This is the General Privacy Statement, for others, see the links below:
Recruitment privacy statement
Newsletter and events privacy statement
Initial partner contact form privacy statement
Platform agreements and policies
Facebook Pages privacy statement
Facebook Pixel privacy statement
Revoke your consent for us to use non-essential cookies
GENERAL PRIVACY STATEMENT
Applicable from 7 September 2021
Compensate Operations Oy ("Compensate" or "we") is a non-profit limited liability company, incorporated under the Finnish laws, on a mission to combat climate change by offering people and different entities, such as companies and organizations (hereinafter all legal entities using our services jointly referred to as the "Company" or in plural "Companies") ways to offset the emissions of everyday life. We provide a carbon footprint test and carbon-offset services available through
In this privacy statement, we explain how we process the data of the users of our Services, our partners, our potential clients, and other business contacts.
We may also use your personal data when you are applying for a certain position at Compensate when subscribing to our Newsletter, when giving us your contact details for business purposes through a webform on our website or when participating in our events. We will process this information as set out in our Recruitment Privacy Statement, Privacy Statement for Newsletter and Events, and Initial Partnership Form Privacy Statement. Some of our Services are available only for Users that are at least 13 years old or otherwise able to agree to these Terms.
You may register to the Services by providing us with your name, email address and other relevant information as instructed on the Services. You may also use some of the Services as an unregistered user. “User” and “you” refers to both registered and unregistered users of our Services. Terms "User" and "you" also refer to the Company, if applicable.
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.
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, Suomi, 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- 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,
Business ID: 2993434-1
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 registering to our 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 website or other Services, such as Compensate mobile app.
We mainly process the following types of your personal data: User Data and Analytics Data.
2.1 User data
User Data are personal data collected directly from you or generated by our Services or us based on your use of the Services. We may collect User Data from our Users in a variety of ways, including, when they register to and use the Services, subscribe to a newsletter, apply for a job or answer our surveys. We mainly process the following User Data relating to the Users:
- 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 Services log certain Analytics Data when you visit our Services. Although we do not normally use 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 such situations, Analytics Data can also be considered personal data under applicable laws and we will treat such data as personal data.
We may collect the following Analytics Data when you visit or interact with the Services.
We collect the following information relating to the technical device you use when using the Services:
- device and device identification number, device IMEI
- IP address;
- browser type and version;
- operating system;
- name of your Internet service providers, and
- advertising identifier of your device.
We collect information on your use of the Services, such as:
- time spent on the Services;
- interaction with the Services, and
- the time and date of your visits to the Services.
If you have
- found Compensate mobile app via our social feature that enables the app users to share their personal data, such as carbon footprint (hereinafter the feature is referred to as “Dynamic Links”) or
- you have posted information about your carbon footprint on your social media account, we also process your personal data. To enable your use of the Dynamic Links we process your
- device specs and IP addresses.
In addition, we also receive certain Analytics Data from you when you use Dynamic Links. These include the information about
- when the app was first opened;
- when the app was reopened;
- 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;
- app installs.
We use the analytics information to gauge the effectiveness of our promotions and campaigns.
If you wish to revoke your consent for us to use non-essential cookies, you may
Compensate Plus Users: essential cookies
We use Compensate’s own cookies to analyze your log-in and session information. These are necessary for us to run Compensate Plus service and therefore no consent is asked for processing this data. The essential cookies we use are the following:
- Cookie: consent, Expiry: 1 year, first-party cookie (Compensate), purpose: functional
- Cookie: __stripe_sid, expiry 30 minutes, third-party cookie (Stripe), purpose: functional
- Cookie: __stripe_mid, expiry: 1 year, third-party cookie (Stripe), purpose: functional
Web analytics services
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
If you consent us to do so, we use the following cookies provided by Google:
- _ga, expiry 2 years, third-party cookie (Google), purpose: analytics. This cookie is set by Google Analytics. It allows Compensate to analyze and improve user experience.
- _ga_Q7G99FVYSV, expiry: 2 years, third-party cookie (Google), purpose: analytics. This cookie is set by Google Analytics. It helps us to analyze and improve user experience.
We use Hotjar in order to better understand our users’ needs and to optimize this service and experience of the Compensate Plus users on
For further details, please see the ‘about Hotjar’ section of
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
If you consent us to do so, we use the following cookies provided by Hotjar:
- _hjid, expiry 365 days, first-party persistent cookie, purpose: Hotjar cookie that is set when the customer first lands on a page with the Hotjar script. It is used to persist the Hotjar User ID, unique to that site on the browser. This ensures that behavior in subsequent visits to the same site will be attributed to the same user ID.
- _hjRecordingLastActivity, first-party session cookie, purpose: this should be found in Session storage (as opposed to cookies). This gets updated when a visitor recording starts and when data is sent through the WebSocket (the visitor performs an action that Hotjar records).
- _hjTLDTest, first-party session cookie, purpose: when the Hotjar script executes we try to determine the most generic cookie path we should use, instead of the page hostname. This is done so that cookies can be shared across subdomains (where applicable). To determine this, we try to store the _hjTLDTest cookie for different URL substring alternatives until it fails. After this check, the cookie is removed.
- _hjUserAttributesHash, first-party session cookie, purpose: user Attributes sent through the Hotjar Identify API are cached for the duration of the session in order to know when an attribute has changed and needs to be updated.
- _hjCachedUserAttributes, first-party session cookie, purpose: this cookie stores User Attributes which are sent through the Hotjar Identify API, whenever the user is not in the sample. These attributes will only be saved if the user interacts with a Hotjar Feedback tool.
- _hjLocalStorageTest, first-party temporary cookie, expiry under 100 minutes, purpose: this cookie is used to check if the Hotjar Tracking Script can use local storage. If it can, a value of 1 is set in this cookie. The data stored in_hjLocalStorageTest has no expiration time, but it is deleted almost immediately after it is created.
- _hjIncludedInPageviewSample, first-party temporary cookie, expiry 30 minutes, purpose: this cookie is set to let Hotjar know whether that visitor is included in the data sampling defined by your site's pageview limit.
- _hjIncludedInSessionSample, first-party temporary cookie, expiry 30 minutes, purpose: this cookie is set to let Hotjar know whether that visitor is included in the data sampling defined by your site's daily session limit.
- _hjAbsoluteSessionInProgress, first-party temporary cookie, expiry 30 minutes, purpose: this cookie is used to detect the first pageview session of a user. This is a True/False flag set by the cookie.
- _hjFirstSeen, first-party session cookie, puprose: this is set to identify a new user’s first session. It stores a true/false value, indicating whether this was the first time Hotjar saw this user. It is used by Recording filters to identify new user sessions.
- hjViewportId, first-party session cookie, purpose: this stores information about the user viewport such as size and dimensions.
- _hjRecordingEnabled, first-party session cookie, purpose: this is added when a Recording starts and is read when the recording module is initialized to see if the user is already in a recording in a particular session.
LinkedIn Insight Tag
Payment Processing and Customer Data Handling
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).
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).
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.
4 Legal grounds for the processing
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
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
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.
In addition, Hotjar shares data with its processors some of which are located outside of EEA. Please see more information here:
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
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
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 (
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.