This Information System, known as the ZDHC Gateway, is provided and

Last Update: 01 January 2022

Consent to Processing of Personal Data:

Last Update: 01 January 2022

2.7. Emergency Outage means downtime of the Information System and/or

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3. Use of Information System

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agrees to immediately notify ZDHC of any unauthorised use of User’s or a

4. Data disclosure. As far as the Information System enables Users to disclose or

• Data marked private. Data provided by the User to and/or stored in

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• Disclosure to selected Users. Data provided to and/or generated

6. Breach of Terms and Conditions. Any breach of User’s obligations or

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Conditions, may immediately withhold or terminate User’s access to the

7. Term and Termination.

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8. Fees and Payments.

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10. Maintenance and Support

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10.8. EXCLUSIONS. Notwithstanding any other provisions of these Terms and

11. Intellectual Property Rights/Third Party Rights.

12. Disclaimer. THE INFORMATION SYSTEM IS PROVIDED "AS IS" WITHOUT

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REPRESENTATIONS AND WARRANTIES, EXPRESS, IMPLIED, AND

13. Limitation of Liability.

14. Non-Disclosure. Notwithstanding any other provisions in these Terms and

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16. Additional Provisions.

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About ZDHC Group

1. Types of Information Collected By ZDHC Group

1.1. Personal Information

1.2. Organisational Information

1.3. Operational Information

1.4. Meta Information

2. How Does ZDHC Group Use Information That Is Collected?

In general, all information collected by ZDHC Group aims at and is limited to

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2.1. Personal and Organisational Information

2.2. Operational Information

2.3. Meta Information

• The data provider/subject provides its express consent.

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ZDHC GROUP PRIVACY NOTICE

Version 1.0 May 2020

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Our full contact details are:

Stichting ZDHC Foundation

1. Our Basis for Holding Personal Data

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2. When Do We Collect Your Personal Data?

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Before we get into more detail we want to be clear that we do not:

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Details of your interactions with us through email, face to face, telephone/conference

Details of your visits to our websites or apps by way of an IP address.

Information gathered by the use of cookies in your web browser.