Commitment For Protecting Your Privacy
We know that providing personal information is an act of trust and we take that seriously.
Using our service means that you’ve read and agreed to what’s written here, so please take a moment to go over it.
We will never, ever, not in a million years, sell your data to others, or use it for purposes other than our main business!
Keeping your personal information secure is incredibly important to us, and we invest a lot of effort in protecting it.
We only collect information in accordance with the applicable data protection laws based on your location during registration.
The data we collect is simply used to conduct our business of saving the planet, to improve our products and to help us with marketing!
And now, for the legal version...
Last updated: October, 2020
I. Personal Data Responsibility
Responsibility for the personal data processing falls on:
Club Leaf B.V.
Manager: Roelien Ruys
Where this data protection declaration speaks of “we” or “us”, this relates in each case to the aforementioned company.
Our Data Protection Officer can be contacted via the email set out above.
II. Basic Principals
We only process your personal data in compliance with the data protection regulations, where a statutory provision allows us to do so, or where you have granted consent. This also applies during the processing of personal data for marketing and advertising purposes.
In the scope of our Internet Services, we also collect information that, taken as such, does not allow any identification of you in person. In certain cases – in particular in combination with other data – this information may still be regarded as “personal data” in the sense of the data protection laws. Further, we, by way of the Internet Services, also capture such information that does not allow us to identify you either directly or indirectly; this is e.g. the case for aggregated information on all users of this Website.
III. Which data is processed by us? For which purposes and under what legal basis is the processing in effect?
When downloading the App, information is transmitted to the App Store. We are unable to influence this kind of collection of data and are not responsible for it. We will only process this data to the extent required for the downloading of the App onto your mobile device.
Further, you may access certain public parts of our Internet Service without providing us with your personal details (such as your name, postal address, or your email address). Also in this case, we need to collect and store certain information in order to enable your access to our Internet Service. On our Website and in our App, we use certain analysis tools and have integrated functionalities via third party providers. Further, we offer certain functionalities on our Internet Service for which we need to collect personal data.
We collect and process personal data on our Internet Service to the following extent:
1. Logfiles: If you visit our Website, our web server will automatically store data and information relating to the device and browser you use. This could include technical information such as browser, system type, and IP-address. We process this technical information in the logfiles of our systems. We process the technical information in order to enable your access to our Internet Service, to secure the functionality of our Internet Service and the security of our IT systems, and to optimize our Internet Service. The legal basis for this data processing is Art. 6 para. 1 lit. f GDPR.
2. Registration: Within the scope of our Internet Service, we offer you the option to register. This is necessary in order to create your account. For this, we request your name, email address, and further details about you.
3. Carbon Footprint Calculation: If you have given us permission, we will set up your own personal carbon account. We will do this by asking you a set of questions. These may include details on how and how often you travel, your eating habits and your lifestyle in general.
4. Contact after the registration process started: If you have already started to enter details including your email address, but have not completed it, we may contact you to remind you to complete your registration, provided you have consented to getting product updates and offers from us. The legal basis for this is therefore your consent according to Art. 6 para. 1 lit. a GDPR. You can always request to unsubscribe from further non-essential emails from us.
5. Contact support: You can also contact us through the contact form on the website or by calling us. We collect all the data you provide and store it insofar as necessary to process your request. Calls may be recorded for quality and training purposes. If necessary, data will be stored longer after completion of processing for reasons of preservation of evidence. The legal basis is Art. 6 para. 1 lit. a, b, f GDPR.
6. Advertising information by email: If you have agreed to receive product updates and offers from us, we will process your email address, and potentially, information included in your account based on your corresponding consent, in order to be able to send you information with regard to our services, offers, and You can always request to unsubscribe from further non essential emails from us. Your personal data in connection with an email subscription will not be disclosed to third parties for any purpose other than to allow us to technically send out communications and analyze the results of our communications through our technical providers. We will process your data exclusively for the selection of individualized content and for sending out product updates and offers within the scope of your consent granted. The legal basis is Art. 6 para. 1 lit. a GDPR.
7. Statistical evaluations: Where necessary, we assess your personal data for the purpose of evaluating your preferences to enable interest-orientated marketing, individual addressing, and a continuous optimization of our business processes in a statistical form. We do this in order to get a better understanding of what our customers expect from us. Our processing is based on Art. 6 para. 1 lit b f GDPR.
8. Job Applications: If you apply for a job posting, we collect information necessary to process your application or to retain you as an employee. This may include, among other things, government identification numbers, contact information, and educational history. We have a legitimate interest in evaluating candidates for potential employment. Our processing is based on Art. 6 para. 1 lit b f GDPR.
9. Social Plug-ins: On our Website, we use plug-ins of social network sites that allow you to conduct activities with regard to content on our Internet Service (also "Social Plug-Ins"). If you are registered in the respective social network and logged in to it, you may communicate directly with the social network. You may also prevent the loading of Social Plug-Ins with add-ons for your browser e.g. with the script blocker "NoScript" (http://noscript.net/). The legal basis for the provision of social plug-ins on our Internet Service is your consent Art. 6 para. 1 lit. a GDPR.
12. Referral program: Further, we might offer you the possibility to join a refer-a-friend program. You will receive a personal link which you send to your contacts. We will register which contacts have successfully used your link and any necessary information in order to perform the refer-a-friend program. The legal basis for this is therefore the performance of our agreement regarding the refer-a-friend program.
13. Further legitimate interests: Where required, we may process your data beyond the purposes mentioned above, for the purpose of maintaining our legitimate interests or for the interests of third parties; this is based on Art. 6 para. 1 lit. f GDPR. Some of our legitimate interests are
a.) the assertion of legal claims and defence of legal disputes;
b.) the prevention and the solving of crimes;
c.) the steering and the further development of our business activities including risk management;
d.) the prevention of fraud;
e.) the ability to identify and resolve technical bugs in the system;
f.) the ability to provide customer support (which is also based on the customer's consent pursuant to Art. 6 para. 1 lit. a GDPR); and the possible sharing of information as part of a corporate transaction or merger;
g.) and the possible disclosure of information in the context of a corporate transaction or merger.
On our Website, we use short-term as well as permanent cookies.
Short-term cookies, such as, in particular, so-called ‘session cookies’ are deleted in an automated manner upon leaving our Website. These store a so-called ‘session ID’ by which different requests are allocated to the website. By this, your device will be recognized when you use our Website again. The session cookies will be deleted when you log off or close your browser.
Permanent cookies will be deleted after a certain time in an automated manner, which may be different depending on the cookie. You may configure the settings of your operating system, to prevent e.g. the acceptance of third party cookies, or of all cookies.
In our app, we use different Software Development Kits ("SDKs") that provide us with data about your usage through our third parties providers. If you would like to avoid this data collection, you will need to close the app and use our website instead. In any case you can always contact our customer service through the website as an alternative to performing in app features.
On the Website, you may prevent the use of third party cookies by way of other measures as explained below.
Please note that if you have accessed other websites from the Club Leaf operating outside of the EU or have agreed to accept cookies from this site in the past, you may have received cookies. If you wish to remove these cookies, please refer to the "manage cookies" section.
Further information on the cookies used by us, their purpose, and legal basis have been compiled by us for you below. Please note that some cookies are necessary for the functioning of our website and therefore cannot be disabled (‘Essential Cookies’). Other cookies are used by us for analytics and marketing purposes and these may be disabled from our cookie banner when you first log into our website. Further information on online advertising cookies, and on how to prevent their use, can be found on the following websites:
- http://www.aboutads.info/choices/ (only available in English)
- http://www.networkadvertising.org/choices/ (only available in English)
a.) Advertising Networks: We may in particular use third party providers such as advertising networks and advertising exchange programs which enable us to include advertising for you on the sites of third parties. The operators of these external advertising networks and advertising exchange programs may, in the case of you consenting, use third party cookies, pixel or similar technologies in order to collect data (Art. 6 para. 1 lit. a GDPR). In some cases, we will place cookies or a pixel on our own site in order to identify cases where a user gets to our Website through advertising placed on another website and completes certain activities (e.g. registration) for the purpose of remuneration of the advertising partner, in which we have a legitimate interest (Art. 6 para. 1 lit. f GDPR).
On our instruction, Google uses the transmitted data to evaluate your use of our internet presence, compile a report on the activities on the Website, as well as to render further services for us regarding the use of our Websites. (Therefore, there is a commissioned data processing agreement in place between us and Google). The use of Google Analytics therefore serves the purpose of continuously improving our internet presence and to optimise your user experience. These activities are in our legitimate interest regarding the data processing (Art. 6 para. 1 lit. f GDPR). Further, by clicking a button on our cookie banner on our Internet Service, you expressly agree to the processing of the collected data by Google in the manner, and for the purposes as described above (Art. 6 para. 1 lit. a GDPR).
If you wish to deactivate or change Google Analytics only in respect of the presentation of content tailored to your interests, including advertising, this can be adjusted under “Google adverts on the web” in the settings for Google Adverts.
Further information regarding the purpose and scope of the data collection as well as regarding the further processing and use by Google, including information on your rights or, as applicable, options for configuration for the protection of your personal data can be found under the following links: http://www.google.com/analytics/terms/nl.html as well as under https://policies.google.com/privacy?hl=nl-NL.
c.) Google Tag Manager: We also use Google Tag Manager. With this service, website tags can be administered via an interface. Google Tag Manager solely implements tags. This means that Google Tag Manager does not place any cookies and no personal data is collected. Google Tag Manager triggers other tags that potentially collect data, but Google Tag Manager does not access this data. If, at domain or browser level, a deactivation of certain websites is affected (see details on the deactivation of cookies given above), this remains in place for all tracking tags to the extent that these are implemented with Google Tag Manager.
d.) Google AdWords / conversion tracking: On our Internet Service we also use, having gained your consent, (Art. 6 para. 1 lit. a GDPR) the online advertising program "Google AdWords,” and within the scope of this, its conversion tracking. With this, Google AdWords inserts a cookie or a pixel on your computer or, as applicable, on the storage of your mobile device, if you were directed to our Internet Service via a Google advert. These cookies are no longer applicable after 30 days. They do not serve for any personal identification. If the user visits certain pages of our Internet Service and the cookie is still active, both we as well as Google are able to see that you clicked on the advert and were forwarded to our site. We, as well as all other clients of Google-AdWords, receive different cookies. The cookies affected by our Google adverts can therefore not be followed beyond our Internet Service.
The information obtained from the conversion tracking serves to compile statistics on the conversion for us. With this, we learn about the total number of users who clicked on an advert and were forwarded to a site provided with a conversion tracking tag. However, we do not receive any information that would allow your potential identification.
If you do not wish to take part in conversion tracking, you may deactivate the conversion cookie in the settings of your browser. More information on this can be obtained from the Google Data Protection Statement.
You may also adjust your settings for Google Advertising in the Google settings for advertising.
16. Are you obliged to provide us with your data?
The details required to create an account, as well as the registration for information by email, are in the respective areas of the Internet Service (e.g. in an online form) and marked as mandatory information; without providing the mandatory details, we are unable to allow you the use of the respective functionality.
17. Who will receive your data?
Depending on the type of personal data that is processed by our company, only certain departments / organizational units have access to your personal data. These include, in particular, our expert departments concerned with the provision of our services and our IT department. Based on the concept of roles and entitlements, the access is, within our company, limited to those functionalities and such scope as is required for the respective purpose of processing.
We may also transfer your personal data within the legally-allowed scope to third parties outside of our company.
We will transfer your data to external recipients only insofar as this processing is necessary for purposes as permitted by law.
18. Is data transmitted to countries outside the EU / EEA?
In certain cases, there may be a transmission of information to recipients in so-called “Third Countries.” Third Countries are countries outside of the EU or the EEA, and it cannot automatically be assumed that their data protection levels are in line with those in the European Union.
VII. How long will your data be stored?
In general, we will store your personal data only as long as we have a legitimate interest in this storage, and your interests in discontinuation do not overtake the legitimate interest.
Additionally, without any legitimate interest, we may continue to store your data where we are statutorily obliged to do so (e.g. for the purpose of fulfilling archiving requirements). We will delete your personal data without any action from your side, as soon as access to the data is no longer necessary to fulfil the purpose of processing, or the storage is otherwise illegal.
The personal data we need to store for the purpose of compliance with retention duties will be stored until the end of the corresponding retention period. Where we store personal data exclusively for the purpose of fulfilling archiving duties, it is normally blocked so that access is only possible where this is required with regard to the purpose of the retention duty.
19. What are your rights?
a.) Right to object according to Article 21 GDPR:
You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you, based on Article 6 para. 1 lit. e or f GDPR, including profiling according to Art. 22 GDPR based on those provisions. In the event of your objection, we will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or where the processing serves for the establishment, exercise or defence of legal claims.
Where we process your personal data for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. Where you object to processing for direct marketing purposes, the concerned personal data shall no longer be processed for such purposes.
You have the possibility, in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to exercise your right to object by automated means using technical specifications.
c.) Further rights of affected persons: Based on the following provisions, you as a data subject have the right:
to obtain access and information on your personal data which is processed, Art. 15 GDPR;
to have incorrect or incomplete personal data corrected, Art. 16 GDPR;
to request deletion of your personal data, Art 17 GDPR;
to request a restriction of the processing of your personal data, Art 18 GDPR; and
to data portability (this means that you have the right to receive your personal data which you have provided to us, in a structured, commonly used and machine-readable format and you may transmit your data to another controller), Art. 20 GDPR.
Further, you are entitled at any time to file a complaint with the responsible supervisory authority for data protection, Art. 77 GDPR. In the Netherlands the supervisory authority is the Dutch Data Protection Authority.