Privacy Policy
1. WHO WE ARE
Treecard.org (the “Website”) and the Treecard App (the “App”) are operated by TreeCard Inc. (9450 SW Gemini Dr, PMB 84131, Beaverton, Oregon, 97008-7105)(“Treecard”, “we”, “us”, “our”). If you have any questions about this privacy policy (the “Policy”) or our privacy practices, please contact us at: support@treecard.org.
We offer and service (the “Services”) a top-up debit card that reforests the planet with your everyday payments (the “TreeCard”). The TreeCard and the Services areprovided via our Website and App and with the help of our partners. We are not a bank, and we are not regulated by any banking authority in any jurisdiction. Any regulatedbanking facility services provided to you will be provided on our behalf by our partners who are regulated in the jurisdictions in which they operate.
In the course of offering the TreeCard and the Services, we need to collect certain personal data (also referred to as "personal information" and "information") about ourcustomers and prospective customers. This Policy explains how we handle personal data about our customers and prospective customers.
Prior to becoming a customer, you will receive our terms of service and the terms of service of our partners who will be providing any regulated banking facility services on ourbehalf. You will be required to read and agree to these terms before your information is passed on to our partners and before we are able to provide you a TreeCard or accessto our Services.
The submission of your personal data to us at this stage shall not be treated as a legal commitment at your end to receive a TreeCard but as an expression of interest in our Services.
2. SCOPE & ACKNOWLEDGEMENT
This Policy applies to any personal data you submit to us via the Website or the App ("directly obtained information") or that you generate while browsing the Website orusing the App or a TreeCard, and also to any other information about you that comes our way during our business development efforts ("indirectly obtained information"). Ifyou do not agree with this Policy, please do not access or use the TreeCard, the Website or the App. By accessing or using the TreeCard, the Website or the App, youexpressly agree to the Policy.
By submitting personal data to us, you acknowledge that you have read this Policy and that we expect you to help us maintain your information accurate and up- to-date. Weendeavor to bring this Policy to your attention every time we obtain information directly from you. In all other circumstances we will bring this Policy to your attention the firsttime we reach out to you.
We would not ask you for any information related to your health, religious/political/philosophical beliefs or racial background or any other sensitive matters, so please do notsubmit such information to us. We do not collect special category personal data or any protected classification characteristics. We do not knowingly collect any personalinformation about any individual under age 16. If you are under 16, do not use or provide any information on this Website or App. If we learn we have collected or receivedpersonal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about achild under 16, please contact us at support@treecard.org.
We do not sell personal information and we do not pass on personal information to any parties who may sell it.
3. MAIN PROCESSING ACTIVITIES
We process the following personal data:
For the following purposes:
On the following ground(s):
Directly obtained information: any information you submit to us via the Website or the App. This information includes your (user)name, password, contact details such as email address, physical address and mobile phone number, date of birth, your reasons why you may wish to use the TreeCard or our Services and in what way you may use the TreeCard or our Services and any other information you decide to submit via web forms or any other means.
(1) We collect all this information for the primary purpose of ensuring the expressions of interest in the TreeCard are genuine and suitable.(2) We collect email addresses for the purpose of maintaining correspondence with you in relation to the TreeCard;
(3) We collect physical addresses for the purpose of delivering your TreeCard should you decide to use our Services.
(4) We collect user names and passwords and we verify phone numbers in order to provide you access to a secure environment with our Website and App.
(5) We collect dates of birth to ensure we do not offer or promote the TreeCard or any Services to minors.(6) We collect your responses to a few questions regarding your intended use of the TreeCard and our Services in order to potentially tailor these Services prior to their launch.(7) We may use email addresses for the purposes of targeted online advertisement via third parties.
(8) We may use email addresses for the purposes of direct marketing.
(1) to (6) This collection is necessary for the purpose of entering into a contract for the TreeCard with you should you wish to access the Services. Simultaneously, this collection is necessary for the purposes of our legitimate interests that are to assess genuine and suitable expressions of interests in the TreeCard.
(7) This processing is necessary for our legitimate interests that are to promote and raise awareness about the TreeCard. Where legally required, we will ask for your consent before undertake this type of processing.
(8) This processing will take place subject to your permission.
Indirectly obtained information: any information you generate while you browse our Website or use our App or the TreeCard or while you read our direct marketing materials. This information is generated with the help of cookies and similar technologies and may include: browser type and version; operating system; the website from which your reach our Website; date and time of access to our Website; your IP address; your ISP, certain information about your device and other technical similar information that is capable of identifying you.
We may use information generated with the help of "cookies" and similar technologies for:
(1) the correct and efficient delivery of Website and App content;
(2) ensuring the viability of information technology systems and Website and App technology;
(3) analysis of the Website and the App any direct marketing material's performance and engagement;
(4) optimization of the Website and App content including its advertisement on search engines;
(5) delivery (via third parties) of targeted advertising tailored to your interests.
(1) and (2) The processing of this information is necessary for our legitimate interests, namely ensuring the efficient, functional and safe delivery of the Website and the App and any direct marketing material.
(3) The processing of this information is necessary for our legitimate interests, namely improving our Website and App. Where required by law, we will seek your permission to process this information.
(4) and (5) For such processing we need to your permission.
You can exercise your choice with respect to cookies via the cookies pop-up on the Website.
For the technical details of the cookies in use, please see the section on cookies and similar technologies below.
4. PERSONAL DATA SHARING
For the following purposes:
On the following legal grounds:
We may disclose your personal data to our suppliers who help us provide run our business, Website and App. Our suppliers may process your personal data on our behalf solely in accordance with our instructions and pursuant to a written contract.For example, we use suppliers for webhosting, secure cloud storage, analytics, email and SMS delivery, customer relationship management, fonts and other services.We also use suppliers such as social media companies and search engines in order to advertise the launch of our Services. We may share your email address or device ID with these suppliers.
This is either:(1) necessary for the purpose of entering into a contract for a TreeCard with you;or(2) necessary for the purposes of our legitimate interests that are to assess genuine and suitable expressions of interests in our Services.When none of the above applies, we will seek your permission in order to use a certain supplier with respect to your personal.
We may disclose your personal data to our professional advisorsthat are usually regulated by a competent authority (lawyers,accountants, etc.) where that proves necessary.
This is necessary for the purposes of the legitimate interests that we pursue namelythe proper administration of our business
We may disclose your personal data to the court service orregulators or law enforcement agencies in connection withproceedings or investigations where we are compelled to do so.
We would do this if we need to comply with a legal obligation or when in pursuit of ourlegitimate interests, namely the protection of our business.
If we sell or buy any assets or business, we may disclose yourpersonal data to the prospective seller or buyer of such business orassets. Conversely, if we are acquired by another business, personalinformation about our customers will be transferred to the buyer.
This is necessary for the purposes of the legitimate interests that we pursue, namelythe proper administration of our business and our business' continued ability toprovide our Website, the App, the TreeCard and Services.
5. ACCESSING AND CORRECTION YOUR INFORMATION; OPTING OUT OF YOUR PERSONAL INFORMATION BEING SHARED
You can review and change your personal data by logging into the Website or the App and visiting your account profile page. You may also send us an email atsupport@treecard.org to request access to, correct or delete any personal information that you have provided to us. In some instances, we may not be able to delete yourpersonal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law orlegal requirement or cause the information to be incorrect.
You always retain the right to opt out of having your personal information being shared, or being used for a particular purpose (subject to the other provisions of this PrivacyPolicy). To do so, simply send us an email with such request to support@treecard.org.
TRANSFERS OF PERSONAL DATA IN AND OUT OF THE EUROPEAN ECONOMIC AREA AND THE UNITED KINGDOM ("EEA"; "UK”)
The very nature of Internet communications means that at least some of the personal data processed by us and the parties we share it with will be transferred in and out of the EEA which is an area composed of countries offering a high standard of personal data protection pursuant to the General Data Protection Regulation (EU) 2016/679 which imposes certain restrictions on outbound transfers to most non-EEA territories. On the other hand, most non-EEA territories do not impose any restrictions on transfers of personal data to the EEA.
If you are residing in the EEA or in the UK your data transferred to our suppliers outside these territories will be protected with model data protection clauses approved by the European Commission. Please contact us if you would wish to have further details of the specific safeguards applied to the export of your personal data outside the EEA (where applicable).
6. YOUR RIGHTS OVER YOUR INFORMATION
We are committed to fulfilling the statutory data protection rights of our customers. These may vary depending on where you live. For example, if you reside in California and certain additional conditions apply, you may be entitled to the rights to know; delete; opt out and non-discrimination. You can learn more about these rights here. Additionally, Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address:support@treecard.org. However, please know we do not currently sell data triggering that statute's opt-out requirements.
However, we will respect your data subject rights enshrined in the General Data Protection Regulation (EU) 2016/679 no matter where you live. Please use the contact us button on our Website and App to exercise the following rights in respect of the personal data about you that we process:
to be informed;
to access;
to rectify;
to erase;
to restrict processing;
to object to profiling;
to data portability;
to complain to your local data protection authority;
to withdraw consent
Detailed information on the full content of the rights or people located in the United Kingdom (and the conditions that apply) is provided by the United Kingdom’s InformationCommissioner’s Office and is available on their website: https://ico.org.uk/your-data-matters/.
7. INFORMATION SECURITY
No data transmission over the Internet can be absolutely guaranteed to be secure from intrusion. Nevertheless, we maintain physical, electronic and procedural safeguards toprotect personal data in accordance with data protection legislation requirements. We only use suppliers who undertake to maintain comprehensive Information SecurityPrograms with effective administrative, technical, and physical safeguards capable of identifying, detecting, protecting against, responding to, and recovering from securityincidents, and are certified against recognized security standards such as ISO/IEC 27001, SOC 2 and PCI DSS. We use the Google Cloud to store your data. If you decide touse our Services, once receive your TreeCard, your information will be stored by our banking partners that are certified against, among others, the Payment Card Industry Data Security Standard.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website,you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Additionally, the transmission of information via the internet isnot completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website.Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website orthe App.
8. DATA RETENTION PERIOD
We shall retain your personal data until you request us to no longer hold it, unless we are required to keep it by law. If your personal data becomes irrelevant for the purpose forwhich it was originally collected then we will securely dispose of it. As a general rule, we delete data about users who do not sign up for a TreeCard within 12 months of Serviceavailability date. In all other cases, to determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, thepotential risk of harm from unauthorized use or disclosure, the purposes for which we process personal data and whether we can achieve those purposes through other means,and the applicable legal requirements.
Please note that the foregoing does not apply to any personal data that has been irreversibly anonymized, meaning data rendered anonymous in such a manner that you areno longer identifiable from such data. Under the applicable law, such data is not deemed "personal" and may be retained and shared indefinitely.
9. COOKIES AND SIMILAR TRACKING TECHNOLOGIES
Some cookies and similar technologies, particularly those that track users' browsing behavior across the web are perceived by data protection regulators as privacy-intrusive.We are, therefore, presenting the below information to our Website visitors and direct marketing material recipients in order to explain why and how we use this technology.
Name of technology
Party serving thetechnology
Purpose of technology
Lifespan oftechnology on users'hardware
Link toprivacypolicy ofthird partyserving thetechnology
Google Analytics
Google Inc
Google’s ability to use and share information collected by Google Analytics is restricted by the Google Analytics Terms of Service and the Google Privacy Policy. You may also learn more about how Google collects and processes data specifically in connection with Google Analytics. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on.
24 months
Privacy Policy
Facebook Pixel andRemarketing Service
Facebook Inc
Facebook’s use of information collected is set forth in its Privacy Policy. You may opt out of Facebook’s interest-based ads.
24 months
Privacy Policy
In addition to the controls provided on our Website via the pop-up, you can choose to block cookies by activating the settings on your browser that allow you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access parts of the Website. Your browser settings also allow you to delete all cookies stored on your device whenever you wish.
The UK Information Commissioner’s Office provides the following guidance on controlling cookies:
● A number of Websites provide detailed information on cookies, including AboutCookies.org and AllAboutCookies.org.
● The European Interactive Digital Advertising Alliance website Your Online Choices allows you to install opt-out cookies across different advertising networks.
● Google has developed a browser add-on to allow users to opt-out of Google Analytics across all websites which use it.
● Some browsers include a feature known as ‘Do Not Track’ or DNT. This allows you to indicate a preference that websites should not track you. However, whilst DNT is available in many browsers, websites are not required to recognize its request, so it may not always work. You can get help on how to use DNT in Microsoft Edge, Microsoft Internet Explorer, Mozilla Firefox, Google Chrome and Opera.
● For more information on how private browsing works as well as its limitations, visit the support pages for your browser: Microsoft Edge, Microsoft Internet Explorer, Mozilla Firefox, Google Chrome and Safari (IOS (mobile) and desktop).If you are concerned about online tracking, then we can recommend you to:
● Install a privacy-friendly browser on your device, such as Mozilla Firefox or Brave;
● Install anti-tracking and ad-blocking plug-ins on that browser, such as Ad Block Plus, Ghostery or Privacy Badger; and
● Use privacy-friendly web search engines, such as Ecosia or Duck Duck Go.
If you have any questions about the cookies or similar technologies in use on our Website or App or in any direct marketing material, please use the contact us button on our Website and App.
10. CHANGES
We reserve the right to amend this Policy from time to time. Any changes we make in the future will be published on our Website, and it is your responsibility to consult the Websiteregularly in order acquaint yourself with such changes. You expressly agree to all Policy changes each time you access or use a TreeCard, the Website or the App.
