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COMPENSATE PRIVACY STATEMENT

Updated January 10, 2022

Compensate Operations Oy ("Compensate" or "we") is a non-profit company based in Finland, on a mission to combat climate change by helping individuals and companies to calculate and offset carbon emissions that they cause. We do this by offering various carbon footprint calculators and carbon offsetting services through our websites, mobiles apps and other services.

In this privacy statement, we explain how we process the data of our users, customers, partners, potential clients and other business contacts. 

(We may also use your personal data if you apply to join our team as an employee, subscribe to our newsletters, submit your contact details through an online form, or take part in an event organized by us. Scroll up to find the specialized privacy policies applicable to these purposes.)

Please note that our websites, mobile apps and services are only intended for users who are at least 13 years old. If you're younger than that, we ask that you do not sign up to or use our websites, mobile apps or services.

This Privacy Statement may be updated from time to time to reflect the changes in data processing practices or otherwise. You should always view the current version on our website. 

Who’s we? Compensate Foundation owns Compensate so we are regarded as joint controllers in relation to some of the personal data.

A non-profit foundation called Compensate Foundation (Business ID 2914937-8, Mariankatu 5 A, 00170 Helsinki, Finland, hereinafter: the ”Foundation”) owns 100% of Compensate. Because the Foundation receives the Compensation payments and purchases the carbon offsets, are Compensate and Foundation as joint controllers relating to some of the personal data defined in this privacy statement.

The joint controllership of the Foundation starts at the very moment you order a carbon offsetting service and ends when you cancel the use of the carbon offsetting service and there is no legal obligation for the Foundation to process the data anymore. In practice, the Foundation acts as a joint controller only in relation to personal data it needs for invoicing the compensation payments and for bookkeeping. This personal data includes, for example, your name, email address, your card details, the amount of the Compensation payment and the invoicing date. In addition, the Foundation may have a legitimate interest or a legal obligation to process some other user data or analytics data. 

In practice, Compensate is liable for complying with the applicable privacy legislation, data security, and your privacy rights relating to the Services. Therefore, the privacy statement of Compensate applies to processing your personal data relating to the Services. 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.

This Privacy Statement applies to the processing of personal data carried out by Compensate and the Foundation as joint controllers or Compensate as a controller. 

1 Contact us

Compensate Operations Oy

Mariankatu 5 A,

00170 Helsinki

Finland

Business ID: 2993434-1

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 signing up to or using our websites, mobile apps or 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 websites, mobile apps or services.

We mainly process the following types of your Personal Data: User Data and Analytics Data. To learn more about this, read on.

2.1 User Data

User Data are personal data collected or otherwise received directly from you or generated by our websites, mobile apps or services or us based on your use of these platforms. We may collect or receive User Data from you in a variety of ways, including, when you sign up to and use them platforms. We mainly process the following User Data relating to you:

  • basic information, such as your name, your contact information (email, address), your business ID, your VAT ID, your employer, your title or position, your place of residence, age;
  • password and credit card information;
  • the payment plan you have chosen;
  • marketing opt-ins and opt-outs;
  • data you have entered into the Services, such as your consumer habits or the data relating to the emissions of the Company. These include, for example, information about your
  • living (such as a number of people living in your household, the living area of your home/the area of the office the Company uses, the kind of electricity you use, the kind and the building year of the house/office),
  • transportation and traveling (such as the average distance you or the personnel of the Company drive by a car, the driving power of the car, information about the use of the public transportation, the time spent flying, the number of return trips by ferry),
  • eating habits (such as the estimated amount of food you consume, a diet, eating outside, estimated amount of food waste),
  • other consumer habits or other emissions resulting from the operations of your Company (such as pets, summer cottage, events you organize, other consumer habits) and
  • system of measurement you use
  • data generated by the Services, such as the carbon footprint based on your consumer habits or the emissions of the Company;
  • 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

Some of the logging systems used by our websites, mobile apps and services log certain Analytics Data when you visit or use them. Although we don't normally process 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 these situations, we'll treat such Analytics Data as your Personal Data. 

To learn more about the types of Analytics Data that we may process, read on.

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 process information on your use of our websites, mobiles apps and services, such as:

  • time spent on them;
  • interaction with them, and
  • the time and date of your visits to them. 

Dynamic Links

If you interact with our social media features that let you submit certain Personal Data to us or to download and install or open our mobile apps (we call these features “Dynamic Links”), or if you post your Personal Data on your social media account, we may also collect or receive your Personal Data from those sources.

To make the Dynamic Links work properly, we process your device specifications (such as the make and model or operating system of your device) and IP addresses.

In addition, we may collect or receive certain Analytics Data from you when you interact with Dynamic Links. These may include information about

  • when the app was first opened;
  • when the app was reopened;
  • clicks;
  • redirects;
  • the total carbon footprint of the 1) User posted a specific Dynamic Link and 2) the new Users who found the Compensate mobile app through that specific Dynamic Link and calculated their carbon footprint by using the Compensate mobile app;
  • and
  • app installs. 

We may also use these Analytics Data to gauge the effectiveness of our promotions and campaigns. 

To create and operate Dynamic Links, we use Google Firebase Dynamic Links features. To this end, we may share Personal Data with Google, and the data is processed in accordance with their privacy policy ( https://firebase.google.com/support/privacy ). 

2.3 Cookies and Similar Technologies

We use various computer technologies to collect or receive and store Analytics Data and other information when you visit some parts of our websites, mobiles apps and services. These technologies may include for example cookies, pixel tags, and web beacons. Cookies are small text files sent and saved on your device that allow us to identify our users and visitors and to facilitate the use of our websites, mobile apps and service. Pixel tags and web beacons are small pieces of computer code that may recognize and gather information about your device, browser or other things with the effect that it may collect, receive or otherwise identify your Personal Data. Cookies and similar technologies will not harm your device or files.

We use cookies and similar technologies to tailor our websites, mobile apps and services to your device specifications and your individual preferences. We process the Personal Data that we collect or receive this way to improve our websites, mobile apps and services as well your user experience on them.

We use various types of cookies, some that are necessary for the technical functioning of our websites, mobile apps and services, and others that are technically speaking non-necessary. While necessary cookies are always on, we only use non-necessary cookies with your consent. Non-necessary cookies include e.g. analytical and marketing cookies. To learn more about this, read on.

To see the current list of cookies that we use, or to revoke your consent for us to use non-necessary cookies, see your Cookie Preferences (<- click).

Necessary Cookies (Always On)

We use cookies that are technically necessary to provide core functionality in our websites, mobile apps and services. These platforms won't function properly without these cookies and they are enabled by default and cannot be disabled.

The necessary cookies that we currently use are:

  • m
m.stripe.com

Used by Stripe Payment Services for fraud prevention and detection.

  • _GRECAPTCHA
www.google.com

Used by Google reCaptcha for risk analysis

  • __cf_bm

.pipedrive.com

The __cf_bm cookie supports Cloudflare Bot Management by managing incoming traffic that matches criteria associated with bots. The cookie does not collect any personal data, and any information collected is subject to one-way encryption.

  • __cf_bm

.pipedriveassets.com

The __cf_bm cookie supports Cloudflare Bot Management by managing incoming traffic that matches criteria associated with bots. The cookie does not collect any personal data, and any information collected is subject to one-way encryption.

Preference Cookies (Opt-Out)

Preference cookies enable the web site to remember information to customize how the web site looks or behaves for each user. This may include storing selected currency, region, language or color theme. We use them to provide you with the best possible user experience when visiting and using our websites, mobile apps and services. However, if you wish, you may turn them off in your Cookie Preferences (<- click).

Analytical Cookies (With Your Consent)

We only use these cookies after you've given us consent to do so. If you have given your consent but wish to revoke it later, see your Cookie Preferences (<- click). If you're a Compensate Plus user, you can also find the consent revoke button in the footer of the Compensate Plus website.

  • Google Analytics

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 (<- click).

Pro tip: It's also possible to opt-out of Google Analytics with the following browser add-on tool:  Google Analytics opt-out add-on (<- click). 

  • Hotjar

We use Hotjar in order to better understand our users’ needs and to optimize this service and user experience. Hotjar Ltd is a company incorporated and registered in Malta with a company number C 65490 and havring its registed office at Dragorna Business Centre, 5th Floor, Dragonarna Road, Pacewille St Julian's STJ 3141, Malta. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback.

Hotjar uses cookies and similar technologies to collect data on our users’ behavior and their devices. This includes a device's IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf.

For further details, please see the ‘about Hotjar’ section of Hotjar’s support site .

You can revoke your consent for us to use the cookies provided by Hotjar either by clicking the link at the beginning of this privacy statement or on the footer of https://www.compensate.com/compensate-plus .

  • LinkedIn Insight

The LinkedIn Insight Tag is a piece of lightweight JavaScript code that helps us gather in-depth campaign reporting and valuable insights about how visitors use our website. Through the Tag, LinkedIn Insight collects data regarding website visits, such as accessed URL, referrer URL, IP address, device and browser characteristics, and time-stamp. We will not receive the data, but instead LinkedIn Insight will provide us with reports and alerts from which users cannot be identified. To learn more, see this answer from LinkedIn Insight (<- click). See also LinkedIn's Privacy Policy here (<- click).

Marketing Cookies (With Your Consent)

We only use these cookies after you've given us consent to do so. If you have given your consent but wish to revoke it later, see your Cookie Preferences (<- click). If you're a Compensate Plus user, you can also find the consent revoke button in the footer of the Compensate Plus website.

  • Google Analytics Advertising Features

As part of Google Analytics, we're using its Advertising Features on our websites to reach out to you with meaningful marketing content. Through Google's remarketing tools, we're delivering ads about us and our services to you through various means. This means that after you have visited our website and have consented to our Google Analytics cookies, you may see our ads on other websites, in other apps and in other instances where Google ad content is delivered to you.

We only reach out to you this way if you have consented to our Google Analytics cookies. Also, you may opt-out from receiving our ads through Google Ads settings, Google Ads settings for mobile apps or by installing the Google Analytics opt-out add-on (<- click). You also use a third-party opt-out tool such as the NAI Consumer Opt-Out Tool (<- click). Read more about Google Analytics Advertising Features and privacy here (<- click).

  • Other Marketing Cookies

To reach out to you with meaningful marketing content through different means, we're using advertising cookies from various providers. We use these to deliver our ads to you in a useful manner on various websites and mobile apps. To see the various marketing cookies that we use, have a look at your Cookie Preferences (<- click).

Other Cookies (With Your Consent)

We may also use a number of uncategorized cookies for various technical and non-technical purposes. We only use these cookies after you've given us consent to do so. If you have given your consent but wish to revoke it later, see your Cookie Preferences (<- click). If you're a Compensate Plus user, you can also find the consent revoke button in the footer of the Compensate Plus website.

2.4 Payment Processing and Customer Data Handling

Stripe

We use Stripe for processing our payments and handling our customer data. For those purposes, we share certain customer information, such as name, postal address, email address, phone number, payment method data and other similar information with Stripe.

Our contracting partner for these purposes is Stripe Payments Europe, Ltd, a subsidiary of Stripe, Inc. (USA) based in Ireland (EU). To provide its services to us, Stripe may have to transfer customer data to its other entities and contracting partners that may be located in other countries outside the EU/EEA.

To that end, we have signed a Data Processing Agreement with Stripe, where necessary, to make sure all personal data is processed in accordance with Finnish, European and other data protection laws (see Section 6 below for details).

Google

We use Google Cloud Platform, Google Firebase and other Google services for customer and user management. For that purpose, we share certain customer and user information, such as name, postal address, email address, phone number, payment method data and other similar information with Google.

Our contracting partner for this purpose is Google Ireland Limited, a subsidiary of Google, Inc. (USA) based in Ireland (EU). To provide its services to us, Google may have to transfer customer data to its other entities and contracting partners that may be located in other countries outside the EU/EEA.

To that end, we have signed a Data Processing Agreement with Google, where necessary, to make sure all personal data is processed in accordance with Finnish, European and other data protection laws (see Section 6 below for details).

2.5 Personal Data Provided Us by Third Party Service Providers

We process data that different third-party service providers give us about you. If you connect or login to your user account with Facebook, Twitter, Instagram, Google, or Apple, they share 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.

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. In addition, Compensate and Foundation may transfer all the personal data defined in this Privacy Statement to each other, if there is a legitimate reason to do so. 

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. If you choose to use the Dynamic Link feature and post information on, for instance, your carbon footprint, on your social media account, please note you have chosen to share your personal data with third parties. For creating the Dynamic Link, we use Firebase Dynamic Links provided by Google LLC so we share the personal data with Google LLC that processes the personal data in accordance with their privacy policy ( https://firebase.google.com/support/privacy ). 

In addition, we will share the total carbon footprint of the 1) User posted a specific Dynamic Link and 2) the new Users who found the Compensate mobile app through that specific Dynamic Link and calculated their carbon footprint by using the Compensate mobile app with each other.

6 Transfers to countries outside the European Economic Area (EEA)

We use service providers in several geographical locations. As far as reasonably possible to achieve, we have chosen to run our Services within the EEA.

For instance, we use Google Cloud Platform to run our Services and choose EEA as a data center location. Please see the privacy policy of Google LLC here: https://policies.google.com/privacy?hl=en-US .

In addition, Hotjar shares data with its processors some of which are located outside of EEA. Please see more information here: https://help.hotjar.com/hc/en-us/articles/360058514233-Sub-Processors-used-by-Hotjar .

However, 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.

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 gathered by Google Analytics for a period of twenty-six (26) months from each visit on our Services. The Analytics Data that has been collected by using Hotjar will be stored for twelve (12) months. If, in some exceptional cases, the Analytics Data is stored for longer than twenty-six (26) or twelve (12) 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 what is 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.

Archived versions of this statement