Last Updated December 31st, 2023

At ESG Solutions, we are dedicated to assisting businesses worldwide in developing their ESG climate strategies for a sustainable future. Our ambition begins with protecting the privacy of everyone in our community. This means that we'll protect the personal information of all visitors who contact us by email or any other means, who access our website (https://esg-solutions.org) or services through any mobile application, platform or device (hereinafter referred to as the " Service"). This privacy policy (" Privacy Policy") explains how ESG Solutions, our subsidiaries and affiliates collect, share, and use personal information. You will also find information about how you can exercise your privacy rights. By using our Service you agree to ESG Solutions using your personal information as described in this Privacy Policy. The terms "we", "us" or "our" are each intended as a reference to ESG Solutions SAS, the company offering and operating the Service.

A. Personal data we collect
 
The personal information that we may collect broadly falls into the following categories:

A.1 Information provided voluntarily
Certain parts of our Service allow or may ask to provide personal information voluntarily. For instance:

• - Contact information: When you contact us by email, using an electronic form offered by our Service or by any other electronic and non-electronic way, we collect information about you, including your name, email, job title, name of the organization that you represent, and details provided in your message.

• - "Know Your Customer" and due diligence information: When you decide to create a ESG Solutions account for the organization you represent, we will collect information about ownership, position in the organization, passport or national ID of people designated as the duly authorized signatories of your organization for signing contracts with ESG Solutions.

• - Registration information: When you create a ESG Solutions account in the name of your company, we collect information about you including your name, job position, employer's name, professional email address and the password you create.

• - Transaction information: We collect information relating to the contributions in projects and retirement of carbon credits of your organization, this can include personal data such as passport or national ID card or credit card details (e.g. your cardholder's name and credit card number) using the secure services of our payment processor Lemon Way SAS. Payment operations are outsourced to our payment processors and we do not store your credit card information in our systems.

• - Information regarding your marketing preferences: We collect information about your preferences to receive marketing information any time you subscribe or unsubscribe.

• - Feedback: When you post messages and reviews of the Service or you contact us, for example with a question, problem or comment, we collect information about you including your name and the content of your query. If you contact our customer support teams we will record and keep a record of your conversation for quality and training purposes and to aid in the resolution of your queries.

A.2 Information that we collect automatically
When you access our Service, we may collect certain information automatically from your device. In some countries, including countries in Europe, this information may be considered personal information under applicable data protection laws. For instance:

• - Activity information: We collect information about your usage of the Service and information about you from the content you create and the notifications or messages you post or send as well as what you search for, look at and engage with.

• - Cookies and similar technologies: We use cookies and similar tracking technology to collect and use personal information about you (e.g. your Internet Protocol (IP) address, your device ID, your browser type and when, how often and how long you interact with the Service), including to facilitate interest-based advertising.

For further information about the types of cookies and similar technologies we use, why, and how you can control such technologies, see our Cookies Policy.

A.3 Information that we obtain from third party sources
From time to time, we may receive personal information from third party sources, including advertising networks but only where we have checked that these third parties either have your consent to process the information or are otherwise legally permitted or required to share your personal information with us. For instance: Analytics reports and market research surveys: We collect information from our third party affiliates about the way you respond to and engage with our marketing campaigns so that we can customise our marketing and Service accordingly. We may also receive aggregated information in the form of audience segments from third party sources in order to display targeted advertising on digital properties operated by organisations like LinkedIn and Google.

B. Our use of collected information

Examples of how we may use this information include: 
B.1 Information provided voluntarily

• - Contact information: The information you provide when you contact us allows us to reach back to you and provide you with an answer to your request.

• "Know Your Customer" and due diligence information: The information you provide when you contact us allows us to make sure we comply with the law, as well as with our own Anti-Money Laundering and Counter-Terrorism Financing and other compliance policies.

• - Registration information: The registration information you provide when you create a ESG Solutions account allows us to give you access to the Service under our Terms and Conditions. We also use this information to authenticate your access to the Service, to contact you and to notify you of important changes or updates to our Service.

• - Transaction information: We may allow credit card payment online to pay for the Application Fee or Listing Fee of a project as defined in our Terms and Conditions. For transactions such as carbon credit sale/purchase or retirement, we will send a contract to be electronically signed by the duly authorised signatories and we may collect a photo of their respective passport or national ID card for security reasons.

• - Information regarding your marketing preferences: ESG Solutionsmay market to you, where permitted by law, by post, email, telephone, mobile (i.e. SMS, in-app messaging and push notification) about our products or services.If you don't want us to use your data in this way or generally change your mind about receiving any form of marketing communications, you can unsubscribe at any time using the unsubscribe functionality in the communication you receive or by amending your profile accordingly. You may also be able to opt-out of push notifications at a device level (e.g. by way of your OS settings). If you choose to unsubscribe from our marketing, we will keep a record of your preferences so that we don't bother you with unwanted marketing in future.

• - Feedback and reviews: If you give us feedback we will use it to reply to your questions or queries, to provide customer support and resolve any problems with the Service.

B.2 Information that we collect automatically
When you access our Service, we may collect certain information automatically from your device such as your IP address, MAC address or device ID. In some countries, including in Europe, this information may be considered personal information under applicable data protection laws.Cookies and similar technologies: We may work with advertising affiliates that serve advertisements on our Service on the websites and services of third parties. Some of those networks use cookies which allow us to display advertisements that are personalised to your interests based upon your internet browsing activity.Like many websites and online services we use cookies and other technologies to maintain a record of your interaction with our Service. For further information about the types of cookies and similar technologies we use, why, and how you can control such technologies, please see our Cookies Policy.

B.3 Information that we obtain from third party sources
Analytics reports and market research surveys: We analyse information we collect from our third-party service providers (such as Google or LinkedIn) to understand how you engage with our Service and advertisements. This helps us to understand the general preferences of our customers as a whole and improve our Service.

C. Who we share personal information with

In delivering the Service to you, we may share your personal information with the following entities:

• - Lemon Way SAS, as part as the "Know Your Customer" procedure.

• - Third parties who undertake various activities to promote and support our Service. This includes offshore customer support agents, website and application support and hosting providers, marketing service providers, eCRM partners like Salesforce or Pipedrive who manage our marketing emails and push notifications, market research companies and payment processing providers which process payment card transactions - any of these third parties might be inside or outside your country of residence. We may also share information with third parties (for example, companies specializing in computing the carbon footprint of your organization or offering services around ESG reporting, CSR strategy) so that they can contact you about goods or services which may interest you. We will only share your information with these third parties where you have given your consent. If you don't want us to use your personal information in this way or generally change your mind about receiving any form of marketing communications, you can unsubscribe at any time using the unsubscribe functionality in the communication you receive or by amending your profile accordingly. If you choose to unsubscribe from our marketing, we will keep a record of your preferences so that we don't bother you with unwanted marketing in future.If any part of our business enters into a joint venture, purchases another business or is sold to or merged with another business entity, your information may be disclosed or transferred to the target company, or new business partners or owners or their agents and advisors. In these circumstances we will always inform the relevant entities that they must only use your personal information for the purposes disclosed in this Privacy Policy.

• - Any law enforcement or regulatory body, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person.

• - Any other person provided that you have given your consent to the disclosure. We will not sell, distribute or lease your personal information unless we have your permission or are required by law to do so.

D. Legal basis for processing personal information

Our legal basis for collecting and using your personal information as described above will depend on the specific context in which we collect it. Our main reason for collecting and using your personal information is to perform our contract with you (i.e., depending on whether your organization is a project developer, a corporate willing to buy carbon credits to offset its emissions or a partner engaged in sustainability). However we will also use your personal information where it is in our legitimate business interests to do so (but only if our interests are not overridden by your data protection interests or your fundamental legal rights and freedoms). In some cases, we may have a legal obligation to collect personal information from you. This is the case for the "Know Your Customer" process that is mandatory for our business partner Lemon Way SAS, regulated in France by the "Autorite de Controle Prudentiel et de Resolution" (ACPR), as well as in the event of legal proceedings. If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (and we'll also explain the possible consequences of you not providing it). Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are. If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the "How to contact us" below.

E. International data transfers
ESG Solutions's website servers are located in the European Union. No data will be transferred by ESG Solutions outside the European Union.

F. Security
We place great importance on keeping your personal information safe and secure. As such, we put in place appropriate technical and organisational measures / industry standard technology to protect it from unauthorised access and unlawful processing, accidental loss, destruction and damage. The security measures we use are designed to provide a level of protection security appropriate to the risk of processing your personal information. Where you have chosen a password which allows you to access certain parts of the Service, you are responsible for keeping this password confidential. We advise you not to share your password with anyone and to use a unique password for our Service. We will not be liable for any unauthorised transactions entered into using your name and password.

G. Data retention
ESG Solutions will retain your personal information where we have an ongoing legitimate business need to do so (for example, while you hold an account with us or to enable us to meet our legal, tax or accounting obligations). If you object to us processing certain categories of your personal information (including in relation to receiving marketing communications from us), we will retain a record of your objection to the processing of your information so that we can continue to respect your wishes. We will destroy or permanently anonymise your personal information at the point that we no longer need to process it for our ongoing legitimate business needs or for any legal reason. If this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store it and isolate it from any further processing until deletion is possible.

H. Your data protection rights
ESG Solutions respects your privacy and data protection rights. Below is a summary of your rights in respect of the personal information of yours which ESG Solutions handles:

• - ESG Solutions provides you with the tools to access, review or update your personal information at any time through your account. If you wish to request deletion of your personal information, you can do so by contacting us using the contact details provided under the "How to contact us" heading below.

• You can object to processing of your personal information, ask us to restrict processing of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the "How to contact us" heading below.

• - You have the right to opt-out of receiving marketing communications we send you at any time. You can exercise this right by using the unsubscribe functionality in the communication you receive or by amending your profile accordingly.

• - Similarly, if we collect and process your personal information on the basis of your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

• - You have the right to complain to a data protection supervisory authority about our collection and use of your personal information.

• We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

I. Links to third-party sites
Our website may, from time to time, contain links to and from the websites of our partners and affiliates or to any number of websites that may offer useful information to our visitors. We provide these links to you only as a convenience and the inclusion of any link does not imply endorsement of the relevant website by ESG Solutions. If you follow a link to any of these websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for these policies or those linked websites. Please check these policies before you submit any personal information to such websites.

J. Updates to this Privacy Policy
We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws.

K. How to contact us
If you have any questions or concerns about this Privacy Policy, please contact our Privacy team by email at: info@esg-solutions.org