1 INTRODUCTION

1.1 We, Greenomy S.R.L. 0760.342.022 (“We”, “Us” or “Our”), are very happy that you want to use our sustainability management service (the “Service”), provided through our website, www.greenomy.io (the “Website”). By using our Service, you will be part of accelerating the climate transition! However, before using the Service, you must accept this privacy policy (the “Privacy Policy”).

1.2 When “you” – a natural person who is a certain Company’s (as defined in our Terms and Conditions, the “Terms”, available on the Website) designated user of the Service – use the Service, or if you make a request via the Website without having an account, we collect some of your personal data. Of course, we only do so to the extent necessary for us to be able to provide and improve the Service.

1.3 “Personal data” is any information that relates to an identified or identifiable living individual. Different pieces of information, which together can lead to the identification of a particular natural person, also constitute personal data.

1.4 We value your integrity and privacy and therefore handle personal data with utmost care. What personal data we collect and how we use and protect it is described below in this Privacy Policy (the “Privacy Policy”).

2 OUR RESPONSIBILITY

2.1 We are responsible for your personal data under the Regulation (EU) 2016/679 (“GDPR”) and other applicable data protection law.

2.2 In some regards, we are the “controller”, as defined in the GDPR, of personal data. This means that we are responsible for our processing of personal data. However, we might process your personal data upon request from someone else, such as the Company that you represent, as a “processor”, as defined in the GDPR, of personal data. The one requesting our processing of your personal data is in such cases the controller.

2.3 If you have any questions, complaints or remarks regarding what we do with your data, please contact us at hello@greenomy.io.

3 THE INFORMATION THAT WE COLLECT

3.1 When you create a User Account (as defined in the Terms) on the Website, you (or the Company) will have to provide us with the following information:

(i) Your first name and lat name,

(ii) Your e-mail address, and

(iii) A password.

3.2 You may also provide us with the following information:

(i) Your work title, and

(ii) Your telephone number.

3.3 When you use the Service, we will also automatically receive information about

(i) IP address,

(ii) The performance of your network and device,

(iii) Type of your device,

(iv) Language preferences, and

(v) Operating system, as well as

(vi) Information regarding the time and date when various requests are made.

3.4 A visitor of the Website may make requests of information, newsletters, a demo of the Service et cetera. You will be asked to provide in these cases through forms that are customized for each request. The type of data collected will thus be apparent with each collection. If we collect more data than is needed for the certain request, that information will be marked as optional and information about the intended use will be presented. You will then have the option not to provide such information. Providing such information will be considered consent. To withdraw your consent regarding such data, please send an e-mail to: hello@greenomy.io. After the request has been met, we will save and all other data provided by you for up to one year. The purpose is to contact you regarding the Services for sales-, information- and customer relation purposes (which is in our legitimate interest). If you do not wish us to save your information after making a request, please send an e-mail to hello@greenomy.io.

4 WHY WE COLLECT AND USE YOUR PERSONAL DATA

4.1 We collect and use your personal data for the following purposes and the following legal ground according to article 6.1 of the GDPR:

(i) To be able to set up your User Account (necessary to fulfill our contractual obligation),

(ii) To enable secure logins (necessary to fulfill our contractual obligation),

(iii) To provide you with important information related to the Service (necessary to fulfill our contractual obligation),

(iv) To provide you with other information, news and other content that you have chosen to receive (our legitimate interest to maintain customer relations and market our services),

(v) To conduct sales and marketing activities (our legitimate interest to market our services),

(vi) To deliver and maintain the Service and the Website (necessary to fulfill our contractual obligation),

(vii) To develop the Service and the Website (our legitimate interest to develop the Service and Website),

(viii) To provide service and support (necessary to fulfill our contractual obligation),

(ix) To obtain statistics and information regarding user behavior to improve the Service and the Website and the corresponding user experience, and

(x) To comply with legal obligations, such as preserving accounting records.

4.2 Your personal data will not be kept longer than necessary for the purpose for which it was collected.

4.3 Most of your personal data will be processed for as long as you are a registered user of a User Account, or to the extent necessary after your deregistration from such account. In this regard, please also note section 7 below.

5 LINKS TO THIRD PARTY WEBSITES

5.1 The Service and Website may, from time to time, contain links to websites provided by third parties. If you follow a link to any of these websites, we advise you to note that such websites have their own privacy policies and that we do not under any circumstances vouch for such websites or their policies. Hence, we encourage you to read the privacy policy of each website before disclosing any personal data.

6 SHARING YOUR PERSONAL DATA

6.1 We will not sell, rent or trade or otherwise share any of your personal data to any unaffiliated third party or use your e-mail address for unsolicited e-mails, unless otherwise stated in the Terms or in this Privacy Policy.

6.2 However, we may share personal data with our subcontractors to facilitate, provide the Service and the Website, and to perform the Service and the Website, or to analyze how the Service and the Website are used. In such case, we remain responsible for our subcontractors’ processing of personal data. Our subcontractors have access to personal data only to perform these tasks on our behalf and are obligated not to disclose or use personal data for any other purpose. Some of our subcontractors may be located outside the European Union. All transfers made by us are always in accordance with Chapter 5 in the GDPR, on the basis of an adequacy decision and subject to appropriate safeguards.

6.3 We use the following categories of contractors who may process your personal data

· Storage providers (servers)

· CRM-system providers

· Accounting and bookkeeping providers

· Communication providers (e-mail and chat systems)

· Marketing automation providers

6.4 Please note that we may disclose personal data to third parties if we are required to do so by applicable law, regulation or a decision from a competent court.

7 SERVER LOGS AND NON-PERSONALLY IDENTIFIABLE INFORMATION

7.1 Like most website operators, we collect non-personally identifying information that web browsers and servers typically make available, such as your browser type, language preference, referring site, and the date and time of each visitor request and eventual Requests. We will collect and share statistics about such use of the Service and the Website in an aggregated and non-personally-identifiable manner. Our purpose for collecting such information is to better understand how our visitors and users use the Service and the Website and for marketing and advertising purposes. Such information is however used in an aggregated manner and is never linked back to any personal data unless to identify anyone using the Service or the Website in an unauthorized manner.

8 YOUR RIGHTS

8.1 Briefly, you have the right to receive information about what personal data of yours we process, to make sure that this data is correct and to complain to us if you think that we do something wrong. The easiest way to contact us is by using our contact details as stated in section 11 below.

8.2 More specifically, you have the following rights:

(i) The right to, once a year without getting charged and otherwise against payment of the administrative costs, request information about what personal data we control about you,

(ii) The right to demand any incorrect personal data is corrected, or to block such data during the time when we make sure whether or not such data is incorrect,

(iii) The right to have your personal data deleted upon termination of your User Account (note that we do this automatically, but you may request a confirmation that it is done) (please note, however, what is stated in section 7 above),

(iv) The right to demand that personal data is not used during the circumstances stated in Article 18 in the GDPR,

(v) The right to have your personal data transferred to yourself or to another controller in a commonly used and machine-readable format (data portability), under certain circumstances, and

(vi) The right to file a complaint with the Data Protection Authority or other relevant authority (for contact details, see www.dataprotectionauthority.be).

8.3 In case of uncertainty about how we handle personal data, if not agreeing with how we handle personal data or in the event of other questions or complaints, please send us an e-mail to the address supplied below in section 11.

9 SECURITY

9.1 We will take all steps reasonably necessary to ensure that any personal data is treated securely and in accordance with this Privacy Policy. All personal data provided to us is stored on secure servers. Unfortunately, the transmission of any information via the internet is not entirely secure. Although we will do our best to protect personal data, we cannot guarantee the security of the personal data transmitted to our Website. Any transmission is at own risk. However, once we have received personal data, we will use strict procedures and security features to try to prevent unauthorized access.

9.2 In the event of a security breach, as soon as possible, notify you about the security breach and the measures taken by us.

9.3 Please contact us for further information regarding our security measures.

10 CHANGES TO THIS PRIVACY POLICY

10.1 Although most changes of this Privacy Policy are likely to be minor, we may change it from time to time and in our sole discretion. All changes are effective immediately upon communication. We encourage you to frequently check this page for any changes to the Privacy Policy.

10.2 We will contact you via e-mail if we make material changes to the Privacy Policy.

11 CONTACT INFORMATION

11.1 If you have any questions regarding our Privacy Policy, how we handle personal data or if you want to exercise any of your rights, please find our contact details below:

Greenomy S.R.L.

526 Avenue Louise

1050 Brussels, Belgium

Corporate Identity Number: 0760.342.022

Email address: hello@greenomy.io

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