Privacy Statement - Carbon Equity

Last updated: September 2024

As an Alternative Investment Fund Manager, Carbon Equity B.V. (“Carbon Equity”, “we”, “our”, “us”) processes large amounts of data from our customers. Our customers are invaluable to Carbon Equity. Therefore it is very important to ensure careful and secure processing of our customers’ data, in particular their personal data.

Through this Privacy Statement, we inform you about the way in which we process personal data of (potential) customers, business partners and website users. At Carbon Equity, we value your privacy. If you have any questions regarding our use of your personal data, you can reach out to us via the contact details provided at the bottom of this Privacy Statement.

Definitions

Account means a unique account created for You to access our Service or parts of our Service.
Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Carbon Equity B.V., Geldersekade 101-G, 1011 EM Amsterdam, North Holland. For the purpose of the GDPR (General Data Protection Regulation), the Company is the Data Controller.

Cookies are small files that are placed on your computer, mobile device or any other device by a website, containing the details of your browsing history on that website among its many uses.
Country refers to: Netherlands
Data Controller, for the purposes of the GDPR, refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
Device means any device that can access the Service such as a computer, a cell phone or a digital tablet.
Personal Data is any information that relates to an identified or identifiable individual. For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.

Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.
Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Website refers to Carbon Equity, accessible from www.carbonequity.com, my.carbonequity.com and jobs.carbonequity.com
You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable. Under GDPR, You can be referred to as the Data Subject or as the User as you are the individual using the Service.

Carbon Equity

Carbon Equity acts as the Alternative Investment Fund Manager (AIFM) of its funds and it is fully licensed pursuant to article 2:65 of the Dutch Financial Supervision Act (Wet op het financieel toezicht). Carbon Equity and the funds it manages are subject to supervision by the Authority for the Financial Markets (Autoriteit Financiële Markten) in the Netherlands. Carbon Equity is registered with the Authority for the Financial Markets with registration number 15005329. The licence allows Carbon Equity to manage investment funds which invest in one or more funds. Neither Carbon Equity nor the funds it manages are subject to regulatory supervision by any other regulatory authority than the Dutch Authority for the Financial Markets. More information about Carbon Equity can be found on the About Us page.

Our responsibilities

For all activities and purposes mentioned in this Privacy Statement, Carbon Equity acts as the controller as referred to in the EU General Data Protection Regulation 2016/679 (GDPR). Carbon Equity acts in this position because as a licensed AIFM we:

Determine which personal data must be processed for the correct processing of an investment commitment or business transaction
Determine for which other purposes the personal data may be processed as long as these purposes are in accordance with the purpose for which the personal data were obtained
Have to comply with legal obligations and requirements, for example under financial legislation and Anti-Money Laundering frameworks, and;
Have our own general terms and conditions that are directly applicable to our customers

Personal data collection and use by Carbon Equity

Personal Data

While using our service and visiting our website, we may collect or ask you to provide us with certain personally identifiable information that can be used to contact or identify you. The following personally identifiable information can be collected and used:

Special categories of sensitive personal data

Special categories of personal data, criminal data and citizen service numbers (BSNs) are sensitive data. Special categories of personal data include data about your health, biometric data, ethnic data or data concerning race, for example. As described in above table, we collect certain special categories of sensitive personal data as part of our onboarding and reporting processes.

If you give us your consent to record special categories of personal data relating to you, or you have made this information public yourself, then we will only process such information if this is necessary for the provision of our services. You can withdraw your consent for recording at any time. Please contact support@carbonequity.com for this purpose.

We only process data from minors under the age of 16 if they purchase a product from us or if the data is provided to us in the context of a product. We will seek the legal representative’s permission to further process children’s data. If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact us. If we become aware that we have collected personal data from anyone under the age of 16 without verification of parental consent, We take steps to remove that information from our servers.

We will only use your BSN if this is permitted by law, for example, in order to pass on information to the Dutch tax authority as part of FATCA/CRS reporting.

If we need to rely on consent as a legal basis for processing your information and your country requires consent from a parent, we may require your parent’s consent before we collect and use that information.

Usage Data

Usage data is collected automatically when visiting our website. Usage data may include information such as your Internet Protocol address (IP address), browser type, browser version, the pages of our service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you visit our website by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile internet browser, unique device identifiers and other diagnostic data.

We may also collect information that your browser sends whenever you visit or access our website by or through a mobile device. Carbon Equity may use personal data for the following purposes:

To provide and maintain our website, including to monitor the usage of our website.
To manage your account: to manage your registration as a user of the website. The personal data you provide can give you access to different functionalities of the website that are available as a registered user.
For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services you have purchased or of any other contract with us through the Service.
To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
To provide you with news, special offers and general information about other products, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.
To attend and manage your requests.
For business transfers: We may use your information to evaluate or conduct a merger, divestiture, restructuring, reorganisation, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by us about our website users is among the assets transferred.
For other purposes: We may use your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

Tracking Technologies and Cookies

Cookies are small text files containing limited amounts of information which are downloaded to (or read off of) your device when you visit a website through, for example, the browser of your computer, tablet, or smartphone. A cookie enables the storage and retrieval of information (potentially including personal data) on and from your device. The use of cookies makes it also possible to identify you when you visit our website again at a later moment in time. JavaScripts, web beacons and pixel tags are examples of similar techniques that can be used to collect and process information through a website. Carbon Equity uses cookies and similar tracking technologies to track the activity on and improve your experience of our service and store certain information. For more information about the cookies we use and your choices regarding cookies, please visit our Cookie Statement.

Subscription types

Carbon Equity will use your personal data (preferences) to track how they can communicate with you. Here are the different subscription types you can sign up for:

Impact in your Inbox: This subscription type allows Carbon Equity to send you its monthly Impact in your Inbox newsletter on everything climate tech investing, including one to one updates by email or phone. This subscription is optional.

Investment opportunities: This subscription type allows Carbon Equity to send you new investment opportunities and other company updates, including one to one updates by email or phone. You will automatically enroll for these after creating an account with us.

Investor updates: This subscription type allows Carbon Equity to update its investors on their investment(s) and upcoming events hosted by Carbon Equity. You will automatically enroll after confirming your investment for any product.

Personal data processing by Carbon Equity

Carbon Equity processes personal data for the purposes listed above based on your consent, for the performance of a contract, based on legal obligations, performance of tasks in the public interest and to pursue legitimate business interests. If Carbon Equity wants to process your personal data for other purposes than described above, Carbon Equity will only do so when we obtain your consent or when we have legitimate interests, if legally required. You can withdraw your consent at any time without giving reasons, or object to the processing of your personal data when we do so based on legitimate interest. Please note that withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent. You can withdraw your consent via the unsubscribe link in our e-mails, if applicable. Otherwise you can send your request to withdraw your consent to support@carbonequity.com. If, as our customer, you withdraw your consent for marketing related purposes, we may still contact you regarding product functionality or updates, security updates, responses to customer support requests or other transactional, non-marketing/administrative related purposes.

Legal Basis for Processing Personal Data under GDPR

We may process personal data under the following conditions:

Consent: You have given your consent for processing personal data for one or more specific purposes.
Performance of a contract: Provision of personal data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof.
Legal obligations: Processing personal data is necessary for compliance with a legal obligation to which we are subject.
Vital interests: Processing personal data is necessary in order to protect your vital interests or of another natural person.
Public interests: Processing personal data is related to a task that is carried out in the public interest or in the exercise of official authority vested in us.
Legitimate interests: Processing personal data is necessary for the purposes of the legitimate interests pursued by us.

In any case, we will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

We may share your personal information in the following situations:

With Service Providers: We may share your personal information with Service Providers to monitor and analyse the use of our website, to contact you.
For business transfers: We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
With Affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any other subsidiaries, joint venture partners or other companies that we control or that are under common control with Us.
With business partners: We may share your information with our business partners to offer you certain products, services or promotions.
With your consent: We may disclose your personal information for any other purpose with your consent.

Detailed Information on the processing of your personal data

The Service Providers Carbon Equity uses may have access to your Personal Data. These third-party vendors collect, store, use, process and transfer information about your activity on our website in accordance with their Privacy Policies. Carbon Equity shares your personal data with third parties if this is necessary to provide our products and services.

Analytics

We may use third-party service providers to monitor and analyse the use of our Service.

Google Analytics: Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network. You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy

Microsoft Clarity: We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioural metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.

Hubspot: HubSpot is a customer relationship management (CRM) platform that provides tools for marketing, sales, and customer service. We use HubSpot to manage our customer interactions and data, track website usage, and optimise our marketing efforts. HubSpot collects data using a variety of cookies and tracking technologies to enhance the user experience and improve the effectiveness of our marketing campaigns. Their Privacy Policy can be viewed at https://legal.hubspot.com/privacy-policy
Segment: Segment is a customer data platform. Segment tracks and gathers data about your interactions with our Service and sends this data to various tools for analytics and marketing purposes. For more information on the privacy practices of Segment, please visit their Privacy Policy: Segment Privacy Policy.
Cloudflare: Cloudflare Insights is a service provided by Cloudflare that provides insights into web traffic and performance, including metrics such as page load times, traffic sources, and other relevant data to improve the performance and security of our website. Cloudflare collects this data using cookies and other tracking technologies. For more information on the privacy practices of Cloudflare, please visit their Privacy Policy: Cloudflare Privacy Policy.
Sentry: Sentry is an error tracking service that helps us monitor and fix bugs in real-time by capturing and reporting errors and exceptions occurring in our application. Sentry collects data about the technical aspects of your interaction with our Service, including error messages, stack traces, and other diagnostic information to help improve the stability and performance of our Service. For more information on the privacy practices of Sentry, please visit their Privacy Policy: Sentry Privacy Policy.

Email Marketing

We may use your personal data to contact you with newsletters, marketing or promotional materials and other information that may be of interest. You may opt-out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.

We may use Email Marketing Service Providers to manage and send emails to you.

Hubspot: Their Privacy Policy can be viewed at https://www.legal.hubspot.com/privacy-policy

Links to Other Websites

Our website may contain links to other websites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Data retention

Carbon Equity will retain your personal data only for as long as is necessary for the purposes set out in this Privacy Statement. We will retain and use your personal data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. Carbon Equity will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our website, or we are legally obligated to retain this data for longer time periods.

Transfer of your personal data

Your information, including personal data, is processed at our operating office(s) and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. Carbon Equity shares your personal data with third parties if this is necessary to provide our products and services or if we are required to do this by law. When third parties will process your personal data on our behalf and under our strict instructions, those third parties act as so-called processors.

We transfer your personal data to third parties if we are required to do so. Examples of such third parties include national and European supervisory authorities, such as the Dutch Authority for the Financial Markets (AFM), the Dutch Data Protection Authority, the Dutch Authority for Consumers and Markets (ACM) or the Dutch tax authority. We sometimes engage other business partners as processors. As a result, they process personal data on our instructions. We will only do so if we consider these parties to be sufficiently reliable. We may only engage other parties if this is in keeping with the purpose for which we processed your personal data. Moreover, these other parties can only be engaged by us if they make specific agreements with us, have implemented demonstrably appropriate security measures and guarantee that your personal data will remain confidential.

Your consent to this Privacy Statement followed by your submission of such information represents your agreement to that transfer.

Carbon Equity will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Statement and our Privacy Policy and no transfer of your personal data will take place to an organisation or a country unless there are adequate controls in place including the security of Your data and other personal information.

Security of your personal data

The security of your personal data is important to Carbon Equity. Carbon Equity has taken various technical and organisational security measures to protect Your Personal Data and to comply with laws and regulations. We have implemented appropriate technical and organisational measures to secure the processing of personal data. These safeguards will vary depending on the sensitivity, format, location, amount, distribution and storage of the personal data, and include measures designed to keep personal data protected from unauthorised access. If appropriate, these safeguards include the encryption of communications via SSL, encryption of information during storage, firewalls, access controls, separation of duties, and similar security protocols. We restrict access to personal data to personnel and third parties that require access to such information for legitimate, relevant business purposes. Our employees, contractors and third parties who have access to personal data are bound to confidentiality. We use control mechanisms to limit access to individuals that require such data for the performance of their responsibilities and tasks. We have an Information Security Policy in place.

Please note that no method of transmission over the Internet, or method of electronic storage is 100% secure. While Carbon Equity strives to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.

Your rights under the GDPR

The Company undertakes to respect the confidentiality of your personal data and to guarantee you can exercise your rights.

You have the right under this Privacy Statement, and by law if you are within the EU, to:

Request access to your personal data. The right to access, update or delete (if not required while having an active product with us) the information we have on you. Whenever made possible, you can access, update or request deletion of your personal data directly within your account settings section. If you are unable to perform these actions yourself, please contact us. This also enables you to receive a copy of the personal data we hold about you.
Request correction of the personal data that we hold about you. You have the right to have any incomplete or inaccurate information we hold about you corrected.
Object to processing of your personal data. This right exists where we are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to our processing of your personal data on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.
Request erasure of your personal data. You have the right to ask ss to delete or remove Personal Data when there is no good reason for Us to continue processing it.
Request the transfer of your personal data. We will provide to you, or to a third-party you have chosen, your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw your consent. You have the right to withdraw your consent on using your personal data. If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of our website. We are required to hold personal data elements as long as there is a customer relationship (and during the retention period).

Exercising of your GDPR data protection rights

You may exercise your rights of access, rectification, cancellation and opposition by contacting us at support@carbonequity.com. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible.

You have the right to complain to a Data Protection Authority about our collection and use of your personal data. For more information, if You are in the European Economic Area (EEA), please contact your local data protection authority in the EEA.

Changes to this Privacy Statement

We may update Our Privacy Policy and Statement from time to time. Any changes are updated by posting the new or updated Privacy Statement on this page. The “Last updated” date on top of this page indicates the latest date of change. You are advised to review this Privacy Statement periodically for any changes. Changes to this Privacy Statement are effective when they are posted on this page.

Contact Us

Our Chief Legal and Risk Officer is responsible for monitoring the implementation of and compliance with the General Data Protection Regulation (GDPR). If you have any questions regarding our use of your personal data or about this Privacy Statement, you can contact us via support@carbonequity.com. Your questions will be handled by our support team.

If you believe that Carbon Equity has used your personal data unlawfully or if you are not satisfied with Carbon Equity’s response to your question or request, you have the right to file a complaint with the relevant Data Protection Authority (in the Netherlands, this is the Autoriteit Persoonsgegevens). More information about your complaint possibilities can be found here. For contact details of all EU Data Protection Authorities, click here.

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