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Privacy Statement (EN)

Effective date: 13 October 2021

 

Club Leaf B.V. its affiliates (“Club Leaf”, “we” or “us”) respect your concerns about privacy and value the relationship we have with you. When you make use of the Club Leaf mobile application and website (the “Software”), Club Leaf processes personal data and uses cookies and similar technologies. We aim to carefully and safely use your personal data in line with applicable privacy rules and regulations.

This Privacy Statement describes who we are, what types of personal data we collect about you, how and for which purposes we process your personal data, and how you can exercise your privacy rights. We also describe the measures we take to protect the security of your personal data, how you can contact us about our privacy practices and all other information that may be relevant to you.

We did our best to provide you with all information in a clear and readable format. However, if you have any questions about the use of your personal data after reading this Privacy Statement, you can always contact us through the contact details provided at the bottom of this Privacy Statement.  

For information on how we use cookies and similar technologies, please read the information under the headline “Which cookies and similar tracking technologies do we use?”

Finally, we would like to point out that we are continually developing and improving the Software. If this changes the way we process your personal data, we will inform you through this Privacy Statement. We therefore recommend you to regularly take notice of the Privacy Statement for any modifications.

Who are we?

Club Leaf B.V. are the data controller of the Software and are therefore responsible for processing your personal data within this Software as described in this Privacy Statement. We are registered at Asterdse Sluis 22, 4823GL Breda, the Netherlands. If you want to contact us, please use the contact details provided at the bottom of this Privacy Statement.

 

Which personal data do we process?

 

Personal data received from you

When you choose to create an account with us, we receive several categories of personal data:

 

  • Email address & password

  • Personal identifier (UserID, LoyaltyID, AccountID, ShopperID)

  • Transactions and spend data
    Such as your CO2 footprint; balance of Leaf; transaction date; product type; price of product; number of products; spend amount; number of Leaf to receive.

  • App usage data
    Device transactional data; type of telephone; operational system and version; language settings; data of app installation; data of app registration; data of app visit(s); visit app locations.

  • Push-notification data
    If you choose to receive push-notifications with helpful information, your MarketingID, app usage data and your user behaviour transactional data (such as user registration, user login, whether a payment has been made) will be processed to trigger sending a push-notification to you.

 

Personal data provided to third party service providers

We use Stripe as our payment service provider. By purchasing Leaf through the Software, Stripe may collect the following categories of personal data on our behalf:

 

  • Contact information (such as name, postal address, email address, mobile or other phone number)

  • Payment information (such as your delivery address and billing address)

  • Purchase history

  • Account information (user ID and password)

  • Location information
    Device information provided to us through the type of device you use, which may also include your unique device identifier, IP address, type of device or mobile operating system

  • Biometric information (fingerprint or facial recognition)
    Stripe uses this information to operate and improve the services it provides to us, including for fraud detection. You can learn more about Stripe and its privacy practices here:  https://stripe.com/en-nl/privacy.

  • Personal data we collect by automated means
    When you make use of the Software, for example to calculate your CO2 footprint, we may use analytics tools (e.g. Google Analytics) to collect certain information about your device or usage by automated means, including using technologies such as cookies, web server logs and web beacons. Analytics tools collect data such as how often you visit or use the Software, which pages they visit and how you interact with and use our Software and its various features. For more information, please refer to the heading “Which cookies and similar tracking technologies do we use?” below.

For which purposes do we process your personal data?

We use personal data as necessary for the performance of our Software and provision of our services; to improve and secure our Software; for analytics and sales purposes; to comply with applicable laws and contractual obligations; and to support our legitimate interests in maintaining and improving our Software, for example, to understand how our Software is used and how our campaigns are performing, gaining insights which help us dedicate our resources and efforts more efficiently; providing customer service and technical support; and protecting and securing our users, ourselves and our Software.

Processing personal data to provide the Software and service

We collect and process your personal data to make sure you can use the Software properly, to:

  • enable you to easily calculate your CO2 footprint

  • enable you to purchase Leaf to offset your CO2 footprint within the Software

  • enable you to check your Leaf balance

  • enable you to receive helpful notifications

  • inform you about changes to our services and products

  • respond to your queries and provide (technical) support when necessary

  • perform accounting, auditing and other internal functions

Processing personal data to measure and improve the Software performance

In addition, we use the data in a pseudonymous and aggregated form to understand how we can develop and improve the service and Software, as well as for reporting purposes, statistical and analytical purposes.

 

When using the Software, the Google Analytics 4 services are provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043 (“Google”).

Google Analytics 4 uses tracking mechanisms that allows it to analyze non-personal use of our Software for the purposes of performance monitoring, error protocols and analysis of user behavior, e.g. which screens are viewed, which publications are opened and how many users are using the Software. The purpose of such use is to analyze the use of our Software, regularly improve it and thereby operate it in a more cost-effective way.

Google Analytics 4 collects information about your use of the Software and transmits it to Google in Ireland or to data centres elsewhere where it is stored. The information is collected and transmitted only in pseudonymized and/or aggregated form, not linked to users’ other data.

Further information on Google and data protection can be found on Google’s Privacy Policy and “How Google uses information from sites or apps that use our services?”

 Processing personal data pursuant to a legal obligation

When necessary, we process personal data to fulfil a legal obligation, such as information needed for our tax returns.

Usage data for analysis

On what legal ground do we base the processing of your personal data?

We base the processing of your personal data within the Software on several legal grounds.

Performance of a contract

If you download, install and use the Software, you agree to the terms and conditions and therefore you enter into a binding agreement with us. We use your personal data for processing necessary for performance of the service contract with you, i.e. the services associated with purchasing Leaf.

 

Given consent

You may freely and based on specific information provided – for example, in this Privacy Statement – choose to download and use the Software, provide your personal identifier (such as email address), receive helpful push notifications, or use biometric information to facilitate payments through our payment service provider (for example, facial or fingerprint recognition).   

If you reside or are using the Service (i) in a territory governed by privacy laws which determine that “consent” is the only or most appropriate legal basis for processing personal data (in general, or specifically with respect to the types of personal data you choose to share via the Software), your acceptance of our Terms and of this Privacy Statement will be deemed as your consent to the processing of your personal data for all purposes detailed in this Privacy Statement, to the extent permitted under law in such territory. If you wish to revoke such consent, please contact us by using the contact details at the bottom of this Privacy Statement.

 

When you choose to use these options, you thereby consent to the processing of data for such purposes by us or our payment service provider (Stripe). Note that you can always withdraw your given consent. We explain how to withdraw your consent under the heading “How can you exercise your privacy rights?”.

 

For compliance with a legal obligation

We may process personal transactional data when necessary to comply with tax, fiscal and other legal obligations. 

 

For our legitimate business interests

The processing of your personal data is necessary to understand how we can develop and improve the service and Software, as well as for reporting purposes, general statistical and analytical purposes. Processing personal data for these purposes serves our legitimate business interest and has no or limited impact on your privacy, because data is used in a pseudonymous or anonymous form when possible.

 

To whom do we provide your personal data?

We share your personal data with our service providers; within our group of companies (affiliates); and in accordance with legal compliance requirements.

Service providers

Your personal data is shared with a limited number of carefully chosen third party service providers who support us in providing you with the Software according to this Privacy Statement and in so far as permitted by law. We take full responsibility for third party service providers’ performances when processing your personal data. We ensure that they maintain an appropriate level of data protection. Without your explicit consent we will not provide your personal data to third parties for their own marketing purposes.

Affiliated companies

We share personal data internally within our group of companies, for the purposes described in this Privacy Statement. In addition, should Club Leaf or any of its group companies undergo any change in control, your personal data may be shared with the parties involved in such an event.

 

Legal compliance

In exceptional circumstances, we may disclose or allow government and law enforcement officials access to your personal data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect the security or integrity of our products and services.

For the avoidance of doubt, we may share your personal data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous.

Is your personal data being transferred outside the country where you are located?   

We may transfer the personal data we collect about you to jurisdictions other than the jurisdiction in which the personal data was originally collected, and your personal data may be processed and stored outside of your jurisdiction of residence. We may transfer your personal data to the EU (the Netherlands, Germany, the Republic of Ireland) and the USA, as this is necessary for providing our services to you. We have taken all necessary measures to secure that the transfers take place in accordance with this Privacy Statement and within the limits set by applicable law.

How long do we store your personal data?

We do not store your personal data longer than is strictly necessary to realise the purposes for which it is collected. Your personal data will be removed or made anonymous when your personal data is no longer necessary for the purposes for which the personal data are processed. If you no longer wish to make use of the Software and choose to delete your account, we will delete your data within a reasonable period of time, unless the law stipulates a storage period.

How can you exercise your privacy rights?

At every desired moment you may request to access, rectify or erase your personal data. In addition to this, you may in certain cases also have the right of restriction of processing concerning your personal data, the right to object to processing, as well as the right to data portability.

  • Withdrawing consent
    You may withdraw any consent you previously provided to us, or object at any time on legitimate grounds, to the processing of your personal data. We will apply your preferences going forward. In some circumstances, withdrawing your consent to our use or disclosure of your personal data will mean that you cannot take advantage of some of our services.
    If you no longer want to use the Software, or have it collect usage data, or to have your personal identifier stored within the Software, you may delete the Software. If you want to withdraw your consent, please contact us via the contact details at the bottom of this Privacy Statement.
    In addition, you can manage your push notification preferences or deactivate the push notification at any time by turning off the notification setting in the Software or in the device setting of your device.
    Please keep in mind that withdrawal does not have retrospective effect and the withdrawal of your consent is only possible in case you first have given your consent.   

  • Reviewing, updating and modifying personal data
    Subject to applicable laws, you may have the right to request access to and receive details about the personal data we maintain about you, update and correct inaccuracies in your personal data, and have the personal data blocked or deleted, as appropriate. The right to access personal data may be limited in some circumstances by local law requirements. We may take reasonable steps to verify your identity before granting access or making corrections. You may request to review, change or delete your personal data by contacting us through the contact details at the bottom of this Privacy Statement.

  • Objecting to processing
    You may object to us processing your personal data where you believe that your rights override our interests in the processing of your personal data.

  • Request for erasure
    - You may ask us to erase your personal data where:
    You do not believe that we need your personal data in order to process it for the purposes set out in this Privacy Statement
    - If you had given us consent to process your personal data, you withdraw that consent and we cannot otherwise legally process your personal dataYou object to our processing and we do not have any legitimate interests that mean we can continue to process your personal data
    - Your personal data has been processed unlawfully or has not been erased when it should have been

Please be aware that these rights may not apply in all cases. For example, we do not have to erase your personal data if we need to use that personal data for a legal obligation.

  • Analytics opt-out
    Google created a browser add-on that allows you to turn off Google Analytics ad trackers, and works for Chrome, Firefox, Safari, Opera, and Internet Explorer 11. By downloading the add-on, your browser will opt-out of Google Analytics requests, meaning that you have prevented your personal data from being collected and used by Google and its affiliates. To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.
     

  • Lodge a complaint
    You can lodge a complaint with your local data protection supervisory authority when you have a complaint about the use of your personal data.

To invoke your privacy rights, please contact us by using the contact details at the bottom of this Privacy Statement. Please keep in mind that we may ask for additional information to verify your identity.  
 

Are you obliged to provide your personal data to us and what are the consequences if you do not?

If you choose to use the Software, some personal data collection is necessary, which means that you can’t use the service without providing this data. Where optional, such as with receiving push notifications, you are free to provide consent or to refrain from using this feature. 

 

Do we use profiling techniques or make automated decisions?

We do not use profiling techniques and/or any kind of automated decision-making.

Which cookies and similar tracking technologies do we use?

Within the Software, we use functional and analytical cookies and similar tracking technologies. Functional cookies are necessary for a proper functioning of the Software. For example, a functional cookie makes sure you don’t have to login every time you open the Software. Analytical cookies help us to improve our services whereby we are able to count our Software visitors and see how visitors make use of our Software. With both analytical and technical cookies, we will not receive any personal data.

 

How can you contact us?

If you have any questions about the way we process your personal data, please read this Privacy Statement first. For additional questions or if you want to contact us, please contact us at:

Club Leaf B.V., Asterdse Sluis 22, 4823GL Breda, the Netherlands

support@clubleaf.com