Last updated and effective as of: January 10, 2022

Who we are

GreenTwin GmbH (“GreenTwin”, “we”, “us”) is an Austrian climate tech company that designs software tools and services in support of climate adaptation and mitigation actions, at local, regional, national and international levels. Our technology solutions are designed to improve circularity of raw materials, thus increasing material flows, reducing waste and environmental footprint.

Our website is owned and operated by GreenTwin GmbH.

This Privacy Policy applies to your use of our tools, services and platform, including any of GreenTwin’sassociated mobile or desktop applications and our website (“services” in short), as well as your relationship with GreenTwin GmbH. By accessing or using our services, you are agreeing to this Privacy Policy and concluding a legally binding agreement between yourself and us.

Your acceptance of this Privacy Policy is deemed to occur upon your first use of our services. If you do not accept and agree with this Privacy Policy, you must stop usingGreenTwin’s services. We are the data controller and therefore responsible for, and control the processing of, the personal data collected via our services, in accordance with the General Data Protection Regulations and Data Protection Act 2018 (the “GDPR/ the “Act”).

We respect your privacy and care about how your information is used and shared online. Please read this Privacy Policy in full to understand what data we collect, how we use it and the circumstances where we may share it.

Definitions

“Cookie” means a small text file placed on your computer or device by our website when you visit certain parts of our website and/or when you use its certain features. Details of the cookies used by our website are set out below.

“European Economic Area (“the EEA”) consists of all EU member states, plus Norway, Iceland and Liechtenstein.

“Personal data” means any information that identifies a living individual or makes the individual identifiable.

“We/us/our” means GreenTwin GmbH, a company registered in Austria under number [company registration number forthcoming].

Scope

This Privacy Policy applies only to your use of our services. It does not extend to any websites or services that are linked to from this website. We have no control over how your data is collected, stored or used by other websites and we advise you to check the Privacy Policies of such websites and services before providing any data to them.

If you follow a link to any of third party services, please note that we do not accept any responsibility or liability for their activities or the content of their privacy policies.

What data do we collect

We collect personal information (or personal data) and non-personal information from you when you use our services. We may receive your personal information that you submit through the services, for example, when signing up to our mailing list. We may also receive personal information about you automatically as you use our services.

  • ‍Information you provide to us, e.g. when you create an account; search for or purchase our offerings; configure settings; communicate with us; or otherwise use our services.

  • Information from our customers: Our customers may share customer data with us so that we can provide them with services.

  • ‍Usage and log data, e.g. when you interact with our services, we may log and store your IP address and technical information about your usage: your device ID, browser type, how you progressed through the services, where you abandoned it, etc. We can use your IP address to determine your general location.

  • ‍App data: If you use our services on mobile or other platforms, we may collect analytic information about your device: IP address, device ID, OS version, and clickstream.

  • ‍Information from public sources or third parties, e.g. we may receive marketing, sales generation, and recruitment information from service providers or partners.

Depending upon your use of our services, we may collect some or all of the following data:

  • personal data, including name, title;
  • employment/ business details, including business/company name and job title;
  • contact information, including email addresses, telephone number and address;
  • demographic information, including post code, preferences and interests;
  • details of any enquiries made by you through our services, together with details relating to subsequent correspondence; and
  • technical information, including IP address (automatically collected), web browser type and version (automatically collected), operating system (automatically collected), a list of URLs starting with a referring site, your activity on our website, and the site you exit to (automatically collected) and other data as collected by industry standard analytics tools, such as Google Analytics.

Comments

When visitors leave comments on the site, we collect the data shown in the comments form, the visitor’s IP address and browser user agent string to help spam detection.

An anonymised string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture, if available, is visible to the public in the context of your comment.

Media

If you upload images to the website, you should never upload images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Cookies

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

We may monitor your use of our website through cookies. We may also monitor traffic, location and other data and information about users. Such data and information, to the extent that you are individually identifiable from it, shall constitute Information as defined above. However, some of this data will be aggregated or statistical, which means that we will not be able to identify you individually.

For more details, see our Cookie Policy.

How do we use your data

We may process your personal data in order to operate, administer, maintain, provide, personalise, analyse, and improve our services. This processing is necessary for the legitimate interest we pursue in improving the services, and we will make sure that our interest is not overridden by any risk to your rights.

In order to investigate and address any comments, queries or complaints made by you regarding our services, the required data processing is necessary to respond to enquires, and we will again assure that our interest is not overridden by any risk to your rights..

Where an enquiry relates to your account or our contract for services, the data processing may be necessary for the performance of a contract.

In order to manage your account, the data processing is necessary for the performance of a contract between us and data is processed to enable us to provide an account to you. Similarly, the data processing is necessary for:

  • supplying our services to you for the performance of a contract between us;
  • personalising and tailoring our services for you, in order to keep them competitive and relevant;
  • processing data with machine learning algorithms, which helps us build, personalise, and improve our services;
  • receiving and processing job applications for jobs with us;
  • processing any claim, including a breach of contract, payment of money due, etc.;
  • enabling communications and providing you with emails that you have subscribed to;
  • contacting you for marketing purposes and services you might be interested in, unless you opt-out;
  • as required by applicable law, legal process, or regulation;
  • for purposes as disclosed at the time you provide your data, with your consent, and as further described in this Privacy Policy.

Who we share your data with

We may contract with third parties to supply products and services to you on our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some of your personal data. Where any of your personal data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law.

We may compile statistics about the use of our services including data on website traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying data. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.

In certain circumstances we may need to share your data with third parties, such as legal counsel, to advance or defend a claim.

In certain circumstances we may be legally required to share certain data, which may include your personal data, e.g. in situations where we are involved in legal proceedings, where we are complying with the requirements of legislation, a court order, or a governmental authority.

We may also share your data with any prospective buyer or seller (and their representative) in the event that we sell or buy a business or asset. Should such an event occur, we will make reasonable efforts to request that the new owner or combined entity (as applicable) follow this Privacy Policy with respect to your personal data. If your personal data would be used contrary to this Privacy Policy, we will request that you receive prior notice.

If we do store or transfer data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA.

If we are going to release your data, we will do our best to provide you with notice in advance by email, unless we are prohibited by law from doing so.

When we use and share your non-personal data

We may use and share your non-personal, de-identified or aggregated data in a variety of ways, including to improve our services.

How long we retain your data

If you leave a comment, the comment and its metadata are retained indefinitely. In that way we can recognise and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website, we also store the personal data they provide in their user profile. All users can see, edit, or delete their personal data at any time (except they cannot change their username). Website administrators can also see and edit that information.

We also retain your personal data for 7 years following termination of our contract/ services with you. If required, we will be entitled to hold your personal data for longer periods in order to comply with our legal or regulatory obligations.

What rights you have over your personal data

If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

If you wish to exercise any of your legal rights over your personal data, you should put your request in writing to us (see Contact Us section below) giving us enough information to identify you and respond to your request. Details of your rights are set out below:

  • The right of access to your personal data – you have a right to access the personal data we hold about you. Most requests will receive a response within one month of receipt of a valid request. Those requests which are more complex or numerous may take up to three months. You may not be entitled to see all of the information about you if an exemption applies;
  • The right to correct or rectify any inaccurate personal data – if the personal data that we hold about you is incorrect, you have the right to ask us to amend it. Taking into account the purposes of the processing of personal data, the data can be rectified or, if data is incomplete, completed;
  • The right to erase your personal data – in certain circumstances you have the right to request that the personal data held about you is deleted or removed. The GDPR outlines specific circumstances when this right applies, including: where data is no longer needed for the purposes for which it was collected or otherwise processed. There are certain exemptions to the right, e.g. when processing is necessary to comply with a legal obligation;
  • The right to restrict the processing of personal data – in certain circumstances you are entitled to restrict process of personal data. This includes, e.g. where you contest the accuracy of the data, or we no longer need the data for the purposes of processing. You may also request processing is restricted were you object to our legitimate interests as the basis of processing your personal data or you believe continued processing to be unlawful. If this right is exercised, any further processing of your data will take place only with your consent or in certain circumstances in which the GDPR allows such processing to take place;
  • The right to personal data portability – in certain circumstances you have the right, on request, to ask us to provide a copy of the personal data that you have previously supplied to us, i.e. where the processing is by automated means and you wish to transfer to a new service provider;
  • The right to object to processing of personal data – in certain circumstances you have the right to object to the processing of your personal data by us. In particular, where you can demonstrate that such processing would be detrimental to your interests. If this right is exercised processing of personal data will stop, subject to us demonstrating compelling legitimate grounds for the processing to continue; or for the establishment, exercise or defence of legal claims.

If you seek to exercise a right and we consider an exemption applicable (or the relevant right is not exercisable), we will explain this to you in as clear a way as possible.

Marketing

Your personal data (name and contact details) will be processed for marketing communications. We do not require your permission for marketing communications that are business to business. Where marketing communications are aimed at you as an individual we may require your permission to send these communications in certain circumstances, which are set out below.

  • Where you have previously ordered products or services from us, unless you have told us not to, we may contact you by email or post about similar products, services, promotions and special offers that may be of interest to you “soft opt-in”.
  • With your permission, we may contact you by telephone, email or post to provide information in relation to other products, services, promotions, special offers and other information we think may be of interest to you.
  • With your permission, we may share your details with carefully selected third parties and they may contact you directly (unless you ask them not to) by telephone, email or post about products, services, promotions and special offers that may be of interest to you.
  • You have the right at any time to ask us, to stop processing your data for direct marketing purposes. If you wish to exercise this right please follow the unsubscribe link on the communications or contact us in order to process your request.
  • Where you have requested that we no longer contact you for marketing communications, we may retain your personal data as a record of this request.

Children’s Privacy

We do not knowingly collect personal data about children. Our services are not designed for use by individuals under the age of 18. If we learn that we have collected or obtained personal data of someone under 18, we will delete that data from our database. If you believe that this has occurred, please contact us at office@greentwin.at

Data security

To protect your data, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through our services. While we take reasonable precautions against possible security breaches, no website or internet service is completely secure and we cannot guarantee that unauthorised access, hacking, data loss, or other breach will never occur. Hence, it is also important to remember that you are advised to take suitable precautions too.

How to Opt-Out of email communications

To stop receiving notifications or promotions, please click the unsubscribe link found at the bottom of each email.

Note that we only send marketing communications to users located in the EEA with your prior consent.

How to deactivate your account

You can choose to deactivate your account so that you are no longer viewable on the services. You can request deactivation through the services or by sending a message to office@greentwin.at

Changes to our Privacy Policy

This Privacy Policy may change over time. If we make changes to it, we will post the updated Privacy Policy on our website. We encourage you to visit this page periodically to learn of any updates.

Complaints

If you have any concerns about how we collect or process your data, please contact us using office@greentwin.at 

Contact Us

We welcome your feedback and questions on this Privacy Policy or our services. If you wish to contact us, please email us using office@greentwin.at

©2022 GreenTwin GmbH. All rights reserved.