About our services and this Privacy Policy

Single.Earth OÜ (Single.Earth) is committed to protecting the privacy and security of our users, and being transparent about how we process information about you. This Privacy Policy will inform you as to how we look after your personal data when you visit our website or use our services and describe how we process your personal information and how you can exercise your privacy rights.

Single.Earth is a deep tech start-up providing tools to invest in nature-based solutions which enable to preserve our natural carbon sinks and biodiversity as the most efficient ways to mitigate climate change.

More information about our (future) services and how you can use them can be found on our website at www.single.earth. Please take the time to also read through our Website Terms of Use when using our website. If you have any questions about this Policy, please submit your request to support@single.earth.

PLEASE TAKE A MOMENT TO READ THIS PRIVACY POLICY CAREFULLY. BY ACCESSING OUR WEBSITE AND USING OUR SERVICES, YOU ACCEPT THE TERMS OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH ANY ASPECT OF THIS PRIVACY POLICY, YOU SHOULD IMMEDIATELY DISCONTINUE ACCESS OR USE OF OUR WEBSITE AND SERVICES.

We may modify this Privacy Policy from time to time which will be indicated by changing the date at the top of this page. If we make any material changes, we will notify you by email (sent to the email address specified in your account), by means of a notice on our services prior to the change becoming effective, or as otherwise required by law.

1. How we collect personal information


Personal information is typically data that identifies an individual or relates to an identifiable individual. This includes information you provide to us, information which is collected about you automatically, and information we obtain from third parties.

The personal information we process depends on the context of your interactions with Single.Earth, your location, and applicable law. However, the personal information we collect broadly falls into the following categories:

Information you provide to us to establish an account and access our services. We ask you to provide us with some important information about yourself. This information is either required by law (e.g to go through the Know-Your-Client processes), necessary to provide the requested services (e.g. you will need to provide land ownership documents when you want to use our services as a landowner), or communicate with us in any other way (via customer support channels, email etc.) As we add new features and services, you may be asked to provide additional information. This information may include:

identification data, e.g. your photo, name, date and place of birth, address, (tax) residency, citizenship;

identity document data, e.g. photo of the document, country of issuance, number and validity;

contact data, e.g. phone number, email address;

financial information e.g bank account information, source of funds, source of wealth;

transaction data and nature of using the service, e.g. transaction sums, counter-parties;

other data used for performing customer due diligence measures, assessing trustworthiness and to prevent fraud, e.g. media coverage, occupation and connection to other persons, whether you are politically exposed person;

correspondence between you and us.

If you choose not to share certain information with us, we may not be able to serve you as effectively or offer you our services.

Information we collect automatically: In some (but not all) countries, including countries within the EEA, this information is considered personal information under applicable data protection laws. Automatically collected data may include:

Browser or device information which is collected through your device, such as Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, internet browser type and version and version of the services you are using.

Usage data which is collected whenever you interact with our service. This may include the dates and times you access the services and your browsing activities (such as what portions of the service you used). We also collect information regarding the performance of the services, including metrics related to the deliverability of emails and other communications you send through the service. If you are using our App, we may collect information about how often you use the App and other performance data. This information allows us to improve the content and operation of the service and facilitate research and analysis of the service.

Log data whereby our web servers keep log files that record data each time a device accesses those servers and the nature of each access, including originating IP-addresses and your activity in the services. We may also access metadata and other information associated with files that you upload into our service.

Cookies which allow us to collect information such as browser type and other anonymous traffic data. Please see our Cookie Policy below for more information on our use of cookies.

Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some services to, among other things, track the actions of our Users, measure the success of marketing campaigns and compile statistics about usage of the services and response rates.

Analytics, meaning the use of third-party analytic services, such as Google Analytics, which use cookies and similar technologies to collect and analyze information about use of the services and report on activities and trends. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

Information we collect from other sources: we may collect information about you from third party sources such as through your representatives, contractors who provide services to us or public sources as required or permitted by applicable law.

2.How we use your personal information


We process your personal data based on your consent, based on the applicable statutory requirements, and based on our legitimate interests. Our primary purpose in collecting personal information is to provide you with a secure, smooth and efficient experience. In some cases, mainly but not limited to anti money laundering laws and regulations and for the purposes of fighting fraud, we may be required by law to collect certain types of personal data about you. We generally use personal information to create, develop, operate, deliver, and improve our services, content and anti-fraud purposes.

We may use your personal information which we collect for the purposes and on the legal bases identified below:

Provide the services. This means using your personal information in order to provide the services’ functionality to you, such as arranging access to an account, carrying out your transactions on the platform, responding to your inquiries. We engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.

Communicate with you. We may need to communicate with you about your account and provide you with customer support to perform our contract with you for the use of the service or where we have not entered into a contract with you, in reliance on our legitimate interests in administering and supporting our services. For example, we may inform you about temporary or permanent changes to our service, such as planned outages, security or compliance notifications, information about new features, version updates, releases, abuse warnings, and changes to this Privacy Policy.

Support and improve the service. Your personal information may be used to provide, support and improve the services in order to perform our contract with you for the use of the service or where we have not entered into a contract with you, in reliance on our legitimate interests in administering and improving the service and providing certain features. For example, this may include sharing your information with third parties in order to provide and support our service or to make certain features of the service available to you.

Comply with legal obligations. We may use your personal information in order to comply with requests by public authorities court orders, or other mandatory enquiries, reporting obligations, etc.. This includes personal information necessary to provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements in reliance on our legitimate interests, and personal information necessary to prosecute and defend a court, arbitration, or similar legal proceeding.

Data analytics. Your personal information may be used to perform data analytics in reliance on our legitimate business interests in improving and enhancing our products and services.

Marketing. We may use your personal information to serve you marketing information, product recommendations and non-transactional communications (such as email or push notifications) about us, in accordance with your marketing preferences and this Privacy Policy. You can withdraw your consent at any time by clicking on the ‘unsubscribe’ link at the end of each email. Please note that withdrawing consent does not affect the lawfulness of processing based on consent before the consent was withdrawn.

Aggregated and anonymized data. Your personal information may be used to combine and anonymize data about You and Your use of the service in order to create aggregate, anonymized statistics which we may use to provide certain features within the service and for promoting and improving the service in reliance on our legitimate interests.

Under the Data Protection Act 2018 and General Data Protection Regulation (GDPR), the lawful bases we rely on for processing your information are:

Keeping to our contracts and agreements with you. We need certain personal data to provide our services and cannot provide them without this personal data.

Your consent. Where you've agreed to us collecting your personal data, for example when you have ticked a box to indicate you are happy for us to use your personal data in a certain way.

Legal obligations. In some cases, we have a legal responsibility to collect and store your personal data - for example, under anti-money laundering laws we must hold certain information about our customers.

Where we have a legitimate interest to do so, provided your rights do not override those interests.

To the extent required by applicable data protection regulation, you have the right to object to the processing of your personal data which is based on legitimate interest. See also the section “Your data protection rights” below. Withdrawing consent does not affect the lawfulness of processing your personal data based on applicable statutory requirements, mainly the applicable laws and regulations on anti-money laundering and counter-financing of terrorism.

3.Who has access to your personal data


We only share your personal data when we have a valid reason for it and we take care to allow your personal information to be accessed only by those who require access to perform their tasks and duties, and to share only with third parties who have a legitimate purpose for accessing it.

We only use service providers (data processors) that provide sufficient guarantees to implement appropriate technical and organizational security measures to protect your personal data. We have concluded appropriate data processing agreements with the service providers and shall remain responsible for their actions in respect of the processing of your personal data. Should you require more detailed information as regards the data processors we use (e.g., their names and location) please contact us via the contact details below.

Your personal data is being processed by the following categories of data recipients:

Browser or device information which is collected through your device, such as Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, internet browser type and version and version of the services you are using.

Service Providers. For providing the services, we use third parties, such as credit institutions, other payment services providers, data and cloud service providers, security and technical support providers, etc. We need to share your personal information with them to the extent we deem necessary for providing our services. Sometimes these persons need to share the personal information with further third parties (e.g. correspondent banks) and the data is processed in accordance with their data protection terms and applicable laws and regulations.

Advertising partners. We may cooperate with third party advertising platforms and social media channels to promote our services, both on our websites and third-party websites. To this effect, we may share limited personal information to achieve this purpose. For example, we and our third-party advertising partners may use cookies, pixels and web beacons and similar technologies to gather information about your activities on the website and other websites to provide you with advertising based on your browser activities and interests. For further information, please see our Cookie Policy.

Professional advisors who provide legal, compliance, insurance, accounting, or other consulting services in order to provide us advice or complete third party financial, technical, compliance and legal audits of our operations or otherwise comply with our legal obligations.

Public institution(s). Any competent law enforcement body, regulatory body, government agency, court or other third party where we believe disclosure is necessary (a) as a matter of applicable law or regulation, (b) to exercise, establish, or defend our legal rights, or (c) to protect your vital interests or those of any other person.

A potential buyer (and its agents and advisors) in the case of a sale, merger, consolidation, liquidation, reorganization, or acquisition. In that event, any acquirer will be subject to our obligations under this Privacy Policy, including your rights to access and choice. We will notify you of the change either by sending you an email or posting a notice on our website.

We will not sell your personal data to any third party.

4.How we protect and store your personal data


We take appropriate and reasonable technical and organizational measures designed to protect personal information from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the personal information. If you have any questions about the security of your personal information, you may contact us at support@single.earth.

However, we cannot guarantee that loss, misuse, unauthorized acquisition, or alteration of your data will not occur. Please recognize that you play a vital role in protecting your own personal information. When registering with our services, it is important to choose a password of sufficient length and complexity, to not reveal this password to any third-parties, and to immediately notify us if you become aware of any unauthorized access to or use of your account.

Furthermore, we cannot ensure or warrant the security or confidentiality of information you transmit to us or receive from us by Internet or wireless connection, including email, phone, or SMS, since we have no way of protecting that information once it leaves and until it reaches us. If you have reason to believe that your data is no longer secure, please contact us.

5. Your data protection rights


To the extent required by applicable data protection regulations, you have all the rights of a data subject as regards your personal data. Such rights include the following:

Access. You have the right to know which of your personal information we process.

Rectification. You may ask us to (and sometimes you are also obliged to) rectify any error in your personal data.

Erasure (the right to be forgotten). You may ask us to erase your personal information, which we will respect and comply with.

Restriction. You may ask us to restrict the processing of your personal information.

Object. You may object to the processing of your personal information.

Data portability. You may ask us to provide you or others with your personal information in a structured, commonly used and machine-readable format.

Lodge a complaint to the data protection authority. You may lodge a complaint with your applicable data protection authority regarding our collection and use of your personal information. Contact details for data protection authorities within the EU and EEA are available here.

Right to withdraw your consent. If personal information is collected or processed on the basis of consent, or if you have, for example, consented to receiving marketing emails from Single.Earth, you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Please note that the above rights may be subject to exceptions and limitations. We cannot, for example, provide personal data if it would violate our duty of confidentiality or if we have a legal obligation to retain such data. Also, certain information is necessary for us for providing the services to you and if we cannot use your information we may not be able to continue providing our services.

Exercise your rights

You may correct and/or delete personal data linked to your account yourself, in the user settings on your account page. If you wish to exercise any of the other privacy rights that applies to you, you can do this by reaching out to us on support@single.earth.

If we receive an email from you, we may ask you to verify your identity to comply with applicable law, and in order to help us respond efficiently to your request.

In certain cases, provided it is allowed under the applicable law, we may charge you an administration fee for providing you with access to the information you have asked for, but we will inform you of this before proceeding.

6.How long is your data stored


We store your personal information securely throughout the life of your account. We will only retain your personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting obligations or to resolve disputes.

Your personal data is generally retained as long as you are using the services. After you have stopped using the services and your account has been closed, your personal data shall be retained as long as any claims can be presented on the basis of such data under applicable legislation.

Certain data, e.g. data obtained for the purposes of the fulfilment of obligations related to anti-money laundering and terrorist financing prevention, or data necessary for accounting purposes, shall be retained as required under applicable legislation and industry standards. Generally, respectively at least for 5 or 7 years since the date of closing the Account, but not longer than 10 years.

7.Cookie Policy


This Cookie Policy explains which cookies and similar technologies we use on our website www.single.earth.

What are cookies?

A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the site again, the cookie allows that site to recognize your browser. This way, the information you previously provided can be retrieved, so you can easily use customized features. Cookies may store user preferences and other information to enhance your experience on the website or be used to track you when you navigate to other sites that also use services from third party cookies.

What types of cookies are used on this site and how are they used?

Strictly necessary cookies: These cookies are necessary to provide you with services available through the website.

Analytics cookies: These cookies collect information that is used either in aggregate form to help us understand how the website is being used or how effective marketing campaigns are, or to help us customise the website for you.

Preference cookies: These cookies allow the website to remember information that changes the way the website behaves or looks, such as your preferred language or the region you are in. Loss of information stored in a preference cookie may make the experience less functional but should not prevent it from working.

Marketing cookies: These cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, and in some cases selecting advertisements that are based on your interests.

We use cookies served by Google Analytics to collect limited data directly from end-user browsers to enable us to better understand your use of our Websites. Further information on how Google collects and uses this data can be found at: https://www.google.com/policies/privacy/partners/. You can opt-out of all Google supported analytics on our Websites by visiting: https://tools.google.com/dlpage/gaoptout.

We use Hotjar in order to better understand your use of our websites, to optimize our websites and to improve your experience. For further details, please see Hotjar’s privacy policy which can be found here: https://www.hotjar.com/legal/policies/privacy. We use Intercom in order to communicate with you via a chatbox on our website. For more details, please see Intercome privacy policy which can be found here: https://www.intercom.com/legal/privacy.

We use Viral Loops to manage our referral campaigns on our Website. For more details, please see Viral Loops privacy policy which can be found here: https://viral-loops.com/privacy.


Your control of cookies

You have the right to decide whether to accept or reject cookies. You can exercise your cookie preferences by indicating your preference on the cookie banner that appears when you enter our website.

Consent. If the cookie is strictly necessary for the service requested by you, your consent for the use of such cookie is not required.

We also use cookies to personalize content and to provide you with an improved user experience. By using the Single.Earth services you consent to the deployment of cookies. You can control and manage cookies using your browser (see below). Please note that removing or blocking cookies can impact your user experience and some functionality may no longer be available. If the cookie is strictly necessary for the service requested by you, your consent for the use of such cookie is not required.

Changing your cookies’ settings

You can change your cookies’ settings and delete cookies through the settings of your web browser (Internet Explorer, Firefox, Chrome, etc):

Internet Explorer
Chrome
Firefox
Opera
Safari


8.Questions and concerns


If you have any questions or comments, or if you have a concern about the way in which we have handled any privacy matter, you may contact us on support@single.earth, or by postal mail to:

Single.Earth OÜ
Telliskivi 60/2
Tallinn 10412
Estonia