Privacy Policy

Last updated: August 21, 2024

Introduction and Definitions
This Privacy Policy (the "Policy") describes how Carbon Direct Inc. ("Carbon Direct", "we", or "our") collects, uses, and protects your data in connection with your use of the Site or our Services (as defined below). Carbon Direct values privacy and respects the importance of safeguarding data.  

This Policy is intended to help you understand how we collect and use your Personal Data, as well as how we share, store, and protect that data. By visiting our Site or using our Services, you accept the practices described in this Policy and consent to our collection, use, and potential disclosure of your information. This may include personally identifiable information, as described below. If you do not agree to the practices and users described in this Policy, please do not use our Site or Services. 

Scope and Limitations
This policy applies to the Carbon Direct website located at https://www.carbon-direct.com and any other Carbon Direct websites, domains, or subdomains (collectively, the "Site") and any services or deliverables, including carbon removal credits (collectively, "Services"). As used throughout this Policy, "Personal Data" refers to any information that on its own, or in combination with other available information, can identify an individual.

This Policy does not apply to third-party websites, domains, applications, services, products, or platforms that may be accessed through links we may provide. Such sites are owned and operated independently from Carbon Direct, and have their own separate privacy and data collection practices. Any Personal Data you provide to such websites will be governed by the third-party's own privacy policy. Carbon Direct cannot accept liability for the actions or policies of independent sites, and is not responsible for their content or privacy practices. 

We carefully analyze what types of information we need to provide our Services, and we try to limit the information we collect to only what we really need. Where possible, we delete or anonymize this information when we no longer need it. When building and improving our Services or Site, our engineers work closely with our privacy and security teams to build with privacy in mind. Our guiding principle is that your information belongs to you, and we aim to only use your information to your benefit.

Data Collected
Carbon Direct is committed to the lawful, fair, and transparent collection and use of Personal Data. We collect Personal Data when you voluntarily provide it to us in connection with your use of our Services. We may also receive information you provide about others, or we may receive information that is collected automatically. For example, you may give us: your name, email address, and areas of interest if you choose to receive newsletters, updates, or other information from us; 

  • your contact information and any other Personal Data you choose to include, if you email, text, or contact us through our Site; 

  • any Personal Data contained in, or included with, any requests for Services, including proposal documents, feedback, comments, photos, or other media or information you submit via online portals, forms, surveys, or interactive portions of our Site;

  • your password; and

  • any other information that you share with us or provide access to, including Personal Data which may identify you individually. 

It is always your choice whether to provide this Personal Data. However, some Personal Data must be provided to use the Site or our Services, including to access specific information, to purchase through our Site or to sign up for a newsletter. The decision not to provide information might limit or eliminate such functions of our Site or our ability to provide you Services. 

Do not provide Personal Data about others unless you are authorized or required to do so by contract or applicable law. You may provide Personal Data on behalf of another person. By using the Site and Services, you assume full responsibility for obtaining consent and represent to Carbon Direct that you have obtained all necessary permissions to provide such information to us. We reserve the right to ask you to provide evidence of that notice and consent.

Data Security
Carbon Direct has put in place appropriate organizational safeguards and security measures in place to protect Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered, or disclosed. We require any third party who is contracted to process your Personal Data on our behalf to have the same or higher security measures in place to protect your data and to treat such data in accordance with all applicable laws. In the unfortunate event of a Personal Data breach, we will promptly notify you and any applicable regulator when we are legally required to do so.

If a third party requests your personal information, we will refuse to share it unless you give us  express permission to do so or we are legally required. When we are legally required to share your personal information, we will tell you in advance, unless we are legally forbidden. If you have any questions regarding our data security and protection, please feel free to reach out to security@carbon-direct.com.

Protection
As the transmission of data via the internet is not completely secure, we cannot guarantee the security of your information transmitted to our Site and any such transmission is at your own risk. However, we maintain appropriate technical and organizational measures, including performing regular self-assessments, to prevent unauthorized disclosure of, or access to, Personal Data. We limit access to Personal Data and require that employees authorized to access Personal Data maintain the confidentiality of that data.How you can access and control your data.

Privacy Regulations
Carbon Direct is committed to protecting privacy in accordance with the highest level of privacy regulation. As such, we work to comply with at least the following regulations:

  • California's Consumer Privacy Act ("CCPA") / California Privacy Rights Act ("CPRA") and California Online Privacy Protection Act ("CalOPPA")

  • Canada's Personal Information Protection and Electronic Documents Act ("PIPEDA"), and applicable provincial legislations

  • European Union's General Data Protection Regulation ("GDPR")

  • United Kingdom General Data Protection Regulation ("UK GDPR")

Processing
This Policy applies when you interact with Carbon Direct through any of the following:

  • make use of our website and services; and

  • receive any communication from us including newsletters, emails, calls, or text messages. 

In these instances, the Carbon Direct is the controller, rather than processor of your information, and responsible for your Personal Data.

Legal Bases Under the GDPR and UK GDPR
If you are accessing our Services or Site while in the European Economic Area or the United Kingdom, we will collect Personal Data only if we have one or more legal bases for doing so under the GDPR or UK GDPR. The legal bases depend on your interaction with us and our Site. This means we collect and use your Personal Data only where: 

  • you have given your express consent for one or more specific purposes; 

  • it is necessary to perform a contract we are about to enter into or have entered into with you; it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; 

  • it is necessary to protect the vital interests of you or another natural person; or 

  • it is necessary to comply with a legal obligation. 

Where we are relying on consent as the legal basis, we will notify you and seek additional consent before using your Personal Data for a new purpose that is inconsistent with the original purpose for which we collected it.

Special Categories of Data
We will not intentionally collect any "special categories of data" under the GDPR or the UK GDPR without your explicit consent for one or more specified purposes or as otherwise permitted or required by applicable law. Special categories of data include personal data (a) revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership; or (b) concerning health or data concerning a natural person's sex life or sexual orientation.

Minors
Our Site and Services are not intended for minors (individuals under the age of 13, or equivalent minimum age depending on jurisdiction), and we do not knowingly collect Personal Data from minors. If you become aware of any Personal Data we have collected from a minor, please contact us. If we learn that we have collected Personal Data from a minor, we will take steps to delete the data without notice as soon as possible.

Data from Third Parties
Carbon Direct may receive Personal Data about you from other sources, including your company/organization, professional references, publicly-available sources, third-party analytics providers, and other third parties. For example, we may receive your Personal Data if: 

  • someone at your company/organization designates you as a contact person for that company/organization or includes information about you in proposal documents; 

  • another visitor includes it in any feedback, comments, photos, videos, or other media or information submitted via online portals, electronic forms, surveys, or interactive portions of our Site; or 

  • one of our employees, a service provider, or a third party acting on apparent authority provides it to us when registering you to access our Services or our Site or participate in one of our events.

Advertising
Carbon Direct may use third-party service providers to serve our advertisements across the internet. These companies may use tracking technologies to collect information about your visits to our Site and other websites and your interaction with our advertising and other communications. Some advertisements may be personalized, meaning that they are intended to be relevant to you based on information collected about your visits to our Site and elsewhere over time. Other companies may also use such technology to advertise on our Site. You have the choice to tell us not to collect and use this information, and in some jurisdictions, we will only engage in interest-based advertising if you opt-in. If you would like more information about this practice and to know your choices concerning interest-based advertisements, please visit:

Cookies and Automatic Data Collection
We may use cookies and similar technologies to collect information and to personalize our Site and Services. By continuing to use the Site and Services, you consent to the placement of these cookies and similar technologies and to our privacy practices. You do not need to have cookies enabled to browse our Site unless you want us to remember you and your preferences when you return. If you prefer not to allow cookies, most cookies can be managed or blocked through your browser. However, if your browser is set to reject cookies or you manually delete cookies, you may have some trouble accessing and using some of the pages and features that are currently on our Site, or that we may put on our Site in the future. Note that browser-management tools for cookies are outside of our control and we cannot guarantee their effectiveness. For more information, please visit our Cookie Notice.

Data Sharing with Employees, Agents, Affiliates, Service Providers, and Partners
We may share your Personal Data with our employees, agents, affiliates, and representatives who have a business need to know, our services providers (including contingent workers, consultants, contractors, vendors, and out-sourced service providers) to process it for us based on our instructions and for no other purpose, and with partners that are collaborating with us to fund projects or host events. We do not share your Personal Data with any third party (including our service providers) for marketing purposes unless you have provided consent for us to do so. If you believe Personal Data you provided to us is being misused by a third party, please contact us right away.

Law Enforcement
Carbon Direct may share Personal Data with law enforcement, other government agencies or authorities, or third parties as required by applicable law, court order, subpoena, or legal process.

Retention
Carbon Direct typically maintains submitted information until you affirmatively change or delete such information. This allows us to help ensure functionality of the Site and Services. Disposal of Personal Information may include anonymizing it, deleting it, or taking other appropriate steps. Personal Data may persist in copies made for backup and business continuity purposes.

Storage and Transfers
Your Personal Data may be stored in your region or in any other country where we or our service providers have facilities. We may also allow employees and service providers located around the world to access Personal Data as provided in this notice. If your Personal Data is subject to GDPR or UK GDPR, Carbon Direct will ensure your legal rights and protections travel with any such "transfer" of your Personal Data as required by applicable law. We do this by signing "standard contractual clauses" approved by the European Commission that give Personal Data the same protection it has in the European Union, or otherwise requiring that our service providers protect Personal Data in accordance with applicable law. We will also comply with similar applicable laws regarding the storage and transfer of Personal Data in other jurisdictions where your Personal Data may be collected or provided.

Storage Period
Carbon Direct will store your Personal Data until it is no longer needed to fulfill the purpose for which it was collected or as otherwise required or permitted by law. After such time, we will either delete or anonymize your Personal Data or, if this is not possible, we will securely store your Personal Data and isolate it from any further use until deletion is possible. We may dispose of any data at our discretion without notice, subject to applicable law. 

Access and Control
If you wish to obtain confirmation that we hold Personal Data about you, access, correct, or delete your Personal Data, withdraw any consent you previously provided to us, or object to or restrict our processing of your Personal Data in any other context, please contact us. We will respond to all legitimate requests within thirty (30) days of receipt. If you do not wish to receive promotional communications from us, you can opt-out by following the instructions contained in the messages you receive. Even if you opt-out of receiving these promotional communications, we reserve the right to send you certain communications relating to our Site or Services, including administrative messages. 

Other Rights
To the extent provided by applicable laws (including the CCPPA, GDPR, and UK GDPR), you may have the right to deactivate, block, anonymize, or delete personal data as appropriate; request and receive a copy of the personal data you have provided us and to transmit this data to a third party; and lodge a complaint with the applicable data protection authority. To exercise any of these rights that you are not able to do directly, please contact us.

Click-Through URLs
If you "opt in" to receive newsletters, updates, or other information from us, our emails may use a "click-through URL" linked to content on our Site. When you click one of these URLs, they pass through a separate web server before arriving at the destination page on our Site. We use this click-through data to help us understand how recipients respond to, or interact with, our emails.Third-party cookies and similar technologies

Third-Party Analytics Services
We use third-party analytics services, including Google Analytics and others, to collect information about your use of our Site and enable us to improve our Site and Services. You can learn about Google's practices by going to www.google.com/policies/privacy/partners. Google Analytics and other third-party analytics services use cookies and similar technologies to collect information about use of our Site and to report website trends to us, without identifying individuals to us. We use this information to see the overall patterns of usage on our Site, help us record any difficulties you have with our Site, and tell us whether our communication efforts are effective. We may also link the information provided by third party analytics services with the information we collect, or you provide in other contexts on our Site (newsletters, etc.), to personalize, connect and streamline your experience when visiting our Site and using our Services.

Click-Through URLs
If you prefer not to be tracked in this way, please do not click text or graphic links in emails you receive from us. 

Third-Party Analytics Services
You can opt out of data collection or use by Google and other third-party analytics services we may use on our Site.

Do-Not-Track Requests
There is no standard for how online service should respond to "Do Not Track" signals or other mechanisms that may allow you to opt out of the collection of information across networks of websites and online services. Therefore, we do not honor "Do Not Track" signals. As standards develop, we will revisit this issue and update this notice if our practices change. More information about Do Not Track is available at www.allaboutdnt.org.

How to Contact Carbon Direct
Please do not hesitate to contact us with any questions, concerns, complaints, or requests with respect to your Personal Data, this Policy, or other privacy practices at Carbon Direct. You may do so via:

Email:
legal@carbon-direct.com

or

Mail:
Carbon Direct Inc.
Attn: Legal
17 State Street, Floor 6
New York, NY 10004

Supplemental Privacy Notices
This Policy may be supplemented by an auxiliary privacy notice applicable to a particular Service, which may be either embedded in this notice or made available to you separately. Carbon Direct will tell you when a supplemental privacy notice applies.

Updates
Carbon Direct will update this Privacy Policy from time to time as relevant and necessary. You are advised to review periodically for changes. Any questions regarding this disclosure should be directed to the Carbon Direct Legal Team at legal@carbon-direct.com.