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Privacy Statement (EN)

Last update: 28 October 2021

When you make use of the Club Leaf mobile application (“App”) and www.clubleaf.com (“Website”), Club Leaf processes your personal data. The App and the Website are owned and operated by Club Leaf B.V. (referred to in this Privacy Statement as “Club Leaf", “we", “our", or “us"). Your privacy is extremely important to us. We always respect your concerns about privacy and are transparent about the processing of your personal data.

This Privacy Statement applies to our online activities through the App and the Website. We describe 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 your personal data, how you can contact us about our privacy practices and all other information that may be relevant to you.

We are continually developing and improving our services. If we change the way we process your personal data, we will always inform you through this Privacy Statement. We therefore recommend to regularly take notice of the Privacy Statement for any modifications. Important changes will also be communicated proactively.

If you have any questions about this Privacy Statement or our use of your personal data, please contact us through the contact details provided at the bottom of this Privacy Statement. 

Please note that we determine the language of this Privacy Statement based on the language settings of your browser. Via the country selector at the Website, you can also select another country to view this statement in another language.

Who are we?

Club Leaf is responsible for collecting and processing personal data through the App and the Website as described in this Privacy Statement and is considered the “data controller”. Club Leaf B.V. is an entity incorporated under the laws of the Netherlands. If you want to contact us, please use the contact details provided at the bottom of this Privacy Statement.

How do we obtain your personal data?

We obtain your personal data when you visit the Website or App. Some personal data we collect from you because you actively provide us with the personal data, for example when you provide information to make an account, provide information about your lifestyle / habits to calculate your personal CO2 footprint or contact us via e-mail. Other data is obtained automatically, for example by using cookies and similar technologies. For more specific information on cookies and similar technologies used, please refer to the question “Which cookies and similar tracking technologies do we use?” below.

You are under no obligation to provide any information about yourself to us. However, refusal to supply certain information via cookie blockers, might impact the Website or App experiences or functionality of the App. We will inform you if the provision of certain personal data is a legal or contractual obligation or an essential requirement for concluding an agreement with us. In this case we will also inform about the possible consequences if this information is not provided.

Which personal data is used for what purposes?

The information which is obtained from you is processed for specific purposes, as detailed below.

Website

We process personal data for providing, maintaining and improving the Website.

  • The persons involved. Website Visitors: persons who visit the Website.

  • The purposes of the processing. When you visit the Website or contacts us via e-mail, we will process your information for the following purposes:

    • Functioning of the Website: including remembering the Website Visitor’s settings.

    • Handling any requests, complaints and disputes, for example when you contact us via the Website contact form, by e-mailing hello@clubleaf.com or to provide (technical) support when necessary.

    • Registration for our newsletter and sending e-mails with our latest news.

    • Redirecting you to our career website enabling to apply for a job opportunity.

    • Processing for other business purposes:

      • Perform accounting, auditing and other internal functions;

      • Determining, exercising and defending our rights; and

      • Complying with legal obligations and requests of authorized governmental institutions.

  • The personal data processed.

    • Website usage data (IP address, Device ID, Browser type, Browser language settings).

    • Other technical information, such as regarding the interaction between the Website Visitor’s device and the Website, the web pages that were visited and the log data.

    • Your email address for requests, complaints, disputes and the newsletters.

    • The communication via our contact form or hello@clubleaf.com.

    • Job application information (such as your personal details, contact details, your CV, cover letter, photo, and other information you provide to us in support of an application.

    • Sensitive information: In the context of the Website we, in principle, do not process special categories of personal data.

  • Legal grounds for the processing.

    • For our legitimate business interests. We base the use of the Website Visitor’s personal data in the context of the Website on our legitimate interest in offering and securing the Website, and pursuing the other processing purposes listed above. If you want more information about this assessment, please use the contact details provided at the bottom of this Privacy Statement.

    • Consent. We will only use your e-mail address for news updates with your prior informed consent. We will always provide you with the option to opt-out in every message.

    • For compliance with a legal obligation. We may also process Website Visitor’s personal data based on a legal obligation. This means that we will process the data for as far as we are legally obliged to do so, for instance if we receive an injunction that we need to adhere to

App  

We process personal data for providing, maintaining and improving our App and to offer online services to you.

  • The persons involved. App users with an account or without an account.

  • The purposes of the processing and personal data processed. We will process your personal data for the following purposes in the App:

    • Your account creation and e-mail validation. It is optional to create an account.

    • To calculate your CO2 footprint. It is optional to use our free service to estimate your personal CO2 footprint based on your habits which will be stored by us once you have created an account. You have the option use the average CO2 footprint of your country. The CO2 footprint is based on calculation of the estimated greenhouse gas emissions caused by an individual, event, organization, service, place or product, expressed as carbon dioxide equivalent. This calculation is based on the App users’ lifestyle choices and is an estimation only.

    • Enabling you to purchase Leaf to offset your CO2 footprint.

    • Enabling you to receive helpful push-notifications.

    • Sending you personalised informative messages about CO2 footprint reduction “Green Tips”.

    • Informing you about changes to our services and products and customer service / IT helpdesk.

    • Analytic purposes to measure and improve App performance.

    • All personal data may be used for the following legitimate business purposes if deemed necessary:  Performing accounting, auditing and other internal functions; determining, exercising and defending our rights; and complying with legal obligations and requests of authorized governmental institutions.

  • The personal data processed.

    • Nickname (you do not need to use your real name).

    • Username (Email address) and password.

    • Language and country of residence.

    • Device information (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).

    • Your lifestyle choices for personalised CO2 calculation and personalised offers (e.g. travel and commuting habits, shopping habits, energy and gas usage, diet, size of your home, household).

    • Your personal CO2 footprint.

    • Purchase and payment details (Personal CO2 footprint, local currency, Leaf balance, transactions and spend data, type of purchase (subscription or one-off), bank account details, billing address, card expiration date, donor name, CVC code, date/time/amount of transaction, DeviceID, email address, IP address/location, OrderID, payment card details).

    • Push-notification data (Customer ID, personal CO2 footprint, app usage data and your user behaviour transactional data (such as user registration, user login, whether a payment has been made) to trigger sending a push-notification to you.

    • Questions, complaints or requests when contacting us.

  • Legal grounds for the processing.

    • For performance of our contract with you. If you download, install and use the App, 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, calculation of your personal CO2 footprint and purchasing Leaf to offset your CO2 footprint).

    • Consent. We will only use your e-mail address for news updates with your prior informed consent. We will always provide you with the option to opt-out in every message. We also ask your consent for receiving of push-notifications and personalised “Green Tips”.

    • For our legitimate business interests. We base the processing for analytics purposes on our legitimate interest in offering and securing our App and pursuing the other processing purposes listed above. The processing of your personal data is necessary to understand how we can develop and improve our services, 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. This means that a balance of interests is performed between the interests that are served by the processing on the one hand and your privacy interests on the other hand, and that the interests of the processing prevail. If you want more information about this assessment, please use the contact details provided at the bottom of this Privacy Statement.

    • For compliance with a legal obligation. We may also process your personal data based on a legal obligation, for example to comply with minimum retention terms in tax law. This means that we will process the data for as far as we are legally obliged to do so, for instance if we receive an injunction that we need to adhere to.

Minors and other persons with a legal representative

In principle, we focus provision of our services to and processing of personal data of persons who are older than 18 years, or who are at least the age of majority in their country of residence and from which country they are using the App and/or Website. We also do not focus on persons who are placed under a legal relationship, such as guardianship or persons who are supervised or administered by someone else.

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 App and/or Website according to this Privacy Statement. Sub-contractors, for example, will in principle only get access to the personal data that they require for their part of the service provision and will not be allowed to process the data for their own purposes. 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.

We use the following service providers with whom we share personal data on a need-to know basis:

  • Payment service provider. We use Stripe Payments Europe Ltd as our payment service provider with whom we share personal when you purchase Leaf through the App. Stripe uses this information also for its own purposes 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.

  • User authorization platform provider.  We use a user authorization platform provider to develop and integrate the identity management aspects of the App.

  • Marketing. We use a service provider for sending push notifications and newsletters.

  • Analytic services provider. We use Google services to process your personal data for analytic purposes as described in this Privacy Statement.

  • Affiliated companies. We share personal data internally within our group of companies, for IT hosting and support services for the Website, the App and data processing for analytic purposes.

Affiliated companies

If Club Leaf or any of its group companies undergo any change in control, your personal data may be shared with our affiliated entities 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.

How do we protect your personal data?

The security of your personal data is important to us. We have implemented appropriate (technical and organizational) security measures to protect the personal data in our care; both in transit and at rest. For example, we use aggregation, anonymisation and encryption techniques to protect your personal data from unauthorized access, as well as unauthorized disclosure or destruction of personal data. In addition, we make sure that service providers, affiliated companies or other recipients will do the same.

 

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. In case the data is processed outside the EEA, the transfer is legitimized in the manner described below. You can find an overview of the EEA countries here: https://ind.nl/en/Pages/eu-eea-countries.aspx.

Transfers outside the EEA. The transfer of personal data to a third party outside the EEA can, in the first place, be based on an adequacy decision of the European Commission, in which it is decided that the third country in question ensures an adequate level of data protection. European Commission website provides an overview of the adequacy decisions that have been taken.

If personal data is transferred to a country outside the EEA for which there is no adequacy decision, we agree on the application of the relevant Standard Contractual Clauses and additional safeguards where appropriate. This contract safeguards the protection of personal data, as approved by the European Commission.

In other specific situations, we may transfer personal data: (i) with your explicit consent, (ii) if this is necessary for the performance of a contract that has been concluded with you or has been concluded in its interest, or (iii) if this is necessary for the establishment, exercise or defense of legal claims. Lastly, in exceptional cases we may also transfer your personal data if the data transfer is necessary for our compelling legitimate interests which is not overridden by your interests or rights and freedoms.

You can contact us if you want additional information about the way in which we legitimize the transfer of personal data to countries outside the EEA. Our contact details are stated at the bottom of this Privacy Statement.

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 your data are 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 App and choose to delete your account, we will delete your data and Club leaf will instruct its processors to delete the personal data, unless the law stipulates a storage period.

Exception: shorter retention period. If you exercise certain privacy rights we may remove the related personal data earlier than the general applicable retention period or – oppositely – retain it for a longer period of time. For more information about this, please refer to the question "How can you exercise your privacy rights (also the right to object)?"

Exception: longer retention period. In certain situations, we may retain your personal data for a longer period of time than what is necessary for the purpose of the processing. This is for instance the case when:

  1. we have to comply with a minimum retention period or other legal obligation to which we are subject based on the applicable law. This will, in principle, not apply to cookie related data.

  2. The data is necessary in relation to a legal procedure.

  3. When further processing of the data is necessary in order to exercise the right to freedom of expression and information. This will in principle not apply to cookie related data.

How can you exercise your privacy rights (also the right to object)?

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. You can exercise the privacy rights free of charge, by e-mail via the contact details below and sometimes through the App or browser settings. To what extent these rights can be exercised, may depend on the circumstances of the processing, such as the manner in which Club Leaf processes the personal data and the legal basis for the processing. Below we included a summary of your privacy rights.

We will respond to all requests without undue delay. If our full response will ever take more than a month due to the complexity or number of requests, we will inform on this. Depending on the complexity of the request and on the number of requests, this period can be extended by another two months. Furthermore, please note that we may request more information to confirm the identity of the person filing the request, before acting on any request.

Your privacy rights:  

  • 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 App, or have it collect usage data, or to have your Customer identifier/number stored within the App, you may delete the App. 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 Green Tips preferences at any time by turning off the setting in the App 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.   

  • Right of access. The right to access enables you to receive a copy of the personal data we hold about you (but not necessarily the files themselves). We will then also provide further specifics of our processing of the personal data. For example, the purposes for which we process the data, where we got it from, and with whom we share it. The right of access to personal data may be limited in some circumstances by local law requirements.

  • Right to rectification. This concerns the right to request rectification of the data that we hold about you. This enables you to have any incomplete or inaccurate data corrected.

  • Right to object. 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 where we are relying on legitimate interest as processing ground (see above). Insofar as the processing of the data takes place for direct marketing purposes, we will always honour an objection; however, we do not process your personal data of for these purposes other than sending you news updates. For processing for other purposes, we will also cease and desist processing, unless we have compelling legitimate grounds for the processing which override your interests, rights and freedoms or that are related to the institution, exercise or substantiation of a legal claim. If such is the case, we will inform on our compelling interests and the balance of interests made.

  • Right 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 data

    • You object to our processing and we do not have any legitimate interests on the basis of which 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 we do not have to honour such requests 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. Please be referred to the website of the European Data Protection Board (EDPB) for an overview of the data protection authorities and their contact details. However, we would appreciate the chance to deal with any concerns before the data protection authority is approached, so please contact us beforehand.

 

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 App, 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?

When you choose to receive personalised “Green Tips” and/or other personalised offers, we use the lifestyle choices you provided to automatically create a profile. Your profile will provide us with a better understanding of where your emissions come from, which enables us to provide you with personalised offers to support you in offsetting your CO2 footprint. You can change your lifestyle choices at any time by redoing the calculation in the App. We will make sure we will always and only use your latest lifestyle choices,  

Which cookies and similar tracking technologies do we use?

When you visit the Website or App, text files will be placed on your computer, tablet or cell phone. This is called a cookie. Cookies can be used to collect or store information about your visit or the device you are using.

The Website and App use functional and privacy friendly analytical cookies. Functional and essential cookies are necessary for a proper functioning of the App. For example, a functional cookie makes sure you don’t have to login every time you open the App. Privacy friendly analytical cookies help us to improve our services, whereby we are able to count visitors/users and see how visitors/users make use of the Website and/or the App.

Website cookies:

Cookie name: wixLanguage

Description: Used on multilingual websites to save user language preference

Cookie type: Functional cookies

Life cycle after last update: 12 months

Cookie name: XSRF-TOKEN

Description: Used for security reasons

Cookie type: Functional cookies

Life cycle after last update: Session

Cookie name: hs

Description: Used for security reasons

Cookie type: Functional cookies

Life cycle after last update: Session

Cookie name: svSession

Description: Used in connection with user login

Cookie type: Functional cookies

Life cycle after last update: 2 years

Cookie name: SSR-caching

Description: Used to indicate the system from which the site was rendered

Cookie type: Functional cookies

Life cycle after last update: 1 minute

Cookie name: _wixCIDX

Description: Used for system monitoring/debugging

Cookie type: Functional cookies

Life cycle after last update: 3 months

Cookie name: _wix_browser_sess

Description: Used for system monitoring/debugging

Cookie type: Functional cookies

Life cycle after last update: Session

Cookie name: smSession

Description: Used to identify logged in site members

Cookie type: Functional cookies

Life cycle after last update: Session

Cookie name: TS*

Description: Used for security and anti-fraud reasons

Cookie type: Functional cookies

Life cycle after last update: Session

Cookie name: bSession

Description: Used for system effectiveness measurement

Cookie type: Functional cookies

Life cycle after last update: 30 minutes

Cookie name: fedops.logger.sessionId

Description: Used for stability/effectiveness measurement

Cookie type: Functional cookies

Life cycle after last update: 12 months

App tracking technologies

Cookie name: Analytics Android SDK & Analytics iOS SDK

Description: Google Analytics 4 (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 App 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 App. The purpose of such use is to analyze the use of our App, regularly improve it and thereby operate it in a more cost-effective way. Google Analytics 4 collects information about your use of the App and transmits it to Google in Ireland or to data centers elsewhere where it is stored.

You can disable these cookies. We have set these cookies to be privacy friendly. The last octet of the IP address is masked. We have chosen to turn off the "data sharing" function and do not use other Google services in conjunction with the Google Analytics cookies. 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?

Cookie type: Analytics SDK

Life cycle after last update: App installation lifetime

Website and App cookies

Cookie type: Social media plug ins

Description: On the App we may use so-called social media plug-ins. When you visit a page that displays one or more of these buttons, your browser makes a direct connection to the relevant social network server and uploads the button from there. Simultaneously, the social media provider will know that the corresponding page on our Website has been visited. We have no influence on the data that the social media providers collect based on the buttons. If you want to prevent the collection of data based on the buttons, please log out of your social media accounts before visiting our websites and disable the storage of cookies in your browser settings.

You can change your cookie settings at any time and disable or delete cookies from the Website or App. However, please note that if you do so, the Website or App may not work optimally. In addition, you can change your browser settings so that Website cookies cannot be placed on your device.

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

Email: hello@clubleaf.com