Privacy policy

This Policy applies as between you, the User of this Web Site and Greenomy Academy the owner and provider of this Web Site. This Policy applies to our use of any and all Data collected by us in relation to your use of the Web Site and any Services or Systems therein.

1. Introduction

This Greenomy privacy policy governs the collection, storage and use of your personal data as a user of our sustainability management service (the "Service") or as a visitor of our website www.greenomy.io (the “Website”). It provides you, as a user or visitor, with details about the personal data we collect from you, how we use it and your rights to control personal data we hold about you.
With reference to the definition of Art. 4 No. 1 of Regulation (EU) 2016/679 (hereinafter referred to as "General Data Protection Regulation" or "GDPR" for short), the term "personal data" means all data relating to you personally are obtainable. This includes, for example, name, address, email address and user behaviour. With regard to other terms, in particular the terms "processing", "person responsible", "processor" and "consent", we refer to the legal data protection definitions of Art. 4 GDPR.

In principle, we only process personal data insofar as this is necessary to provide a functional website and the content and services we offer. The processing of personal data takes place regularly only if you give us your consent within the meaning of Art. 6 Para. 1 lit. a) GDPR or the processing is based on statutory provisions, in particular through one of the items listed in Art. 6 Para. 1 lit. b) to lit. f) GDPR is permitted.
Your personal data will be deleted or blocked as soon as the purpose of storage no longer applies. Storage can also take place if this has been provided for by national or European regulations to which we are subject. In this case, the data will be blocked or deleted when the storage period prescribed in the respective regulations has expired. The latter does not apply if further storage of the data is necessary for the conclusion or performance of a contract.

2. Our Responsibility

As data controller, we are responsible for your personal data under the Regulation (EU) 2016/679 (“GDPR”) and other applicable data protection laws.
The supervisory authority responsible for data protection for us is the Belgian Data Protection Authority - l’Autorité de Protection des Données.
If you have any questions, complaints or remarks regarding what we do with your personal data, please contact us at privacy@greenomy.io

3. Responsible Authority

The person responsible within the meaning of Art. 4 No. 7 GDPR, the other data protection laws applicable in the member states of the European Union and other provisions as well as provisions with a data protection character is:
  • Alexander Stevens, Greenomy S.R.L
  • 54 Avenue Louise
  • 1050 Brussels, Belgium
  • Corporate Identity Number: 0760.342.022
  • Email: alex@greenomy.io
  • Telephone: +32 478 084 088

4. The personal data that we collect

Category of Personal Data Source
First name and last name, e-mail address, password, work title, telephone number Provided by you when you create a User Account on the Website
IP address, the performance of your network and device, type of device, language preferences, operating system and information regarding the time and date when various requests are made Automatically collected by us when you use the Service
First name and last name, e-mail address, password, work title, telephone number Provided by you when you request information, a demo of the Service, etc via a form on our Website.
First name and last name, e-mail address, password, work title, telephone number Provided by you when you request newsletters or other forms of direct marketing via electronic means of communication.

5. Why we collect and use your personal data

We collect and use your personal data for the following purposes and the following legal ground according to article 6.1 of the GDPR:
Purpose Legal Ground
To be able to set up your User Account Art. 6.1.(b) GDPR - necessary for the performance of a contract
To enable secure logins Art. 6.1.(b) GDPR - necessary for the performance of a contract
To provide you with important information related to the Service Art. 6.1.(b) GDPR - necessary for the performance of a contract
To provide you with other information, news and other content that you have chosen to receive Art. 6.1.(a) GDPR – consent
OR
Art. 6.1.(f) GDPR - our legitimate interest to maintain customer relations and market our services
To conduct sales and marketing activities Art. 6.1.(f) GDPR - our legitimate interest to market our services
To deliver and maintain the Service and the Website Art. 6.1.(b) GDPR - necessary for the performance of a contract
To develop the Service and the Website Art. 6.1.(f) GDPR – our legitimate interest to develop the Service and the Website
To provide Service and support Art. 6.1.(b) GDPR - necessary for the performance of a contract
To obtain statistics and information regarding user behavior to improve the Service and the Website and the corresponding user experience Art. 6.1.(f) GDPR – our legitimate interest
To comply with legal obligations, such as preserving accounting records Art. 6.1.(c) GDPR – necessary for compliance with a legal obligation
To send direct marketing communications via electronic means  Art. 6.1.(a) GDPR – consent 
OR
Art. 6.1.(f) – our legitimate interest but only for existing customers and impersonal addresses of legal entities

6. Links to Third-Party Websites

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.

7. Sharing your Personal Data Your Right to Withhold Information

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.
However, we may share personal data with our sub-processors 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 sub-processors 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.
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

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.

8. Server Logs & Non-Private Data

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 unauthorised manner.

9. Your rights

You have the following rights towards us with regard to your personal data:

● the right to information,
● the right to correction and deletion,
● the right to restriction of processing,
● the right to object to processing,
● the right to data portability.

You also have the right to complain to a data protection supervisory authority about the processing of your personal data by us.

10. Additional/Natural processing

If you visit our website without registering or otherwise providing us with information ("informational use"), we only collect the personal data that your web browser transmits to our server. If you would like to view our website, we collect the following data, which is technically necessary for us to enable you to display our website and to ensure stability and security:
● IP address
● Date and time of the request
● Time zone difference to GMT
● Website content
● Access status (HTTP status)
● Amount of data transferred
● Website from which you accessed our website
● Web browser
● Operating system
● Language and version of the browser
● The aforementioned data are also stored in so-called log files on our servers. This data is not stored together with other personal data about you.

The collection and temporary storage of the IP address is necessary to enable our website to be delivered to your end device. To do this, your IP address must be stored for the duration of your visit to our website. The storage of the above-mentioned data in log files serves to ensure the functionality and optimization of our website as well as to ensure the security of our information technology systems. An evaluation of this data for marketing purposes does not take place.
Our legitimate interest in data processing lies in the above purposes. The legal basis for the collection and temporary storage of the aforementioned data and the log files is Art. 6 Para. 1 S. 1 lit. f) GDPR.
The above data for the provision of our website will be deleted when the respective session is over. The collection of the above data for the provision of our website and the storage of this data in log files is essential for the operation of our website. There is no possibility of objection.

11. Further functions on our website

In addition to the informational use of our website as described above, we offer various services that you can use if you are interested. For this, it is usually necessary to provide further personal data. We need this data to provide the respective service. The above data processing principles apply. In some cases, we use external service providers who have been carefully selected and commissioned by us to process this data. These service providers are bound by our instructions and are regularly checked by us. As far as personal data is passed on to third parties in the course of services that we offer together with partners, you can find more information in the following descriptions of the individual services. If these third parties are based in a country outside the European Economic Area, you can find more information about the consequences of this circumstance in the following descriptions of the individual services.

12. Further functions on our website

If you contact us by e-mail, the personal data you send us with your e-mail will be saved. We also have a contact form on our website that you can use to contact us. The data you enter in the input mask will be transmitted to us and saved.
● Salutation
● First name
● Surname
● E-mail address
● Phone

The data will only be used to answer your questions. Unless explicitly stated in this data protection declaration, the data will not be passed on to third parties. In addition, we record your IP address and the time of sending.
The processing of the above personal data is only used to process your inquiries. The processing of further personal data that arise through the use of the contact form provided on our website serves to prevent misuse and to ensure the security of our information technology systems.
This is also where our legitimate interest in processing your personal data lies. If you have given us your consent for this, the legal basis for processing this data is Art. 6 Para. 1 lit. a) GDPR. Otherwise, the legal basis for processing this data is Art. 6 Para. 1 lit. f) GDPR, especially in the event that your data is transmitted to us by sending an email. If you want to work towards the conclusion of a contract through your email, Art. 6 Para. 1 lit. b) GDPR is an additional legal basis.
Subject to statutory retention periods, the data will be deleted as soon as we have finally processed your request. If you contact us by email, you can object to the storage of your personal data at any time. We would like to point out that in this case your request cannot be processed any further. You can declare your revocation or objection by sending an email to our email address given in the legal notice.

13. YouTube

We include videos from "YouTube", a social media platform of Google Ireland Limited, Google Building Gordon House, Barrow St, Dublin 4, Ireland (hereinafter referred to as "Google") on the websites of our website. When you visit a website that includes a video from YouTube, data is transmitted to a Google server and stored there. If you have a user account with Google and are registered, Google can assign the visit to your user account. Google stores this data as a usage profile and uses it for advertising, market research and / or needs-based design of its websites. Such an evaluation takes place in particular (also for users who are not logged in) to display needs-based advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of these user profiles. Please contact Google directly. We integrate content from YouTube on the websites of our website in order to make this content immediately available to you without you having to call up the content separately on YouTube. This means that you can already use the functions of the social media platform YouTube on our website. This allows us to improve our offer and the user experience for you and make it more interesting. This also includes our legitimate interest in the processing of the above data by the third-party provider. The legal basis is Art. 6 Para. 1 S. 1 lit. f) GDPR. If you want to prevent data transfer, you cannot use the functions of YouTube. Regardless of this, we recommend that you regularly log out of your local user account after using a social network, but especially before activating integrated content, as this allows you to avoid being assigned to your profile with the respective provider. Third party information: Google Ireland Limited, Google Building Gordon House, Barrow St, Dublin 4, Ireland

Further information on data protection and data usage by Google can be found on the following Google website: https://policies.google.com/privacy

14. Retention period

We store personal data as long as necessary to carry out a service you have requested or to which you have given your consent, unless we are subject to other legal obligations such as commercial or tax law retention periods or those related to ongoing court proceedings.

15. Security

We will take all reasonable and appropriate technical and organizational measures necessary to ensure that any personal data is treated securely and protected against unauthorized or unlawful processing and against accidental destruction, loss or damages and in accordance with this Privacy Policy.
As a rule, any data is stored on servers within the European Union. The geographical location of the infrastructure (primary and backup) and of the services and support centers of our current cloud hosting services provider is Frankfurt, Germany.

16. Changes to this privacy policy

Although most changes of this Privacy Policy are likely to be minor, we may change it from time to time and at 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.
We will contact you via email if we make any material change to the Privacy Policy.

17. Contact information

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.
54 Avenue Louise
1050 Brussels, Belgium
Corporate Identity Number: 0760.342.022
Email address: privacy@greenomy.io