Privacy Policy
Thank you for choosing greenpass!
I. SCOPE OF THE PRIVACY POLICY
I. SCOPE OF THE PRIVACY POLICY
§ 1.1 Scope. This Privacy Policy applies to services (the "greenpass Services") provided on www.greenpass.io and other of our websites, mobile, or desktop applications (the "Platform"), as well as to other interactions (e.g., customer service inquiries, user conferences, etc.) that take place between you and us. The greenpass Services include, in particular,
(a) visiting the platform; visiting the platform;
(b) the account you will create (the “User Account”);
(c) the purchase of physical products through the platform; and
(d) the subscriptions related to software for climate protection in the construction sector (the “Subscription”).
§ 1.2 Declaration of consent. If you do not agree to the terms of our Privacy Policy, you may not access or use the greenpass Services, the Platform, or any other aspect of our business.
§ 1.3 Third-party providers. This Privacy Policy does not apply to third-party applications or software integrated into the greenpass Services through a platform ("Third-Party Services"), or to products, services, or companies of other third parties.
§ 1.4 Definitions. “We”, “our” and “us” refer to the persons referred to in Article XVI.
In a nutshell
In a nutshell
Please always observe this privacy policy when using the greenpass services
II. DATA WE COLLECT AND RECEIVE
II. DATA WE COLLECT AND RECEIVE
§ 2.1 Registration data.When you create a user account, we will receive the following information from you or a third party (the “Registration Data”):
(a) When you register via a platform, we receive:
(b) When you register via the social logins Facebook, Google and Apple, we receive your first and last name and an email address.
§ 2.2 Account details. When you purchase physical products or activate a subscription, you provide us or our payment providers with billing information such as credit card information, bank details, billing address or payment ID number ("Account Data").
§ 2.3 Other information. We also collect, generate and/or receive other information and data ("Other Information"):
(a) Usage information.
i. greenpass Services Metadata. When you use the greenpass Services, metadata is generated that provides additional context about your usage. For example, we may log features, content, links, or Third-Party Services (as defined below) that you have viewed or used.
(b) Newsletter.
(c) Third-party services.
(d) Data from third parties.We may receive data about your visits to the Platform, marketing campaigns, and other matters related to our business from affiliates, our partners, or other third parties. We may use this data to improve our offerings or make the content we provide to you more useful. We may also combine this data with other information we collect and include aggregated data, such as the language and country from which you access the greenpass Services. Or it may be more specific, such as how well an online marketing or email campaign performed.
(e) Additional Information. We also receive other information when it is submitted to us through the Platform or otherwise, such as when you participate in a competition or event, apply for a job, request support, interact with our social media channels, or otherwise contact us.
§ 2.4 Automatic capture. Generally, no one is legally or contractually obligated to provide registration data or other information (collectively, the "Information"). However, certain information is collected automatically or is mandatory for using the greenpass Services.
In a nutshell
In a nutshell
There is content that you voluntarily upload to the Platform, and there is other information that we collect and receive from you while you use the Platform and the greenpass Services. Please read on to learn more about our obligations regarding such information.
III. HOW WE USE INFORMATION
III. HOW WE USE INFORMATION
§ 3.1 User account data. We use registration data and other information collected through the use of your account (the "Account Data") in accordance with your instructions and applicable laws. We are a processor of such data, and you are the controller. For example, you can modify or remove the data or configure certain settings.
§ 3.2 Other information. We use other information, except for that in Section 3.1, to protect our legitimate interests in operating the greenpass services, platforms, and our business. Specifically, we use other information
(a) to provide, update, maintain, and protect the greenpass services and platform. This includes, in particular,
(b) if required by applicable law, legal process or regulation;
(c) to communicate with you by responding to your inquiries and requests. If you contact us, we may use your other information to respond;
(d) to send emails and other communications. We may send you service, technical, or administrative emails and other types of communications, such as push notifications. We may also contact you to inform you about changes to the greenpass Services, our offerings within the greenpass Services, and important notices related to the Services, such as security and fraud alerts. These communications are considered part of the greenpass Services, and you cannot opt out of receiving them. In addition, we sometimes send emails or other notifications about new product features, promotional messages, or other news about our company. These are marketing messages, so you have the option to choose whether to receive them. If you have further questions about a message you received from us, please contact us;
(e) for billing, account management, and other administrative matters. We may need to contact you for billing, account management, and similar purposes, and use account data to manage accounts and keep track of invoices and payments; and
(f) to investigate security issues and abuse and work to prevent them.
§ 3.3 Personal and anonymized data. If information is aggregated or anonymized so that it can no longer be reasonably associated with an identified or identifiable natural person, we may use it for any business purpose. To the extent that information is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection law, it is referred to in this Privacy Policy as "Personal Data."
In a nutshell
In a nutshell
We use the data we store only to provide and improve the greenpass services and for related business purposes. Of course, we always comply with all applicable laws.
IV. LEGAL BASIS
IV. LEGAL BASIS
§ 4.1 Legal provisions. We process your data in accordance with the provisions
(a) the General Data Protection Regulation (GDPR);
(b) Austrian data protection regulations, such as the Data Protection Act (DSG); and/or
(c) other national provisions applicable to the matter. These may also be laws of the country in which you are resident.
§ 4.2 Data categories. We process the above-mentioned data categories in accordance with the following provisions of the GDPR:
(a) Registration data and account data based on Art 6 Para 1 lit a for those data whose processing you have consented to, and lit b for those data that we necessarily need to fulfill our contractual obligations;
(b) Other information based on Art 6 (1) (a) for data whose processing you have consented to, (b) for data that we necessarily need to fulfil our contractual obligations, and (f) for processing that is necessary to safeguard the legitimate interests of us or a third party; and
(c) Legal obligation In the event that the processing of your data is necessary to fulfill one of our legal obligations, this is based on Art 6 Para 1 lit c.
V. DATA RETENTION
V. DATA RETENTION
§ 5.1 Settings. We retain user account data in accordance with your instructions and applicable laws. Depending on your chosen subscription plan, you may be able to adjust certain retention settings. Deleting user account data may result in the deletion or anonymization of certain other related information.
§ 5.2 Duration of storage. We may retain Other Information about you for as long as necessary to fulfill the purposes described in this Privacy Policy. This may include retaining your Other Information even after your account is deactivated, as long as necessary to pursue our legitimate business interests, conduct audits, comply with and demonstrate compliance with legal obligations, resolve disputes, and enforce our agreements.
In a nutshell
In a nutshell
We retain information for as long as necessary to provide the greenpass services or as is legitimate to support our business
VI. RECIPIENTS OF THE DATA WE PASS ON
VI. RECIPIENTS OF THE DATA WE PASS ON
§ 6.1 Guidelines and Practice. Here we describe the circumstances under which we may share and disclose information. Generally, you set your own policies and practices regarding sharing and disclosure of information, and we have no control over how you or other third parties share or disclose information.
§ 6.2 Instructions and applicable law.We will only share and disclose user account information in accordance with your instructions and applicable law.
§ 6.3 Third-party service providers and partners. We may engage third-party companies or individuals as service providers or business partners to process other information and support our business. For example, these third parties may provide virtual computing and storage services, or we may share business information to develop strategic partnerships with third parties to support our mutual customers. Before engaging a processor, we review its privacy, security, and confidentiality practices and enter into an agreement setting forth the relevant commitments.
(a) Tools and applications,connected to our platform and the greenpass services.
i. Website activities
| Zoho Page Sense | Trinkausstr. 7, 40213 Düsseldorf, Germany |
| Google Analytics | Gordon House, Barrow Street Dublin 4, Ireland |
ii. Customer inquiries
| Zoho CRM | Trinkausstr. 7, 40213 Düsseldorf, Germany |
| Zoho Forms | Trinkausstr. 7, 40213 Düsseldorf, Germany |
| Zoho Billing | Trinkausstr. 7, 40213 Düsseldorf, Germany |
| Zoho Bookings | Trinkausstr. 7, 40213 Düsseldorf, Germany |
| Zoho Campaigns | Trinkausstr. 7, 40213 Düsseldorf, Germany |
| Zoho Meeting | Trinkausstr. 7, 40213 Düsseldorf, Germany |
iii. Emails. We use the following services to send emails, which handle both processing and analysis of the transmission:
| Zoho Mail | Trinkausstr. 7, 40213 Düsseldorf, Germany |
iv. Performance and quality of greenpass services. We use the following services to monitor performance and quality:
| Zoho Analytics | Trinkausstr. 7, 40213 Düsseldorf, Germany |
v. Customer relationships and HR management. We use the following CRM/CMS software to improve customer and HR management:
| Zoho CRM | Trinkausstr. 7, 40213 Düsseldorf, Germany |
| Zoho Recruit | Trinkausstr. 7, 40213 Düsseldorf, Germany |
| Zoho Desk | Trinkausstr. 7, 40213 Düsseldorf, Germany |
| Zoho Projects | Trinkausstr. 7, 40213 Düsseldorf, Germany |
| Zoho Sign | Trinkausstr. 7, 40213 Düsseldorf, Germany |
| Zoho Workdrive | Trinkausstr. 7, 40213 Düsseldorf, Germany |
| Trainer Central | Trinkausstr. 7, 40213 Düsseldorf, Germany |
vi. Retargeting. We use the retargeting technologies of the following services to show you personalized advertising on our partners' websites:
| Google Ads | Gordon House, Barrow Street Dublin 4, Ireland |
vii. Marketing through partners. We use the following services for our marketing, particularly advertisements and analysis of customer reviews:
| Zoho Marketing Automation | Trinkausstr. 7, 40213 Düsseldorf, Germany |
| Zoho Campaigns | Trinkausstr. 7, 40213 Düsseldorf, Germany |
viii. Newsletter. To send the newsletter we use
| Zoho Campaigns | Trinkausstr. 7, 40213 Düsseldorf, Germany |
ix. Surveys. We use the following services to improve our products through voluntary surveys, learn more about your usage behavior, and adapt marketing activities accordingly.
| Zoho Survey | Trinkausstr. 7, 40213 Düsseldorf, Germany |
| Zoho Forms | Trinkausstr. 7, 40213 Düsseldorf, Germany |
(b) More information about the type, scope, purposes and, in particular, opt-out options for the services described in Section 6.3(a) can be found in the privacy policies of the respective provider.
(c) The platform also contains links to other websites. These are provided for informational purposes only. We have no control over these websites or the content presented there. Such websites are therefore not covered by the provisions of this Privacy Policy. If you click on a link, the operator of such a website may collect data about you and process it in accordance with its own privacy policy, which may differ from ours.
(d) External tools and applications. In addition to the above, you have the option to interact with a number of social networks on the platform via plugins. Clicking on a plugin for one of these social networks activates it and establishes a connection to the server of the respective network. We have no influence on the scope or content of the data transmitted to the operator of the respective social network when clicking on the plugin.
§ 6.4 Third-party services. You may enable third-party services. We require each third-party service to disclose all permissions to access information in the greenpass Services, but we do not guarantee that they will actually do so. If enabled, we may share Other Information with third-party services. Third-party services are not owned or controlled by us, and third parties granted access to Other Information may have their own policies and practices regarding the collection, use, and disclosure of Other Information.
§ 6.5 Change concerning our company. If we undergo or are subject to a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of our assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, similar transaction or proceeding, or take any steps in contemplation of such activities, some or all of the Other Information may be disclosed or transferred, subject to customary confidentiality agreements.
§ 6.6 Aggregated or anonymized information.We may disclose or use aggregated or anonymized Other Information for any purpose. For example, we may share it with potential or existing business partners for business or research purposes.
§ 6.7 Compliance with laws. If we receive a request to provide information, we may disclose other information if we believe that disclosure is in compliance with, or required to comply with, an applicable law, regulation or legal process.
§ 6.8 Enforcement of our rights, prevention of fraud, and security.We may disclose information to protect and defend our or third parties' rights, property, or safety, including to enforce agreements or policies, or in connection with investigations and prevention of fraud or security issues.
§ 6.9 Consent.We may share other information with third parties if we have your consent.
In a nutshell
In a nutshell
We do not sell or otherwise share your information with third parties unless it helps us provide the greenpass services or we are legally required to do so
VII. COOKIES
VII. COOKIES
§ 7.1 Definition. Cookies are small text files that we send to your computer or mobile device to enable the functionality of the greenpass services or to facilitate their use. New cookies are sent to each user account and browser, so they are always unique.
§ 7.2 Types of cookies. Cookies can be divided into different categories depending on their characteristics, as shown below.
(a) Storage period.
i. Temporary cookies remain only as long as your browser is open and are automatically deleted when you close your browser. They therefore only exist for the specific period of use of the greenpass services, i.e., a "session".
(b) Creator of the cookies.
(c) Need.
§ 7.3 Our cookies. We use the following cookies:
(a) Necessary cookies;
A detailed list of the cookies we use can be found in Appendix § 7.3 of this Privacy Policy.
§ 7.4 Rejection of cookies. You can refuse all cookies except those that are strictly necessary for the greenpass services, the necessary cookies. Such refusal may happen by
(a) when visiting the website via the cookie banner; or
(b) subsequently in your browser settings. How this works depends on the browser used. You can find a link to the instructions for the most common browsers here:
In a nutshell
In a nutshell
we have the right to always collect technically necessary cookies
VIII. SECURITY
VIII. SECURITY
§ 8.1 We take the security of your data very seriously. We work hard to protect the Other Information you provide from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the Other Information we collect, process, and store, as well as current technology advances. Given the nature of communications and information processing technologies, we cannot guarantee that information will be absolutely secure from intrusion by others while being transmitted over the Internet or while stored on our systems or otherwise in our care. When you click on a link to a third-party website, you will leave the Platform, and we have no control over, and do not endorse, the content of third-party websites.
In a nutshell
In a nutshell
We are constantly trying to improve the security of our system to protect your data. This is an important concern for us.
IX. AGE RESTRICTIONS
IX. AGE RESTRICTIONS
§ 9.1 Minimum age. We only permit the use of greenpass services to persons who are at least 16 years old.
In a nutshell
In a nutshell
You may not use the greenpass services without the consent of your legal guardian if you are under 18 years of age
X. EFFECTIVENESS AND CHANGES TO THE PRIVACY POLICY
X. EFFECTIVENESS AND CHANGES TO THE PRIVACY POLICY
§ 10.1 Effectiveness. This privacy policy will take effect on December 1, 2023.
§ 10.2 Changes. We may change this Privacy Policy from time to time. Such changes may be necessary as laws, other regulations, industry standards, or our business and the related services we offer evolve. We will post the changes on this website and encourage you to revisit our Privacy Policy from time to time to stay informed. If we make changes that materially alter the rights granted to you under this Privacy Policy, we will provide you with additional notice, for example, by email or through the Platform. If you do not agree to the changes to the Privacy Policy, you should deactivate your user account.
In a nutshell
In a nutshell
Please check this page regularly as this privacy policy may change over time
XI. INTERNATIONAL DATA TRANSFERS
XI. INTERNATIONAL DATA TRANSFERS
§ 11.1 We may transfer your personal data to countries outside the European Economic Area for processing. We will strictly ensure that the level of protection required by the GDPR is maintained during such processing.
§ 11.2 The processing pursuant to Section 11.1 is carried out on the basis of a data processing agreement containing the standard contractual clauses of the Commission of the European Union.
In a nutshell
In a nutshell
We have entered into contracts to ensure that all your data is secure, even if it is processed outside the EU
XII. DATA PROTECTION OFFICER
XII. DATA PROTECTION OFFICER
§ 12.1 To communicate with our data protection officer, please send an email to florian.kraus@greenpass.io
In a nutshell
In a nutshell
This is the person you can contact with any concerns regarding data protection
XIII. IDENTIFICATION OF THE DATA CONTROLLER AND THE DATA PROCESSOR
XIII. IDENTIFICATION OF THE DATA CONTROLLER AND THE DATA PROCESSOR
§ 13.1 Data protection law in certain jurisdictions distinguishes between the "controller" and the "processor" of information. Generally, the customer is the controller of registration data and account data, and we are the processor of registration data and the controller of other information.
In a nutshell
In a nutshell
We acknowledge our responsibility in handling your data and our crucial role in maintaining the security and protection of data
XIV. YOUR RIGHTS
XIV. YOUR RIGHTS
§ 14.1 Individuals located in certain countries, including the European Economic Area and the United Kingdom, have certain legal rights with respect to their personal data. Subject to legal exceptions, you have the right to request access to information, as well as to request that that information be updated, deleted, or corrected. We strive to enable you to do this through the settings and tools provided in your greenpass Services user account.
§ 14.2 To the extent that our processing of your personal data is subject to the EU General Data Protection Regulation (GDPR), we rely on our legitimate interests described above to process your data. We may also process other information that constitutes your personal data for direct marketing purposes, and you have the right to object to our use of your personal data for this purpose at any time.
In a nutshell
In a nutshell
You have the right to know what personal data we have stored about you as an individual
XV. DATA PROTECTION AUTHORITY
XV. DATA PROTECTION AUTHORITY
§ 15.1 Data Protection Authority. Subject to applicable law, you also have the right
(a) restrict our use of other information that constitutes your personal data; and
(b) lodge a complaint with your local data protection authority or the Austrian Data Protection Authority, which is our lead supervisory authority in the European Union. If you are located in the European Economic Area and believe that our storage of your personal data falls within the scope of the GDPR, you may address questions or complaints to our lead supervisory authority:
Austrian Data Protection Authority
Barichgasse 40-42,
1030 Vienna
Austria / Europe
Phone: +43 1 52 152-0
Mail: dsb@dsb.gv.at
§ 15.2 United Kingdom. If you are a resident of the United Kingdom and believe that we are managing your personal data in accordance with the personal data laws applicable there, you may address any queries or complaints to the UK supervisory authority, the Information Commissioner's Office
In a nutshell
In a nutshell
Our handling of data protection matters is monitored by government authorities, which you can contact if you have any questions or concerns
XVI. CONTACT INFORMATION
XVI. CONTACT INFORMATION
§ 16.1 You may also contact us if you have any questions about this Privacy Policy or our activities, or if you wish to exercise any of your legal rights. We will respond to you within a reasonable timeframe. You can reach us at contact@greenpass.io or at the following postal address:
