PRIVACY STATEMENT: COMPENSATE BRAND GUIDELINE

Compensate non-profit operations oy (“Compensate” or “we“) provides its Partners with information, instructions and other material via a web portal brand.compensate.com (the website “Services“)  to carry out the cooperation between Compensate and its Partners and to instruct the Partner.

In this Privacy Statement, we explain how we process the data of the users of our Services (hereinafter: “you“). This Privacy Statement may be updated from time to time to reflect the changes in data processing practices or otherwise. You can find the current version on our website. 

You may log into the Services by using the username and password provided from us to you (username and password jointly as the “Portal Account”) You may also use some of the Services without logging in. 

This Privacy Statement applies to the processing of personal data carried out by Compensate as a data controller under the Cooperation Agreement signed by Compensate and its Partners.  Should you have any questions relating to the processing of your personal data, or should you wish to use your rights as a data subject, please contact us on the addressees set out below. General information on how Compensate otherwise processes personal data can also be found here

1. Data controller

Compensate non-profit operations oy

Korkeavuorenkatu 47

00130 Helsinki

Finland

2993434-1

info@compensate.com

compensate.com

Data protection officer

Emmi Simonen

+358 50 439 5999

emmi@compensate.com

2. How we collect data

As a carbon offset services provider, we regularly receive and process various types of personal data in connection with our operations. “Personal data” are data that can be used to identify you or data that can otherwise be linked to you. Relating to the cooperation between the Compensate and your employer and the use of the Services, we mainly collect two types of Personal data: Basic Information and Analytics Data

2.1 Basic Information

We may process personal information (e.g. name, title, e-mail address, telephone number, your employer, hereinafter jointly: the “Basic Information”).

The main subject of the processing is Basic Information which we have received from you or your employer directly as a result of contact between us. Basic Information is also collected from public sources, such as the Parties’ websites. 

2.2 Analytics Data

The logging systems used by our Services automatically log certain Analytics Data when you visit or interact with our Services. Although we do not normally use Analytics Data to identify you as an individual, you can sometimes be recognized from it, either alone or when combined or linked with the other Personal Data we have collected from you as described in the Cooperation Agreement or on our website compensate.com. In such situations, Analytics Data can also be considered personal data under applicable laws and we will treat such data as personal data.

We may automatically collect the following Analytics Data when a Registered visit or interact with the Services.

Device Information

We collect the following information relating to the technical device you use when using the Services:

  • device and device identification number, device IMEI
  • country;
  • IP address;
  • browser type and version;
  • language of the browser
  • operating system;
  • name of your Internet service providers, and
  • advertising identifier of your device.

Usage Information

We collect information on use of the Services, such as:

  • time spent on the Services,
  • interaction with the Services,
  • your geographic location; and
  • the time and date of your visits to Services.

Cookies

We use various technologies to collect and store Analytics Data and other information when you visit the Services, including cookies, pixel tags, and web beacons. Cookies are small text files sent and saved on your device that allow us to identify visitors of our Services and facilitate the use of the Services and to create aggregate information of our visitors. This helps us to improve the Services and better serve you. The cookies will not harm your device or files. We use cookies to tailor the Services and the information we provide in accordance with your individual interests. 

You may choose to set your web browser to refuse cookies, or to alert when cookies are being sent. For example, the following links provide information on how to adjust the cookie settings on some popular browsers: Safari, Google Chrome, Internet Explorer, Mozilla Firefox.

Please note that some parts of the Services may not function properly if the use of cookies is refused. 

Web analytics services

The Services use Google Analytics and other web analytics services to compile Analytics Data and reports on visitor usage and to help us improve the Services. For an overview of Google Analytics, please visit Google Analytics. It is possible to opt-out of Google Analytics with the following browser add-on tool: Google Analytics opt-out add-on. Please take a look at how Google is processing the data of its partners on its website and applications and visit: www.google.com/policies/privacy/partners/

Personal Data Provided Us by Third Party Service Providers

If you connect or login to your user account with Facebook or Google, Facebook or Google shares with us personal information about you such as your Facebook/Google ID.

3. How we use your data 

We use the personal data we collect for several purposes:

To provide you the Services and to carry out our contractual obligations

Compensate processes your personal data to be able to provide the Services to you under the contract between you or the Company you represent and Compensate. If you contact our customer service, we will use the information provided by you to answer your questions or solve your complaint. 

For customer communication and marketing

Compensate processes your personal data to contact you regarding the Services and to inform you of changes relating to them. Your personal data are also used for the purposes of marketing the Services and our other relevant products and services to you.

For quality improvement and trend analysis 

We may also process information about your use of the Services to improve their quality e.g. by analyzing any trends in their use. In order to ensure that the Services are in line with your needs, personal data can be used for things like customer satisfaction surveys. When possible, we will do this using only aggregated, non-personally identifiable data.

For our legal obligations

Compensate processes data to enable us to administer and fulfill our obligations under the law. This includes data processed for complying with our bookkeeping obligations and providing information to relevant authorities such as tax authorities.

For claims handling and legal processes

Compensate may process personal data in relation to claims handling, debt collection, and legal processes. We may also process data for the prevention of fraud, misuse of our services and data, system and network security.

4. Legal grounds for the processing

Compensate processes your personal data primarily in order to fulfill our contractual obligations to you as well as to pursue our legitimate interest to run, maintain and develop our operations and to create and maintain customer and other business relationships. When choosing to use your data on the basis of our legitimate interests, we weigh our own interests against your right to privacy and e.g. provide you with easy to use opt-out from our marketing communications and use pseudonymized or non-personally identifiable data when possible.

We may also process your personal data in order to comply with our legal obligations. 

In some parts of the Services, you may be requested to grant your consent for the processing of personal data. In this event, you may withdraw your consent at any time.

5. How we may share your personal data

We only share your personal data within our organization if and as far as reasonably necessary for the purposes of this Privacy Statement.

We do not share your personal data with third parties outside of our organization unless one of the following circumstances applies:

For the purposes set out in this Privacy Statement and to authorized service providers 

To the extent that third parties need access to the Personal Data for us to provide the Services, we provide such third parties with your data. Furthermore, we may provide your personal data to our affiliates or to authorized service providers who perform services for us (including, for instance, data storage, accounting, payment, sales, and marketing service providers).

When your personal data is processed by third parties as data processors on behalf of Compensate, Compensate has taken the appropriate contractual and organizational measures to ensure that your data are processed exclusively for the purposes specified in this Privacy Statement and in accordance with all applicable laws and regulations and subject to our instructions and appropriate obligations of confidentiality and security measures.

Please bear in mind that if you provide personal data directly to a third party, such as through a link somewhere on our website, the processing is typically based on their policies and standards.

For legal reasons and legal processes

We may share your personal data with third parties outside our organization if we have a good-faith belief that access to and use of the personal data is reasonably necessary to: (i) meet any applicable law, regulation, and/or court order; (ii) detect, prevent, or otherwise address fraud, crime, security or technical issues; and/or (iii) protect the interests, properties or safety of Compensate, the users of the Services or the public as far as in accordance with the law. When possible, we will inform you about such processing.

For other legitimate reasons

If Compensate is involved in a merger, acquisition or asset sale, we may transfer your personal data to the third party involved. However, we will continue to ensure the confidentiality of all personal data. We will give notice to all the users of the Services concerned when the personal data are transferred or become subject to a different privacy statement. 

With your explicit consent 

We may share your personal data with third parties outside Compensate when we have your explicit consent to do so. You have the right to withdraw this consent at all times. 

6. Transfers to countries outside the European Economic Area (EEA)

We use service providers in several geographical locations. As such, we and our service providers may transfer your personal data to, or access it in, jurisdictions outside the EEA or your domicile. 

We will take steps to ensure that your personal data receives an adequate level of protection in the jurisdictions in which they are processed. We provide adequate protection for the transfers of personal data to countries outside of the EEA through a series of agreements with our service providers based on the Standard Contractual Clauses or through other appropriate safeguards, such as the Privacy Shield Framework

More information regarding the transfers of personal data may be obtained by contacting us on any of the addresses indicated above. 

7. How long we will store your data

Compensate does not store your personal data longer than is legally permitted and necessary for the purposes of this Privacy Statement. The storage period depends on the nature of the information and the purposes of the processing. The maximum period may, therefore, vary per use. When the processing of your personal data is no longer necessary for the purposes they were collected, we will delete or anonymize the personal data relating to you in a secure manner. 

Basic Information shall be processed no longer than 36 months from the due date of the last invoice provided by the Partner after the expiration or termination of this Agreement. Analytics Data will be processed no longer than 26 months from each visit on the Web Portal. If, in some exceptional cases, the personal data is stored for longer than twenty-six (26) months for the purposes outlined in this Privacy Statement we provide adequate protection for that data through anonymization or other appropriate safeguards.

8. Your rights

Right to access

You have the right to access and be informed about your personal data processed by us. We give all of you the possibility to request a copy of their personal data.

Right to withdraw consent

In case the processing is based on the consent granted by you, you may withdraw the consent at any time. Withdrawing consent may lead to fewer possibilities to use the Services. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

Right to rectify

You have the right to have incorrect or incomplete personal data we have stored about you corrected or completed by contacting us. 

Right to erasure

You may also ask us to delete your personal data from our systems. We will comply with such a request unless we have a legitimate ground to not delete the data. 

Right to object

You may have the right to object to certain use of your data if such data are processed for other purposes than necessary for the provision of the Services or compliance with a legal obligation. If you object to the further processing of your personal data, this may lead to fewer possibilities to use the Services.

Right to restriction of processing

You may request us to restrict the processing of personal data for example when your data erasure, rectification or objection requests are pending and/or when we do not have legitimate grounds to process your data. This may, however, lead to fewer possibilities to use the Services.

Right to data portability

You have the right to receive the personal data you have provided to us yourself in a structured and commonly used format and to independently transmit those data to a third party.

How to use your rights

The abovementioned rights may be used by sending a letter or an e-mail to us on the addresses set out above, including the following information: full name, address, e-mail address, and phone number. We may request the provision of additional information necessary to confirm your identity. We may reject requests that are unreasonably repetitive, excessive or manifestly unfounded. 

In case you consider our processing of personal data to be inconsistent with the applicable data protection laws, a complaint may be lodged with the local supervisory authority for data protection. In Finland, the local supervisory authority is the Data Protection Ombudsman (www.tietosuoja.fi).

9. Direct marketing

You have the right to prohibit us from using your personal data for direct marketing purposes, market research and profiling made for direct marketing purposes by contacting us on the addresses indicated above or by using the unsubscribe possibility offered in connection with any direct marketing messages.

10. Information security

We use administrative, organizational, technical, and physical safeguards to protect the personal data we collect and process. Measures include for example, where appropriate, encryption, pseudonymization, firewalls, secure facilities, and access right systems. Our security controls are designed to maintain an appropriate level of data confidentiality, integrity, availability, resilience and ability to restore the data. We regularly test the Services, systems, and other assets for security vulnerabilities.

Should despite the security measures, a security breach occurs that is likely to have negative effects on your privacy, we will inform you and other affected parties, as well as relevant authorities when required by applicable data protection laws, about the breach as soon as possible.

Updated 6.2.2020