Veritree Privacy Policy

Veritree Privacy Policy

Last Updated: August 17, 2023

1. INTRODUCTION

Veritree Technology Inc., having a principal address located at 230-1275 Venables Street Vancouver, British Columbia V6A 2E4 Canada (“veritree”, “we”, “us”) has created this Privacy Policy (“Privacy Policy”) in order to set out how we collect, use, and disclose Personal Data through theveritree platform available at www.veritree.com including its subpages (the “Platform”) any software applications made available by us (“Apps”)  and in the course of providing any related products and services.  This Privacy Policy also applies to Personal Data collected through any mobile applications or other sites that display this Privacy Policy and to information we collect when you engage with us in person or on social media, or otherwise interact with us (collectively with use of the Website and/or our Apps, the “Services”). Please review this Privacy Policy carefully. Any capitalized terms that are not defined herein shall have the same meaning as the veritree Terms of Service available at www.veritree.com/terms-of-service.

By using the Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy and you hereby consent to the collection, use and disclosure of your Personal Data in accordance with this Privacy Policy.

2. WHAT DOES THIS PRIVACY POLICY COVER?

This Privacy Policy covers our collection, use and disclosure of information about identifiable individuals and information which can be used to identify or can reasonably be associated or linked with an individual consumer or household (“Personal Data”).  We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:

• Contact Data includes name, email address, billing address and telephone numbers.
• Transaction Data includes details about payments from you (eg. to plant trees) and orders you have placed.
• Technical Data includes internet protocol (IP) address, your mobile device’s unique ID number, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Services.
• Usage Data includes information about how you use our Services, such as the buttons, controls, pages that you visit, the time spent on those pages, your search queries, the dates and times of your visits, but also about the webpage you were visiting before you came to our Website, App and the webpage and app(s) you go to next.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

This Privacy Policy does not apply to the practices of companies that we do not own or control, including third party organizations that may interact with you through the Services and Organizational Users who use the Platform to share information, materials and data with other users of the Platform.  This policy does not set out the information collected by Organization User or the processing or disclosure of such information by Organization Users.  Any access requests or similar from other Users of the Services in relation to content and information shared by an Organization User will be directed to that organization. 

You are responsible for ensuring that you have obtained the necessary authorizations and consents for any Personal Data you make available to us for use in accordance with this Privacy Policy.

3. COLLECTION AND USE OF PERSONAL DATA; LEGAL BASES OF PROCESSING

3.1 Profile and Transactional Information; Other Information You Provide. In order to make purchases through the Website (eg. paid subscriptions for certain types of users; tree planting funding, etc), you will need to provide certain contact and payment information to us such as your name, email address, phone number, and payment information as well as any other Personal Data requested on our purchase/transactional pages. We use this Personal Data to process your purchase requests. veritree may also keep a record of and store your past purchases and pending purchases or purchases made on your behalf by an organization.  We use this information to set-up your Impact Hub, allocate ordered trees and carry out other service-related functions in a secure and effective manner. . If you are an Organization User, your organization has a corporate agreement with veritree, and you choose to authenticate your account by linking your account with your organization, veritree may collect metadata. Although we limit the Personal Data that we request or require in connection with your use of the Services, we cannot control the content of information that you provide to us and will make commercially reasonable efforts to treat all such information pursuant to this Privacy Policy (subject to the limitations set forth herein).

3.2 Third Party Sources. We may also collect or collate Personal Data about you through:

• Organization Users’ sites which you interact with and any subpages of the Platform managed by Organization Users with which you engage;
• Publicly available sources; and
• Unaffiliated parties, such as service providers that we use, analytics companies, marketing or advertising service providers, fraud prevention service providers, and other third parties that provide us with information, so we can better understand you and provide you with information and offers that may be of interest to you.  The treatment of your Personal Data by such third parties is subject to their terms of use, privacy policies, and related practices; we take commercially reasonable steps to ensure that third parties we receive information from have received the required permissions to provide such information to us, but we are not responsible for such third parties’ compliance with their own data handling procedures or terms, or their compliance with applicable law. 

3.3 Use of Personal Data. veritree uses Personal Data to:

• authenticate access to user accounts on the Website; 
• provide, operate, maintain and improve the Services;
• provide and deliver the Services and features you request, process and complete transactions, and send you related information, including confirmations and invoices;
• respond to comments, questions, and requests and provide customer service and support;
• communicate with you about services, features, surveys, newsletters, offers, promotions, contests and events, and provide other news or information about us and our select partners;
• investigate and prevent fraudulent transactions, unauthorized access to the Services, and other illegal activities;
• personalize and improve the Services;
• monitor and analyze trends, usage, and activities in connection with the Services and for marketing or advertising purposes;
• link or combine with other information we receive from third parties to help understand your needs and provide you with better service; and 
• for other purposes which we will notify you about and seek your consent.

3.4  Legal Bases for Processing Personal Data. In certain jurisdictions we are required to notify of the legal grounds for Processing Personal Data. veritree’s legal grounds are as follows:

• To honor our contractual commitments to an individual: Some of our Processing of Personal Data is to meet our contractual obligations to the individuals to whom the Personal Data relate, or to take steps at their request in anticipation of entering into a contract with them.  For example, when a tree planting commitment is made by or on behalf of an identified individual. 
• Consent: Where required by law, and in some other cases, we handle Personal Data on the basis of consent.  For example, some of our direct marketing activities happen on the basis of opt-in consent, such as sending marketing emails to individuals who have requested them. 
• Customer support; marketing, including, in some cases, direct marketing such as via email; analyzing and improving our business and Service Offerings; and managing legal issues. We may also Process Personal Data for the same legitimate interests of our Customers and business partners.
• Legal compliance: We need to use and disclose Personal Data in certain ways to comply with our legal obligations.

4. COOKIES & INFORMATION COLLECTED AUTOMATICALLY 

When you visit the Website, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Website, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Website, and information about how you interact with the Website. We refer to this automatically collected information as “Device Information”.

We collect Device Information using the following technologies:

• “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
• “Log files” track actions occurring on the Website, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
• “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Website.

The Website uses "cookies" to collect information and improve our products and services. A cookie is a small data file that is stored on your device. Cookies cannot be used to see any other data on your computer, nor can they determine your email address or identity. 

We may use "persistent cookies" to save your registration ID and login password for future logins to our service. We may use "session cookies" to enable certain features of our service, to better understand how you interact with our service and to monitor aggregate usage and web traffic routing on our service. We also use session cookies to verify your age, keep track of items you have viewed and store such items in your cart while you are browsing.

The Website may also use technologies such as beacons, scripts, and tags. These technologies may be used for analyzing trends, administering the website, tracking users’ movements around the website, and gathering demographic information about our user base as a whole. Various browsers may offer their own management tools for removing these types of tracking technologies. We may also use third-party ad companies to help provide some of our advertising services. These third parties may place cookies on your computer and collect data about your online activities across websites or online services when you are logged into the third-party service, including for targeted advertising.

For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by using the links below:

• Facebook: https://www.facebook.com/settings/?tab=ads
• Google: https://www.google.com/settings/ads/anonymous

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

5. YOUR PERSONAL DATA ON THE PLATFORM

Public Information. Public information can be seen by anyone, including visitors that don't have an account on the Platform. This includes your username; any information you make public on the Platform (eg. your veritree profile information) and content you share on the Platform including on sub-pages and any discussion forums. Public information can also be seen, accessed, reshared or downloaded through third-party services such as search engines, APIs, apps, websites and other services that integrate with our Services.

User Decisions.  When users share and communicate using the Services, users can make decisions on what to share publicly on the Platform. For example, you can choose what goes into your public veritree profile and Organization Users can share donation information and photos of tree planting that mention contributors or participants and they may name you in their posts, some of which may be generated through the Services and some of which may be pulled into the Platform from other sources and made available by the Organizational User.   

Sharing by Individual Users.  Individual users can choose what they wish to share through the Platform by using the tools provided to update their profile, including name/username and any custom profile data such as location, content relating to the impacts an individual’s investment in ecosystem restoration is having and media from the planting sites.  Certain information is by default, public such as your name and the number of trees planted which will be visible to anyone on the Platform.   

Sharing by Organizational Users.  Organizational Users have the ability to update and share their corporate profile but also to share pdf reports, photo galleries and other audio-visual content, news feed stories, donation details and other content which they upload and transmit on the Platform and which may contain Personal Data.  veritree has no control over or responsibility for this content.  Organizational Users can also make their own decisions about what Personal Data to share. This means that if an Organizational User has Personal Data about you, such information is subject to their own privacy policies and if it is made available by the Organizational User through the Platform, it will be publicly visible to anyone on the Platform (whether they have an account or not) or the select users with whom the Organizational User has shared it with. 

6. STORAGE LOCATION AND TRANSFER OF PERSONAL DATA

veritree processes and stores its data, including Personal Data, on servers located in Canada and the United States. veritree also transfers data to the following third-party service providers described on our Sub-Processors webpage, available here: http://www.veritree.ca/subprocessors (“Sub-Processors”). By submitting Personal Data or otherwise using the Services, you agree to this transfer, storing or processing of your Personal Data in Canada and United States. You acknowledge and agree that your Personal Data may be accessible to law enforcement and governmental agencies in Canada and the United States under lawful access regimes or court order.

7. DISCLOSURE OF PERSONAL DATA WITH THIRD PARTIES

7.1 Service Providers and Business Partners. We may from time to time employ third parties to perform tasks on our behalf and we may need to share Account Information and other Personal Data with them to provide certain services. Unless we tell you differently, such third parties do not have any right to use the Personal Data we share with them beyond what is necessary for them to provide the tasks and services on our behalf. The third parties we currently engage includes third party companies and individuals employed by us to facilitate our services, including the provision of database management, payment processing and customer relationship management tools, including the Sub-Processors.

7.2 Business Transfers. If our business (or substantially all of our assets) are acquired by a third party, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Data may be made available or otherwise transferred to the new controlling entity, where permitted under applicable law.

7.3 With Your Consent. If we need to use or disclose any Personal Data in a way not identified in this Privacy Policy, we will notify you and/or obtain consent as required under applicable privacy laws. 

Our Services may provide you with the ability to post comments, review or other messages viewable to other users (“Postings”).  Where the information that you provide us with includes Postings, you provide your consent, upon their submission, to the publication of such Postings and understand that they may be publicly available.

7.4 Aggregated Information.  We may disclose to third parties certain aggregated information (that is, information that does not directly identify a particular consumer or household). This allows us to give you a more personalized experience when you use our Services. 

7.5 As Required by Law. We may disclose your Personal Data to third parties without your consent if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other users, or anyone else (including the rights or property of anyone else) that could be harmed by such activities. Further, we may disclose Personal Data when we believe in good faith that such disclosure is required by and in accordance with the law. 

We also reserve the right to access, read, preserve, and disclose any information as we reasonably believe is necessary to:

• satisfy any applicable law, regulation, legal process or governmental request; enforce our contracts or user agreement, including investigation of potential violations hereof; and
• detect, prevent, or otherwise address fraud, security or technical issues. 

The above may include exchanging information with other companies and organizations for fraud protection and spam/malware prevention. Notwithstanding the general terms of this policy, the collection, use, and disclosure of Personal Data may be made outside of the terms herein to the extent provided for in any applicable privacy or other legislation in effect from time to time, or pursuant to court orders.

8. RETENTION

We will keep your Personal Data for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally identifiable data, account recovery, or if required by law. All retained Personal Data will remain subject to the terms of this Privacy Policy.

9. RESIDENTS OF THE EUROPEAN ECONOMIC AREA (“EEA”), SWITZERLAND AND THE UK

If you are a resident of the EEA, the UK or Switzerland, you have certain additional data protection rights mandated by the laws of your jurisdiction. veritree takes reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed of what Personal Data we hold about you and if you want it to be removed from our systems, please contact us using the contact information set out below. Note that where we act as the data processor on behalf of our users, you will be required to contact the data controller directly to exercise your rights.

In certain circumstances, where we act as data controller, you have the following data protection rights:

• Request access to your Personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Data we hold about you where we are the data controller and to check that we are lawfully processing it.
• Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.
• Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. 
• Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the information's accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it. 
• Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. 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 consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the EEA.

If you wish to exercise any of the rights set out above, please contact us using the contact details below.

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.

We may also contact you to ask you for further information in relation to your request to speed up our response.

10. INTERNATIONAL USERS

Veritree is headquartered in and operated from Canada. We Process Personal Data in Canada and United States in accordance with this Privacy Policy.  Where required by applicable law, we put in place approved transfer mechanisms required or mandated by applicable law with our Sub-Processors.  

11. ACCESS, CORRECTION AND ACCURACY

You have the right to access the Personal Data we hold about you in order to verify the Personal Data we have collected in respect to you and to have a general account of our uses of that information. Upon receipt of your written request, we will provide you with a copy of your Personal Data, although in certain limited circumstances, and as permitted under law, we may not be able to make all relevant information available to you, such as where that information also pertains to another user. In such circumstances we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access and modifications in a timely manner.

We will make every reasonable effort to keep your Personal Data accurate and up to date, and we will provide you with mechanisms to update, correct, delete or add to your Personal Data as appropriate. As appropriate, this amended Personal Data will be transmitted to those parties to which we are permitted to disclose your information. Having accurate Personal Data about you enables us to give you the best possible service.

12. CALIFORNIA PRIVACY RIGHTS

12.1 CCPA. This section provides additional details about the Personal Data we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act (the CCPA).

For more details about the Personal Data veritree has collected over the last 12 months, please see the section “Information you provide us” above. We collect this Personal Data for commercial purposes described above. veritree does not sell (as that term is defined in the CCPA) the Personal Data we collect.  

Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of Personal Data we collect (including how we use and disclose this Personal Data), to delete their Personal Data, to opt out of any “sales” or “sharing” of Personal Data that may be occurring, and to not be discriminated against for exercising these rights.

California consumers may make a request pursuant to their rights under the CCPA by contacting us at the contact information below. We will verify your request using the information associated with your account, if available, including email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.

12.2 Civil Code 1798.83.  Pursuant to Section 1798.83 of the California Civil Code, California residents have the right to request from a business with whom the California resident has an established business relationship certain information with respect to the types of Personal Data the business shares with third parties for direct marketing purposes by such third party and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year.  We do not, and have not within the last 12 months, disclosed Personal Data to third parties for any third parties’ direct marketing purposes.  If you reside in California, you can prevent future disclosures for direct marketing purposes of your Personal Data, at no charge, by indicating to us your intent to opt out of such disclosures in a message addressed to the applicable contact information set forth in the “Additional Information” heading below.

13. CHILDREN’S PERSONAL DATA

We do not knowingly collect Personal Data directly from children under the age of 13 without parental consent. Our Services are not targeted to or intended for use by children. If we are informed that we have unintentionally received Personal Data from a child under the age of 13, we will delete that information. If you want to notify us of our possible receipt of information by children under the age of 13, please contact us at the contact information set forth in the “Additional Information” heading below.

14. NEVADA RESIDENTS

Under Nevada law, we are providing this notice to Nevada residents.  You may opt out of sales of your Personal Data by contacting us at the contact information set forth in the “Additional Information” heading below with a clear reference to your applicable Nevada law rights and information permitting us to verify your identity and the authenticity of your request. 

15. CHANGES TO THIS PRIVACY POLICY

We may amend this Privacy Policy from time to time. Use of Personal Data we collect is subject to the Privacy Policy in effect at the time such information is collected, used or disclosed. If we make material changes or changes in the way we use Personal Data, we will notify you by posting an announcement on our Website, within App or sending you an email prior to the change becoming effective. You are bound by any changes to the Privacy Policy when you use the Website or Services after such changes have been first posted.

16. ADDITIONAL INFORMATION

Questions regarding this Privacy Policy or veritree’s privacy practices should be directed to us at:

Privacy Officer at veritree

230-1275 Venables Street Vancouver, BC V6A 2E4

Email: [email protected]

Phone: 1-833-520-1145