PRIVACY STATEMENT: Newsletter and Events

Compensate Operations Oy ("Compensate" or "we") provides carbon offset services for individuals, companies and other organizations by calculating and offering a platform to compensate for their carbon footprint. 

In this Privacy Statement, we explain how we process the personal data of the subscribers of the newsletter ("Newsletter") and the participants of our events, including webinars (“Events”). The logging systems used by our website (compensate.com) log certain Analytics Data when you visit the website. Some of them are provided by third party service providers. We will process this information as set out in our general Privacy Statement.

"Subscriber" or "you" refers to the subscriber of the Newsletter and participants of  the Events. Please note that our Newsletter and some of our Events are only available for persons over 13 years old or for persons whose legal guardians have allowed them to subscribe to the Newsletter or participate in such an Event. As a Subscriber you ensure that you are at least 13-year-old or otherwise able to agree to these Terms.

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

Business ID: 2993434-1

info@compensate.com

compensate.com

Data protection officer

Emmi Simonen

legal@compensate.com

2. How we collect data

You may subscribe to our Newsletter by providing us with your name and email address as instructed. In addition, you may participate in the Event by telling us your name, your email address and other information relating to your participation, such as allergy information. The personal data collected and processed by us in connection with your use of the Newsletter and your participation in the Event is called Subscriber Data

We may process your name, email address and any other additional data relating to your participation of the Event or subscribing to the Newsletter, such as allergy information. In addition, we may process all other data you provide us by emails or any other correspondence with us. 

3. How we use your data

For customer communication and marketing

Compensate processes your personal data to contact you regarding the Newsletter. Your personal data are also used for the purposes of marketing our carbon offset services and our other relevant products and services to you. 

For quality improvement and trend analysis

We may also process information about your personal data to improve the quality of our carbon offset services e.g. by analyzing any trends. In order to ensure that our carbon offset services are in line with your needs, personal data can be used for things like further 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 to maintain and develop our operations and to create and maintain customer and other business relationships. When choosing to use your data based on 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 process your personal data if you have consented to the processing activity. You may withdraw your consent at any time. Relating to some Subscriber Data, such as allergy information, we only proceed your data based on your explicit consent to processing of those personal data for one or more specified purposes. 

5. How we may share your personal data

We only share your Subscriber 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 Subscriber Data in order 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). In addition, we use Mailchimp in sending the Newsletter to you. Mailchimp processes your personal data in accordance with its privacy policy (https://mailchimp.com/legal/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 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 Subscribers 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 Subscribers concerned when the personal data are transferred or become subject to a different privacy statement. 

For 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 have 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 the Subscriber's 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.

Most personal data relating to a Subscriber will be deleted after a period of 90 days has elapsed after the registered Subscriber has requested the deletion of their Subscriber 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 Subscriber account with the Services will be anonymized or deleted within a period of ten (10) years after the Subscriber has deleted its Subscriber account with the Services, except for personal data required in certain rare situations such as legal proceedings.

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 personal data if such data are processed for other purposes than necessary for the provision of the Services or for 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 a 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 our data protection officer on the addresses indicated above.

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 Newsletter, 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 16.4.2020