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Chooose Data Protection Policy

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1. Introduction

This Data Protection Policy (the “Policy”) sets out how Chooose (“we” and/or as defined in the GTCs) handle personal data in the Chooose services (as defined in the GTCs) and on associated websites, third party partner platforms and applications for desktops, tablets and mobile handsets (hereinafter referred to as the “Service”). By using the Service, you indicate your acceptance of this Policy. If you do not agree to this Policy, you are not permitted to access the Service and you should not do so. By personal data we mean information that can be used to uniquely identify a single person. If you have questions about this Policy please feel free to contact us by following the instructions on our website: http://chooose.today or by sending an e-mail to privacy@chooose.today.

2. Children and privacy

We do not knowingly collect information from children under age 13. If you are under age 13, you are not permitted to use the Service. If you are 13 - 17 years of age, you may visit, browse and use the information on the Service but you may not register an account or submit any personal information. If you are 13 - 17 years old, by browsing, using or accessing the Service you confirm that you have the permission of a parent or guardian to do so. If you are a parent or guardian and believe that we may have inadvertently collected personal information from your child, please notify us immediately by following the instructions on our website: http://chooose.today or by sending an e-mail to privacy@chooose.today.

3. Collection and use of personal data

When you register as a user for the Service at a Chooose website or through a third party partner platform, you may provide us with certain information that we store. When you use the Service, we may store information generated by your use of the Service, such as virtual emissions statistics for your user, activity in the Service, time of log-in, location of sessions if allowed by the device, what version of the Service you use, technical data such as your IP address, location information, and other similar information. If the Service is accessed via a handheld device we also store a number that uniquely identifies the device. Information that you add to your profile like your age may also be stored. If you reply to surveys that we have provided or otherwise provide us with your personal data in response to our communications to you, the information you provide will be made anonymous unless otherwise specified. This information is used to provide the Service to you, to calculate settlement when acquiring actual emission quotas, to improve the Service, and if provided by you in response to our communications, to provide you with special offers and promotions from Chooose or its partners. Your participation in any such special offer is completely voluntary. When you purchase climate offsetting or any other product offered by us through a third party platform, we will store name, address email, phone number and user- or membership ID or other information needed for the purposes of completing the transaction and comply with our legal obligations.

4. Lawful bases of processing

We primarily process your personal data so that we can fulfil our contractual obligations in providing our Service to you. When you purchase a product through our Service, our legal basis for processing your personal information is our legal obligations as the counterparty to the transaction, hereunder accounting and reporting requirements. When you use our services we process personal data based on our legitimate interest to run, maintain and develop our operations and to create and maintain customer and other business relationships. 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. Please see section 12 for further information on how to exercise this and other rights.

5. Sharing information with third parties

We will not share your personal data with third parties except in the following situations:

a) when necessary for billing purposes or other services/functions performed on our behalf, we share information with the billing provider or other vendor to facilitate billing or other services/functions, respectively. The payment information is stored by the billing provider and not by Chooose;

b) when we engage third parties to perform services on behalf of us in relation to the Chooose service, either companies that are affiliated with us or third parties. In such cases we will remain responsible for your personal data and ensure that all handling of the data will be in accordance with this policy and applicable laws; and

c) in response to legal processes, such as a request by law enforcement, a court order or similar, or to protect the integrity of the Service if we believe that a user has committed unlawful or otherwise harmful acts.

d) when using Chooose services through a third party partner platform information may be shared with the Chooose partner to the extent necessary for Chooose and the third party platform partner to deliver the agreed services and for the third party platform partner´s own purposes.

We will never sell your personal data to third parties and except for as stated above we will never allow third parties to have access to your data for their own purposes unless you otherwise provide your consent. If all or part of Chooose is sold, merged or is otherwise transferred to another entity, the information you have provided on or through the Service may be transferred to such entity as part of that transaction.

6. Communications

If you have provided us with your email address or your phone number, we will only use this information to communicate with you in matters relevant to the Service. Such information includes receipts for payment, information about changes in the Service, changes in the GTCs, and this Policy.

We will not use this information to send you information about third-party services unless you otherwise provide your consent. Providing us with this information in response to our communications to you shall be considered consent from you to use this information to send you information about third-party services. If the legal statuary requirements are met or if you have opted in, we will send you our newsletter and similar information. You can at any time give us notice that you no longer want to receive such communication.

7. Server log files

Usage of the Service may be logged in the server log files. These log files include the IP address of the device that accessed the Service together with the time of the use and which resource that was requested, as well as user identification information. The log file of the Service is used to create anonymous usage statistics that are used to settle with the owners of the content, to analyze the usage of the Service, and for the purposes of system administration.

8. Cookies and similar technologies

Read more about our use of cookies and analytical tools in our Cookie Policy.

9. Integration with third-party websites

We may link and allow you to connect to third-party websites. Chooose cannot control or be held liable for third parties’ privacy policies and content. Please refer to the site’s privacy policy to understand how the site deals with your data. Please check these policies carefully before you submit any personal data to such sites.

10. Safeguarding of personal data

We continuously work to safeguard your data in a secure manner on restricted and protected equipment. We limit access to this equipment, and only persons with a legitimate reason have access to your personal data. Chooose is certified to the standard ISO270001 Information Security Management System and our security work focuses on implementing sufficient security measures to prevent unauthorized access. We also use anonymized and non-personally identifiable data when possible.

11. Retention of personal data

We will retain your personal information only for the period necessary to fulfill the purposes outlined in this policy. When it is no longer necessary to store the data it will be deleted or made anonymous in a safe and permanent manner or the access to it will be blocked to the extent that statutory data retention requirements apply.

12. Your rights

You have the following rights:

  • The right to be provided with copies of personal information that Chooose holds about you at any time.
  • The right to ask Chooose to update and correct any incorrect personal information held about you free of charge
  • The right to request deletion or removal of your personal data where there is no good reason for us to continue processing the data. Note, however, that we might have to continue processing some of the information in order to comply with legal requirements.
  • The right to object to the processing of your personal data where we rely on legitimate interest
  • The right to opt-out of any marketing communications that Chooose may send you
  • The right to request the transfer of your personal data to you or to a third party.
  • The right to withdraw consent where we are relying on consent to process your personal data. Please note that this will not affect the processing activities carried out prior to your withdrawal of consent.

If you wish to exercise any of the above rights, please send your request to privacy@chooose.today

13. Detection of misuse of the service

If there is suspicion of misuse of the Service, we might combine data collected in accordance with this Policy with other information in order to investigate the extent of the misuse and who is responsible.

14. Notices, consents, and contact

If you have questions regarding your data stored with us, its rectification or deletion, or would like to revoke any consent provided to us, object against certain uses, or similar, please feel free to contact us at privacy@chooose.today.

15. International users

Chooose may process personal data on computers and servers located outside the EEA. When transferring your personal data to jurisdictions outside the EEA we always ensure that your personal data receives an adequate level of protection and that we can ensure that your rights can be adequately exercised. We ensure this through at least one of the following safeguards:

The country where the data will be processed have been deemed to provide an adequate level of protection by the European commission

Specific contracts approved by the European commissions which give personal data the same protection it has within the EEA.

16. Amendments to policy

The Service is subject to constant improvement and future changes may influence what data we store and how we process it. This Policy might be updated to reflect such changes, changes in the legal framework, or improvements in how we handle personal data. Such changes or updates are effective immediately after we give notice of the change or update, which we may do by revising the “Date of Last Revision” date of this Policy or by otherwise posting on the Service, or by email or conventional mail, and/or by any other means which provides reasonable notice. Your use of the Service after such notice is posted means that you accept these changes or updates. You agree that Chooose shall not be liable to you for any damages that might result from any changes to this Policy, if any. The current version of this Policy can be found on our website: http://chooose.today​.