PRIVACY POLICY

Data Privacy Policy

Effective Date: March 10, 2021

Thank you for being part of the Greenr community!

We are committed to respecting and protecting your privacy. This Data Privacy Policy informs you about how we collect, use, disclose, manage and protect any Personal Data you provide to us when accessing or using our Website, the Greenr App, or otherwise, what we do with it and how you can control what Personal Data we collect from you. Please read it carefully.

A. Table of Contents

Section Heading Summary
1. Definitions Basic definitions which will enable you to understand this Data Privacy Policy.
2. Who We Are and How to Contact our Privacy Manager Greenr Technologies Limited is a private company registered in England and Wales. We do not meet the criteria for a mandatory appointment of a Data Protection Officer under the UK General Data Protection Regulation but we have allocated informal responsibility to a person in our business who can deal with any data protection related matters. You can contact our Privacy Manager at dataprivacy@greenr.com .
3. Our role as Data Controller When we use Personal Data about you or others in connection with promoting and administering our business, providing the Service, or recruitment, we do so as data controller.
4. Applicable Terms and Consent By accessing or using the Service, you accept and agree that you will comply with this Data Privacy Policy.
5. Age of Consent and Third Party Services While we welcome users of all ages, in order to use the Service, you must be at least the age of majority in the area in which you reside. We may allow you to log in to the Greenr App through various online third-party services such as Google. We assume no responsibility for the privacy practice of such third parties.
6. Personal Data we collect This section sets out the type of Personal Data we collect, such as contact data and technical data which is automatically collected with the help of cookies.
7. How we collect your Personal Data There are different ways that we can obtain your Personal Data. You could give it to us, for example by creating a User account or you could give permission to us to obtain it for example if you choose to share your precise location using your device settings or through photos. When you use our Website or the Greenr App, certain internet and electronic network activity information also gets created and logged automatically.
8. How we use your Personal Data We use your Personal Data to improve your experience using our Service.
9. How we make sure your Personal Data is secured We organize ourselves in such a way that your Personal Data is not inappropriately disclosed. Although we take technical measures to avoid data breaches, no transmission over the internet or electronic storage is 100% secure.
10. Retaining Personal Data We will only keep your Personal Data for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.
11. Your Rights You may have a number of rights in relation to your Personal Data such as the right to request access to your Personal Data, to have it corrected or deleted, to object to us processing it or to withdraw consent at any time.
12. Sharing of Personal Data with Third Parties We may share your Personal Data with third parties to whom we have outsourced certain tasks, such as IT, business administration or marketing and analytics services. When we do so, we make sure that such third party respects the security of your Personal Data and treats it in accordance with the law.
13. International Transfers For data transfers taking place outside of the UK, we make sure that a similar degree of protection is afforded to your Personal Data as if it were still in the UK.
14. Cookies and other Web technologies We use cookies to ensure that you enjoy your visit to our Website, for example, to remember your preferences or to enable you to log into your account more easily. You can block these cookies and similar technologies by changing your browser setting. However, in relation to those that are essential for the operation or improve the functionality of the Website, this may impact your use of the Website.

B. Policy Terms

  1. Definitions
    1. “Community Areas” means discussion forums, blogs, or other interactive areas or social features that allow you and other users to post User Content and interact with one another.
    2. “Comply with a legal obligation” means processing your Personal Data where it is necessary for compliance with a legal obligation that we are subject to.
    3. Data Protection Laws” means the UK General Data Protection Regulation and the Data Protection Act 2018.
    4. Greenr”, “We”, and “Us” means Greenr Technologies Ltd., a company registered in England and Wales with company registration number 12513017 and registered office at 41&43 Maddox Street,  Mayfair, London,   W1S 2PD.
    5. Greenr App” means the mobile application developed by Greenr for Users to track their carbon footprint, gain Greenr Points, and purchase Carbon Offsets.
    6. “Legitimate Interest” means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
    7. “Performance of Contract” means processing your Personal Data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
    8. Personal Data” means collectively all information that you submit to Greenr and incorporates where applicable the definitions provided in the Data Protection Laws.
    9. Service” means the Website and the Greenr App, and all other current and future digital products and services available through the Website and the Greenr App, including any products, services, and content provided in collaboration with our partners.
    10. Stripe” means [Stripe Payments UK] having its registered office at 9th Floor, 107 Cheapside, London, EC2V 6DN, our payment partner.
    11. User”, “You”, and “Your” refers to the individual person that has visited or is using the Website, Greenr App, or Services.
    12. User Content” means any Content that a user submits, transfers, or otherwise provides to or through the use of the Services.
    13. Website” means our website located at greenr.com and any Greenr-owned subdomains of greenr.com. unless expressly excluded by their own terms and conditions.
    14. Unless defined otherwise, all definitions included in our Terms and Conditions will apply to this Data Privacy Policy.
  2. Who We Are and How to Contact our Privacy Manager
    1. The Website and the Greenr App are owned and operated by Greenr Technologies Limited, a private company registered in England and Wales, with company registration number 12513017  and whose registered office is at 41 & 43 Maddox Street, Mayfair, London W1S 2PD.
    2. We do not meet the criteria for a mandatory appointment of a Data Protection Officer under the UK General Data Protection Regulation but we have allocated informal responsibility to a person in our business who can deal with any data protection related matters. If you have any questions regarding this Data Privacy Policy or our privacy practices, please feel free to contact our Privacy Manager at  dataprivacy@greenr.com .
  3. Our role as Data Controller 
    1. For purposes of the applicable Data Protection Laws, Greenr is the “data controller”. This means that Greenr determines the purposes for which, and the manner in which, your Personal Data is processed.
  4. Applicable Terms and Consent
    1. When you access or use the Service, or otherwise provide any Personal Data to us, you agree to this Data Privacy Policy, including the manner in which we use your Personal Data. If you do not agree to this Data Privacy Policy, or to any changes we subsequently make to this Data Privacy Policy, you must immediately stop using the Service or otherwise providing any information to us.
    2. Further, we reserve the right to change, at our sole discretion, the terms of this Data Privacy Policy at any time by publishing the varied terms on the Website, with or without notice.
    3. You are responsible for reviewing regularly information posted online to obtain timely notice of such changes. As such, we recommend that you check the Website regularly to ensure you are aware of our current terms. We do not undertake to keep our Website up-to-date and we are not liable if any content is inaccurate or out-of-date. Your continued use of the Services after changes are posted constitutes your acceptance of the Data Privacy Policy as modified by the posted changes.
  5. Age of Consent and Third Party Services
    1. Greenr welcomes users of all ages, but to use the Greenr App, you must be at least the age of majority in the jurisdiction where you reside. No individual under these age limits may use the Services, provide any Personal Data to us, or otherwise submit Personal Data.
    2. By using the Service, you represent that you are at least the age of majority in your country of residence and lawfully able to enter into and form contracts on the internet in accordance with such laws.
    3. You may need to create a Greenr account to access and use the Greenr App and in doing so, you must provide us with accurate and complete information as prompted by the registration process.
    4. We may allow you to log in to the Greenr App through various online third-party services, such as social media and social networking services like Google or Twitter (“Third Party Services”). In order to use these features and capabilities, we may ask you to authenticate, register for, or log into Third Party Services on the websites of their respective providers.
    5. Third Party Services use, store, and disclose your information solely in accordance with their own policies. We assume no responsibility or liability for the privacy practices or any other actions of any third-party website or service that may be enabled within the Services or of which a link is included on the Website. Further, we assume no responsibility or liability for any damage or loss caused or alleged to be caused by or in connection with the use of or reliance on any such Third Party Services.
  6. Personal Data we collect
    1. We may collect different kinds of Personal Data about you when you interact with us, including via the Website, the Greenr App, social media, email, telephone, post or in person. We have grouped this information together as follows:
      • Identity Data includes name
      • Contact Data includes address, email address, and telephone numbers
      • Financial Data includes bank account and payment card details (managed through Stripe)
      • Transaction Data includes details of products and services you have purchased from us
      • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website
      • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses
      • Usage Data includes information about how you use our Website and Service
      • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences
    2. We also get information about you and your activity outside Greenr from our affiliates, advertisers, partners and other third parties we work with. For example, online advertisers or third parties share information with us to measure, report on or improve the performance of ads, or to figure out what kinds of ads to show you.
    3. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Data Privacy Policy.
    4. We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
  7. How we collect your Personal Data
    1. We collect Personal Data through one or more of the following ways:
      • when you sign up to have early access to our beta app
      • when you contact us through the Website form, by telephone, post, email, or through any other means
      • when you create an account on the Greenr App
      • when any User Content you post in the Community Areas would contain any Personal Data
      • referring websites or third parties, including social media sites
      • when you enter a competition or promotion through a social media channel
      • when you elect to receive marketing communications from us
      • when you answer to onboarding quiz
      • the maintenance and analysis of Website server logs; and
      • “cookies” (small text files placed by us on your computer(s)), single pixel GIF image files, Website server log analysis and other similar technological means.
    2. We collect information about your location based on:
      • derivations made from the IP address from which you connect; and
      • if you consent (by accepting on your mobile operating system), the Global Positioning System (GPS) of your device when the Greenr App is running in the foreground (together, “Location Information”).
    3. If you do not wish to share your GPS location with us, you can switch off GPS functionality on your mobile device. If you otherwise wish to withdraw you consent to us using cell ID data and GPS data, email us at dataprivacy@greenr.com
  8. How we use your Personal Data 
    1. We will only use your Personal Data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
      • Where we need to perform the contract we are about to enter into or have entered into with you
      • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
      • Where we need to comply with a legal obligation
    2. Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
    3. We have set out below, in a table format, a description of all the ways we plan to use your Personal Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
    4. Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Data where more than one ground has been set out in the table below.
      Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
      To register you as a User and create your Greenr account (a) Identity
      (b) Contact
      Performance of a contract with you
      To help your friends and contacts find you on Greenr (a) Identity
      (b) Contact
      Necessary for our legitimate interests (to build your own Greenr community)
      To process your Carbon Offset orders (a) Identity
      (b) Contact
      (c) Financial
      (d) Transaction
      (e) Marketing and Communications
      (a) Performance of a contract with you
      (b) Necessary for our legitimate interests (to recover debts due to us)
      To manage our relationship with you which will include:
      (a) Notifying you about changes to our Terms and Conditions or Data Privacy Policy
      (b) Asking you to leave a review or take a survey
      (a) Identity
      (b) Contact
      (c) Profile
      (d) Marketing and Communications
      (a) Performance of a contract with you
      (b) Necessary to comply with a legal obligation
      (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
      To review User Content in the Community Areas to detest activity that poses a risk to the safety of you, our Greenr community and/or members of the public (a) Identity
      (b) Contact
      Necessary for our legitimate interests
      To enable you to partake in a prize draw, competition or complete a survey (a) Identity
      (b) Contact
      (c) Profile
      (d) Usage
      (e) Marketing and Communications
      (a) Performance of a contract with you
      (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
      To administer and protect our business and the Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
      (b) Contact
      (c) Technical
      (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
      (b) Necessary to comply with a legal obligation
      To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity
      (b) Contact
      (c) Profile
      (d) Usage
      (e) Marketing and Communications
      (f) Technical
      Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
      To use data analytics to improve our Service, products/services, marketing, customer relationships and experiences (a) Technical
      (b) Usage
      Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy)
      To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity
      (b) Contact
      (c) Technical
      (d) Usage
      (e) Profile
      (f) Marketing and Communications
      Necessary for our legitimate interests (to develop our products/services and grow our business)
  9. How we make sure your Personal Data is secured
    1. To protect your Personal Data, we take reasonable precautions to try to ensure that it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed.

    2. We implement and maintain appropriate technical, security and organisational measures in relation to the processing of your Personal Data so that the processing will meet the requirements of applicable Data Protection Laws and ensure the protection of your rights.

    3. Storage of payment details and processing of payments for Carbon Offset is managed through Stripe, a third party payment services provider. You must agree to the Stripe terms of service to make purchases. We assume no responsibility or liability for the privacy practices or any other actions of Stripe.
  10. Retaining Personal Data
    1. We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

    2. To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
  11. Your Rights
    1. Under certain circumstances, you have rights under applicable Data Protection Laws in relation to your Personal Data. Please click on the links below to find out more about these rights:

      • Right to request access to your Personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.

      • Right to request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

      • Right to request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
      • Right to object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
      • Right to request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios:
        1. If you want us to establish the data’s accuracy.
        2. Where our use of the data is unlawful but you do not want us to erase it.
        3. Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
        4. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
      • Right to request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
      • Right to withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
    2. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Personal Data (where consent is our legal basis for processing your Personal Data), please contact us via this e-mail address: dataprivacy@greenr.com
    3. You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
    4. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
    5. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.
    6. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
    7. It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during the period for which we hold it.
  12. Sharing of Personal Data with Third Parties
    1. We may share your Personal Data with any of our affiliates to ensure the proper administration of our Website and business and with our insurers, our professional advisors (lawyers, bankers, auditors, corporate financiers and brokers) in connection with services they provide to us.
    2. We share Personal Data with the following third parties for advertising and analytics purposes.
    3. We may also share data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Data in the same way as set out in this Data Privacy Policy.
    4. We require all third parties to respect the security of Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.
    5. We will not otherwise share personal information with any third party except where we are permitted to under data protection laws or required to by law.
  13. International Transfers
    1. The General Data Protection Regulation no longer applies to us and any transfers of Personal Data outside the UK that we make will be made in compliance with the UK General Data Protection Regulation.
    2. For data transfers taking place outside of the UK, we ensure that a similar degree of protection is afforded to it, either by making our own assessment of adequacy, or using one of the standard mechanisms available to us. These may include:
      • Transfers to the EEA because these have been confirmed by the Information Commissioner’s Office as being adequate.
      • Transfer to countries or organisations that have officially been deemed to provide an adequate level of protection for Personal Data by the Information Commissioner’s Office (which for the moment is the same list as the European Commission list referred to above).
      • Using specific contracts approved by the Information Commissioner’s Office (which for the moment is to continue to use the Standard Contractual Clauses).
    3. If you are transferring Personal Data to us from the EEA, in the absence of an adequacy ruling for the United Kingdom, the arrangements agreed between the UK and EU in the UK-EU Trade and Cooperation Agreement shall apply to legitimise the transfer. These arrangements are stated to last for no more than six months and are to allow time for the UK to be granted adequacy.
  14. Cookies and other Web technologies
    1. The types of cookies and similar technologies used by us and our partners in connection with the Website can be classified into one of five categories, namely ‘essential Website cookies’, ‘functionality cookies’, ‘analytics and performance cookies’, ‘advertising cookies’, and ‘social media cookies’. Cookies do a lot of different tasks to ensure you enjoy your visit to our Website, for example, they are used to remember your preferences on our Website, to help you navigate between pages more efficiently, to enable you to log into your account more easily and to make sure the adverts you see on our Website are relevant to you and your interests. We have set out some further information about each category, and the purposes of the cookies we and third parties set in the following table.
    2. You can block these cookies and similar technologies by changing your browser setting. However, in relation to those that are essential for the operation or improve the functionality of the Website, this may impact your use of the Website.
      Type of cookie What it does
      Cookies necessary for essential Website purposes These cookies are essential to provide you with the Website and any services available through the Website and to use some of its features, such as access to secure areas. Without these cookies, services you have asked for, like transactional pages and secure login accounts, would not be possible.
      Functionality Cookies Functionality cookies record information about choices you’ve made and allow us to tailor the Website to you. These cookies mean that when you continue to use or come back to the Website, we can provide you with our services as you have asked for them to be provided.
      These cookies allow us to:

      • Save your location preference if you have set your location on your homepage, if applicable, in order to receive a local weather forecast;
      • Remember settings you have applied, such as layout, text size, preferences, and colors; and
      • Store accessibility options.
      Performance Cookies We use performance/analytics cookies to analyze how the Website is accessed, used, or is performing in order to provide you with a better user experience and to maintain, operate and continually improve the Website.
      We use Google Analytics, which is a web analytics tool that helps us understand how users engage with the Website. Like many services, Google Analytics uses first-party cookies to track user interactions, as in our case, where they are used to collect information about how users use our site. This information is used to compile reports and to help us improve our Website. The reports disclose website trends without identifying individual visitors. For more information on Google Analytics, see here. You can opt out of Google Analytics without affecting how you visit our site – for more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page: https://tools.google.com/dlpage/gaoptout.
      These cookies allow us to:

      • Better understand our Website visitors so that we can improve how we present our content;
      • Test different design ideas for particular pages, such as our homepage;
      • Collect information about Website visitors such as where they are located and what browsers they are using;
      • Determine the number of unique users of the Website;
      • Improve the Website by measuring any errors that occur; and
      • Conduct research and diagnostics to improve product offerings.
      Social Media Cookies On some pages of our Website, third parties that provide applications through our Website will set their own cookies in order to track the success of their applications or customize applications for you. Because of how cookies work, we cannot access these cookies, nor can the third parties access the data in cookies used by us.
      These cookies are used when you share an article using a social media sharing button on our Website (e.g., Facebook, Twitter, or Google Plus) as the social network that has created the button will record that you have done this. If you are logged in to your account with the third party, the third party will be able to link information about you with your actions via cookies.
    3. You can choose to enable or disable cookies in your internet browser. By default, most internet browsers accept cookies but this can be changed. For further details, please consult the help menu in your internet browser.
    4. You can choose to delete cookies at any time; however, you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.
    5. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.
    6. For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer