Applicable until 6.7.2020

GENERAL PRIVACY STATEMENT

Compensate Operations Oy ("Compensate" or "we") provides a carbon footprint test and carbon-offset services available through compensate.com (the website and the services jointly "Services") for calculating and compensating for your carbon footprint.

In this Privacy Statement, we explain how we process the data of the users of our Services, our partners, our potential clients, and other business contacts (hereinafter: "you"). We may also use your personal data when you are applying for a certain position at Compensate, when subscribing to our Newsletter, when giving us your contact details for business purposes, or when you use our Carbon Footprint Calculator. We will process this information as set out in our Recruitment Privacy Statement, Privacy Statement for Newsletter, Initial Partnership Form Privacy Statement, and Privacy Statement for Carbon Footprint test. Some of our Services are available only for Users that are at least 13 years old or otherwise able to agree to these Terms.

You may register to the Services by providing us with your name, email address and other relevant information as instructed on the Services. You may also use some of the Services as an unregistered User.

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. 

This Privacy Statement applies to the processing of personal data carried out by Compensate as a data controller. 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.

1 Data controller

Compensate Operations Oy

Korkeavuorenkatu 47

00130 Helsinki

Finland

2993434-1

info@compensate.com

compensate.com

Data protection officer

Emmi Simonen

legal@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.

We mainly process personal data we obtain from you directly, for example when registering to our Services or when you send us emails or communicate with us through other channels. Where applicable, we also process your personal data obtained from publicly available sources, such as your employer's website, and personal data that accumulates from your use of our website.

We mainly process the following types of your personal data: User Data and Analytics Data.

2.1 User data

User Data are personal data collected directly from you or generated by our Services or us based on your use of the Services. We may collect User Data from our Users in a variety of ways, including, when they register to and use the Services, subscribe to a newsletter, apply for a job or answer our surveys. We mainly process the following User Data relating to the Users:

  • basic information, such as your name, your contact information (email, address, phone number(s)), your employer, your title or position, your place of residence, age);

  • password and credit card information;

  • marketing opt-ins and opt-outs;

  • data you have entered into the Services, such as your consumer habits or the data related to your Company's or Organisation's operations;

  • data generated by the Services, such as the carbon footprint based on your consumer habits;

  • data relating to your use of the Services, such as payments made by you;

  • data you provide us by phone or in email correspondence with us, and

  • any additional data you provide us by the Services.

2.2 Analytics Data

The logging systems used by our Services automatically log certain Analytics Data when you visit 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 User Data. 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 you 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;

  • operating system;

  • name of your Internet service providers, and

  • advertising identifier of your device.

Usage Information

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

  • time spent on the Services;

  • interaction with the Services, and

  • the time and date of your visits to the 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. 

If you wish to revoke your consent for us to use non-essential cookies, you may do so here. The only non-essential cookie we use is Google Analytics, which collects information about how you use our Services. We may share the information with Google. For more information please see below.

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

Personal Data Provided Us by Third Party Service Providers

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

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 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 User Data for us to provide the Services, we provide such third parties with your data. Such third parties include our payment service provider Stripe, that processes certain personal data collected by it as a controller in accordance with its privacy policy (https://stripe.com/en-FI/privacy). 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 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 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 anonymise the personal data relating to you in a secure manner. 

Most personal data relating to a registered User's user account will be deleted after a period of 90 days has elapsed after the registered User has requested us to delete one’s user account with the Services. Thereafter, some of the personal data may be stored by us only as long as such processing is required by law or is reasonably necessary for our legal obligations or legitimate interests such as claims handling, bookkeeping, internal reporting and reconciliation purposes. All personal data relating to a User's user account with the Services will be anonymized or deleted within a period of ten (10) years after the User has requested us to delete one’s its User account with the Services, except for personal data required in certain rare situations such as legal proceedings.

We will store Analytics Data of our Users and personal data provided by third-party service provides for a period of twenty-six (26) months from each visit on our Services. If, in some exceptional cases, the Analytics 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 registered Users the possibility to view certain User Data through their user account on the Services. 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. Registered Users can correct or update some of their User Data through their user account on the Services. 

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 16.12.2019