Privacy Policy

Last updated: 3rd November 2022

Renoster Systems Inc., on behalf of its affiliates and subsidiaries (collectively, “us,” “we,” or “our”) has prepared this Privacy Policy (“Privacy Policy”) to describe to you (“you” or “your”) our online and offline practices regarding the Personal Data (defined below) that we collect, use, retain, and share when you access our website,https://www.renoster.co/; download, register for, or access our Renoster Carbon Credit Project Platform (the “Platform”); log into your account; subscribe to our newsletter; download our software; subscribe to one of our plans; submit an inquiry to us; or otherwise access or use the various content, features, software, or other services offered by us through the website, and related applications and software (collectively, the “Services”). Capitalized terms not defined in this Privacy Policy, shall have the meanings as defined in our Terms of Service, located athttps://www.renoster.co/terms-of-service.

We reserve the right, at any time, to modify this Privacy Policy. If we make revisions that change the way we collect, use, retain, or share Personal Data, we will post those changes in this Privacy Policy. You should review this Privacy Policy periodically so that you keep up to date on our most current policies and practices. We will note the effective date of the latest version of our Privacy Policy at the top of this Privacy Policy. Your continued use of the Services following posting of changes constitutes your acceptance of such changes.

This Privacy Policy also does not apply to information that you provide to or that is collected by any third party, even if you access such third party through the Services. Finally, this Privacy Policy does not apply to the extent that we process Personal Data in the role of a processor (or a comparable role) on behalf of our customers, including where we offer to our customers various software-as-a-service products, through which our customers collect, use, retain, share, or otherwise process Personal Data via our products. If your Personal Data has been submitted to us by or on behalf of one of our customers and you wish to exercise any rights you may have under applicable laws, please inquire with the applicable customer directly.

See below for more information about what Personal Data is, the categories of Personal Data we collect, the means of collecting Personal Data, the purpose of collection, and to whom we may disclose it and why.

  1. 1. COLLECTION OF PERSONAL DATA
    1. 1.1. Personal Data Defined. When you access our Services, we collect the information you provide to us, and certain information about your device and interaction with the website or application from which you are accessing the Services. In this Privacy Policy, we refer to any information that is related to or can identify a unique individual as “Personal Data.” Personal Data is inclusive of information referred to as “personal information,” “personally identifiable information,” and other such similar terminology as may be used under applicable privacy laws.
    2. 1.2. Categories of Personal Data We Collect. The following are categories (with non-exhaustive examples) of Personal Data we may collect about you:
      • Contact Details.We collect data such as your first and last name, email and mailing addresses, postal code, and phone number.
      • Business Data.We collect data such as the company you work for, company description, and job title.
      • Profile Data.We collect data such as your username and password, which you set to establish an online account with us.
      • Communications.We may collect or exchange Personal Data when you communicate with us, including through your questions, feedback, or other inquiries.
      • Payment and Transactional Data.We collect the information needed to complete your orders and registration on or through the Service (including name, credit card information, bank account number, billing and shipping information), and information about services you have purchased from us.
      • Cookies and Internet Activity.We collect text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, and helping us understand user activity and patterns.
      • Marketing Data.We collect your preferences for receiving communications about our products, services, activities, events, and publications and details about how you engage with our communications.
      • Other information.We may collect other information not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
    3. 1.3. Sources of Personal Data. We obtain the categories of Personal Data listed above on or through our Services from the following categories of sources:
      • Personal Data You Provide.We collect Personal Data when you voluntarily submit it to us. For example, we may collect or receive Personal Data from you when you create an account; enter Personal Data into our Platform, sign up to receive promotional communications; use or access certain products or content available through the Services; posts a review, where available; submit a request to our customer service team; interact with our social media pages; or otherwise interact with us or others through the Services. Additionally, as part of our customer service assurance practice, telephone conversations over phones may be monitored or recorded as a part of normal business operations.
      • Automatically Collected Personal Data.In addition to Personal Data that we may receive directly from you, we indirectly collect other data from you automatically through the Services. For example, we receive Personal Data when you visit our Services on any device; install or use the Platform; or enable location-based features on the Services. We may also collect Personal Data about you over time and across different websites, apps, and devices when you access the Services. We collect some Personal Data automatically using cookies or other online tracking technologies.
      • Personal Data Obtained from Third Parties.In addition to the Personal Data that we collect from you directly and automatically, we may receive Personal Data about you from other third-party sources. For example, we may receive Personal Data from our business partners, social media sites, or companies that provide Personal Data to supplement what we already know about you. We may merge or combine such Personal Data with the Personal Data we collect from you directly or automatically.
    4. 1.4. Third Party Collection. Certain third parties may use automatic information collection technologies, including cross-site tracking technologies, to collect Personal Data about you or your device. These third parties may include, but are not limited to, your internet service provider, your web browser, your mobile service provider, your mobile device manufacturer, online advertisers, and data analytics companies. We do not control these third parties or how they collect, use, or disclose your Personal Data. This Privacy Policy is not applicable to third party collection, use, retention, or disclosure of your Personal Data. If you have any questions about the privacy practices of any third party, you should contact the responsible third party directly.
      • Social Media. The Services may contain links to our accounts on Facebook, Twitter, LinkedIn or another similar social network. Clicking on any such links means that the respective social network will receive information on from which website you accessed the platform and may collect other Personal Data. It is also possible, if you are currently logged in as a user to the social network in question, that the social network will link this information to your account with the social network.
  2. 2. USE OF PERSONAL DATA

    Our primary purpose in collecting Personal Data is to provide the Services that you request. We may also use Personal Data for various purposes, including without limitation to:

    • To Provide Our Products and Services.This could include fulfilling your requests for our Services. It could also include processing purchases or other transactions. For example, if you share your Personal Data to request a price quote or ask a question about our products or services, we will use that Personal Data to respond to your inquiry. If you provide your Personal Data to purchase a product or service, we will use such information to process your payment and facilitate delivery. We may also save your Personal Data to facilitate new product or service orders or process returns. Monitored or recorded calls will be used for quality assurance and training purposes.
    • To Improve Our Products and Services.We use Personal Data to understand and analyze the usage trends and preferences of our users to make our Services better, diagnose technical issues, prevent fraud, and develop new features and functionality.
    • To Understand Your Interests.We use your Personal Data to personalize your experience on the Services and to deliver information about products and services relevant to your interests. Our Services may make suggestions for content that may be interesting to you. We use the data you provide and the data we have about other users, to make these recommendations.
    • To Process Your Payment for Products and Services.We use Personal Data to facilitate payment for products and services that you select through our Services.
    • To Respond to Your Requests or Questions.We use Personal Data to provide you with support and to respond to your requests for customer support, including to investigate and address your concerns and monitor and improve our responses. This may also include responding to your Feedback.
    • To Determine Your Eligibility and Set Up Your Account.We use your Personal Data to verify your identity or determine your eligibility for some of our products, services, and promotions. For example, this may include verifying your age, date of birth, and place of residence. If you set up an account on the Services, we will use the Registration Information you provide in relation to that account creation to create, maintain, customize, and secure your account.
    • To Market Products or Services.We provide you with information about products, services, or promotions. For example, we may use cookies or other online tracking technologies to provide customized advertisements, content, and information; monitor and analyze the effectiveness of marketing activities; and track your entries, submissions, and status in any promotions. These might be third party offers we think you might find interesting. These communications may come in the form of interest-based advertising using information gathered across multiple websites, devices, or other Services.
    • To Secure the Services.We use Personal Data to maintain the safety, security, and integrity of our Services, products and services, databases and other technology assets, business, and other users.
    • To Communicate with You.We may communicate with you about your account or our relationship. We may also contact you about this Privacy Policy or our Terms of Service.
    • As required by LawWe use Personal Data to respond to requests from law enforcement and as required by applicable law, court order, or government investigation.
  3. 3. SHARING OF PERSONAL DATA

    In addition to the specific situations discussed elsewhere in this Privacy Policy, we may share your Personal Data in the following circumstances:

    1. 3.1 Subsidiaries and Affiliates. We may share your Personal Data within our corporate group, including with our subsidiaries, parent organization, and business affiliates (that is, that control, are controlled by, are under common control with us, or with whom we share common branding) in accordance with this Privacy Policy and applicable law. We do so for the purposes of fulfilling your requests to us, performing our contract with you, providing better service to our customers, and managing warranty, repair, or customer feedback.
    2. 3.2 Service Providers. We may share your Personal Data with third parties who perform services on our behalf that are necessary for the orderly operation of the Services (“Service Providers”). Among other things Service Providers may help us perform website hosting, app design, maintenance services, database management, web analytics, app analytics, billing, payment processing, fraud protection, credit risk reduction, marketing, or any other use set out in this Privacy Policy. Access to your Personal Data by these Service Providers is limited to the information reasonably necessary for the Service Provider to perform its limited function. We require our service providers to keep the Personal Data that they are provided with confidential and to comply with all applicable laws.
    3. 3.3 Asset Transfers and M&A Transactions. We may share your Personal Data with a buyer or successor in the event of a merger, divestiture, restructuring, reorganization, 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 is among the assets being transferred, including at the negotiation stage.
    4. 3.4 Legal Compliance. We may disclose Personal Data in response to subpoenas, warrants, or court orders, in connection with any legal process, or to comply with relevant laws. We may also share your Personal Data in order to establish or exercise our rights; to defend against a legal claim; to investigate, prevent, or take action regarding possible illegal activities or fraud; to protect the safety and security of other users; or to prevent a violation of our Terms of Service. This may include sharing Personal Data with other companies, lawyers, agents, or government agencies. Nothing in this Privacy Policy is intended to limit any legal defenses or objections that you may have to a third party’s, including a government’s, request to disclose your information.
    5. 3.5 Behavioral-Based Advertising. We participate in behavioral-based advertising. This means that a third party may use technology (e.g., a cookie) to collect information about your use of our Services so that we can provide advertising about products and services tailored to your interest. That advertising may appear either on our Services, or on other websites.
    6. 3.6 Social Networking. The Services may offer you the ability to share your Personal Data through a social networking website (e.g., Facebook, Twitter), using such website’s integrated tools (e.g., Facebook “Like” button, or Twitter “Tweet” button). The use of such integrated tools enables you to share Personal Data about yourself with other individuals or the public, depending on the settings that you have established with such social networking websites. For more information about the purpose and scope of data collection and use in connection with such social networking websites or a website’s integrated tools, please visit the privacy policies of the entities that provide these social networking websites.
    7. 3.7 Public Forum and Messaging. The Services may provide you with the opportunity to post comments, messages, or reviews in a public forum. If you decide to submit Personal Data at these locations, that information will be available to other users of the Services.
    8. 3.8 Referrals. Users of our Services may recommend other users to join the Services by providing their contact information or selecting friends from a social networking website. Users may also provide information about other users of the Services such as reviews of the services or products that he or she received or reference information.
    9. 3.9 Consent. We may ask if you would like us to share your Personal Data with other unaffiliated third parties who are not described elsewhere in this Privacy Policy, and we may do so with your consent.
    10. 3.10 Partner or Client Offerings. We may jointly offer events, promotions, or any other product or service offerings with third party partners or our clients, which may be your employer. The Personal Data that you submit through an event, promotion, or other product or service offering may be combined and transmitted with the Registration Information related to your account. Third party partners or clients may collect information directly from you, which may be combined with Personal Data disclosed by us. If you decide to request, enter into, or participate in an event, promotion, or other product or service offering that is offered by us and identified as a joint effort with a third-party partner or client, the information that you provide may be shared with us and with that identified third party.
  4. 4. RETENTION OF PERSONAL DATA

    We retain your Personal Data in accordance with our data retention policies; typically, that is for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. Specifically, we retain your Personal Data:

    • Active Account.We retain your data so long as your account is active or as needed to provide you with the Services or to fulfill our contractual obligations.
    • Legal Obligations.We retain your data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
    • As Necessary.We retain your data for so long as is necessary for the purposes for which we collected such Personal Data.
  5. 5. SECURITY OF PERSONAL DATA

    No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your Personal Data from the risks presented by unauthorized access or acquisition, we cannot guarantee the security of your Personal Data. In the event that we are required by law to inform you of any unauthorized access or acquisition of your Personal Data we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

  6. 6. YOUR CHOICES

    You can make the following choices regarding your Personal Data:

    1. 6.1. Changes to Your Personal Data. We rely on you to update and correct the Personal Data contained in your account. Note that we may keep historical information in our backup files as permitted by law. If our Services do not permit you to update or correct certain Personal Data, please contact us.
    2. 6.2. Promotional E-mails.When you provide us with your e-mail address, we may send you newsletters, surveys, offers, and other promotional materials related to our Services, as well as targeted offers from third parties. You can stop receiving promotional e-mails by clicking the “unsubscribe” links in the e-mails or by contacting us as described below. If you decide not to receive promotional e-mails, we may still send you service-related communications, such as those about your account, to fulfill orders for products and services you have requested or we may deliver notifications directly to you through the Services.
    3. 6.3. Browser Settings and Managing Cookies. You can control and manage cookies in various ways. Please keep in mind that removing or blocking cookies can negatively impact the functionality of our website and your experience accessing our Services. Most browsers automatically accept cookies, but you can choose whether or not to accept cookies through your browser controls, often found in your browser’s “Tools” or “Preferences” menu. For more information on how to modify your browser settings or how to block, manage or filter cookies can be found in your browser’s help file or through websites likewww.allaboutcookies.org.
    4. 6.4. Behavioral-Based Advertising. We participate in behavioral-based advertising. This means that a third party may use technology (e.g., a cookie) to collect information about your use of our Services so that we can provide advertising about products and services tailored to your interest. That advertising may appear either on our Services, or on other websites. If you wish to limit third parties’ collection of information about your use of our Services, you can opt-out of such at theDigital Advertising AllianceorNetwork Advertising Initiativein the U.S., theDigital Advertising Alliance of Canadain Canada, or theEuropean Digital Advertising Alliancein Europe. Mobile app users may opt out of receiving behavioral-based advertising in mobile apps provided by participating members of the Digital Advertising Alliance by installing theAppChoices mobile app. PLEASE NOTE THAT OPTING-OUT OF BEHAVIORAL ADVERTISING DOES NOT MEAN THAT YOU WILL NOT RECEIVE ADVERTISING WHILE USING THE SERVICES. IT WILL, HOWEVER, EXCLUDE YOU FROM INTEREST-BASED ADVERTISING CONDUCTED THROUGH PARTICIPATING NETWORKS, AS PROVIDED BY THEIR POLICIES AND CHOICE MECHANISMS.
    5. 6.5. Do-Not-Track.Some web browsers and devices permit you to broadcast a preference that you not be “tracked” online. At this time we do not modify your experience based upon whether such a signal is broadcast.
  7. 7. INTERNATIONAL TRANSFERS OF PERSONAL DATA

    We are based in the United States of America. If you are from a country outside of the United States of America with laws governing data collection, use, and disclosure that may differ from U.S. law and you provide Personal Data to us, please note that any Personal Data that you provide to us may be transferred to the United States of America. By providing your Personal Data, where applicable law permits, you hereby specifically and expressly consent to such transfer and processing and the collection, use, retention, and disclosure set forth herein or in our Terms of Service related to the use of and access to the Services. We safeguard and enable the global transfer of Personal Data in a number of ways. For example, if you or your organization is required to enter into a contract or other binding legal act under European Economic Area (EEA), United Kingdom (UK), or Switzerland (Swiss) law with your processors, and we are acting as a processor for you (as the controller) you may request that we enter into a Data Processing Addendum with Standard Contractual Clauses by contacting us at the address listed in the section titled “CONTACTING US” below.

  8. 8. RESIDENTS OF THE EUROPE

    The following applies to individuals in the EEA or the UK.

    1. 8.1. Lawful Basis for Processing. We are required to inform you of the lawful basis of our processing of your Personal Data, which are described in the table below. If you have questions about the lawful basis of how we process your Personal Data, contact us at the address listed in the section titled “CONTACTING US” below.

      Processing PurposeLawful Basis
      • Collection of Sensitive Personal Data.
      • To Improve Our Products and Services.
      • To Market Our Products and Services.
      Processing is based on your consent.
      • To Provide Our Products and Services.
      • To Communicate with You.
      • To Understand Your Interests.
      • To Process Your Payment for Products and Services.
      • To Respond to Your Requests or Questions.
      • To Determine Your Eligibility and Set Up Your Account.
      Processing is necessary for the performance of a contract. You are subject to a contract with us and we need to use your Personal Data to provide products and services.
      • To Secure the Services.
      • As Required by Law.
      Processing is necessary to comply with our legal obligations and exercise our legal rights.
      • To Improve Our Products and Services.
      • To Understand Your Interests.
      • To Market Products or Services.
      • To Secure the Services.
      • To Use Personal Data as Otherwise Described in this Privacy Policy.
      Processing activities constitute our legitimate interests. We consider and balance the potential impact on your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent, or we are otherwise required to perform a contract or by law).

      We will use your Personal Data only for the purposes for which we collect it, unless we reasonably determine we need to use it for another reason and that reason is compatible with the original purpose. For example, we consider deidentification, aggregation, and anonymization of Personal Data to be compatible with the purposes listed above and in your interest, because the deidentification, aggregation, and anonymization of such data reduces the likelihood of improper disclosure of that data.

      PLEASE NOTE WE MAY PROCESS YOUR PERSONAL DATA WITHOUT YOUR KNOWLEDGE OR CONSENT WHEN REQUIRED OR PERMITTED BY APPLICABLE LAW.

    2. 8.2. Your Rights.European data protection laws give you certain rights regarding your Personal Data. You may ask us to take the following actions in relation to your Personal Data that we hold:

      • Access. Provide you with information about our processing of your Personal Data and give you access to your Personal Data.
      • Transfer. Transfer a machine-readable copy of your Personal Data to you or a third party of your choice.
      • Correct. Update or correct inaccuracies in your Personal Data.
      • Restrict. Restrict the processing of your Personal Data.
      • Object. Object to our reliance on our lawful basis as the basis of our processing of your Personal Data that impacts your rights.
      • Delete. Delete your Personal Data.

      Furthermore, you have the following additional rights:

      • Right to Complain.You have the right to file a complaint with the supervisory authority in your jurisdiction if you consider that the processing of your Personal Data infringes upon your rights. You can find your data protection regulator in the EEAhere. In the United Kingdom, you can find your data protection regulatorhere.
      • Right to Withdraw Consent.If we are processing your Personal Data based on your consent to do so, you may withdraw that consent at any time.

      When we receive your request, we may ask you to verify your identity before we can act on your request. We may withhold information where we are required by law to do so or if the search for that information would require disproportionate effort or have a disproportionate effect to, for example, the cost of providing the information, the time it would take to retrieve the data, or how difficult it may be to obtain the information requested.

      If you are a resident EEA and would like to exercise any of these rights, please submit your request to the address listed in the section titled “CONTACTING US” below.

  9. 9. RESIDENTS OF CALIFORNIA

    California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Services that are California residents to request certain information regarding our disclosure of Personal Data to third parties for their direct marketing purposes, if any. To make such a request, please write or email us by using the details in the Section “CONTACTING US” below. Use the words “Shine the Light” in the subject line and within the correspondence.

  10. 10. CONTACTING US

    If you have any questions or concerns about our Privacy Policy or any other privacy or security issue, please contact us at: privacy@renoster.co.