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Privacy Policy

1. General

Offspend, a company operating under the trade name Greenly, processes your personal data to help you improve your ecological impact, taking care of the health of the planet and that of your data

As data controller, Offspend(Offspend SAS, registered in the Paris Trade and Companies Register under number 878 730 647 and domiciled at 9 rue de Quatrefages, 75005, France,) ("Offspend" or "we") is committed to protecting your privacy as well as the confidentiality and security of your personal data that it processes, in compliance with the applicable regulations relating to the protection of personal data, including in particular the amended "Informatique et Libertés" law of 6 January 1978 and the General Data Protection Regulation, EU 2016/679, known as the GDPR.

Personal data means any information that can identify you directly (e.g. your name) or indirectly (e.g. your IP address) ("Personal Data" or "Data").

This privacy policy explains how we handle your Personal Data, in order to inform and guide you towards a more environmentally responsible life, when you ("you", "User", "Customer") visit or use our Greenly services, consisting of the Greenly application, intended for individuals, and the Greenly Corporate SaaS platform, intended for companies ("Greenly Services") or when you browse the website ("Greenly Website"). We therefore invite you to read this privacy policy carefully.

2. Characteristics of the processing of your Personal Data

For the purposes of this Privacy Policy:

- A "Greenly Customer" is a person who uses the Greenly Services for individuals on the basis of a contract (i.e. the terms and conditions of use that you accept when creating your customer account);

- A "Prospect" is a person who visits the Greenly Services without creating a customer account;

- A "Company Representative" is a person who represents his or her company within the framework of the Greenly Services intended for companies by creating a customer account, and therefore by subscribing to a contract, or who subscribes to a demo;

- An "Internet user" is a person who browses the Greenly Site or theGreenly social networks (Facebook, Linkedin)


* At the end of these retention periods, your Personal Data, strictly necessary, may be archived in an intermediate database for administrative reasons (legal, accounting, tax, etc.). For example, it may be archived for a period of 5 years, from the end of the active database retention period, for litigation reasons (duration of the statute of limitations), or for 10 years for accounting reasons. At the end of these periods, the data will be deleted or anonymized.
We may also carry out statistical processing on anonymized data, as further processing for certain purposes in order to improve the Greenly Services and to carry out aggregate studies for the purposes of communication and information.

Furthermore, for the conclusion and execution of the contract, the control of access to the company (based on legitimate interest), if applicable, and the management of pre-litigation and litigation, Offspend is also required to process the professional contact details of the representatives of its suppliers and service providers for the duration of the contractual relationship, without prejudice to the legislative or regulatory provisions specific to certain categories of Personal Data imposing a particular period of retention or deletion of such Personal Data.

3. Do we share your Personal Data?

Your Personal Data is processed exclusively by Offspend for the purposes described in this privacy policy.

However, in order to provide you with the Greenly Services, to allow you to browse the Greenly Site or to fulfill certain legal obligations Offspend may transmit your Personal Data to our trusted service providers or recipients.

Here is a summary table :


4. Do we transfer your Personal Data outside the European Union?

our Personal Data that we process is hosted by Amazon Web Service within the European Union.

In order to provide the Greenly Services, we may transfer some of your Personal Data to trusted service providers located, or using servers, outside the European Union or the European Economic Area. In this case, we ensure that the service provider is located in a country with an adequacy decision from the European Commission or we put in place appropriate safeguards (standard contractual clauses adopted by the European Commission) with additional technical and organizational security measures (e.g. encryption), if applicable.

5. What security measures do we take to protect your Personal Information?

At Offspend the security of your Personal Data is a priority. Therefore we implement technical and organizational security measures to ensure the confidentiality, integrity and availability of your Personal Data, such as:

- Encryption of data in transit and at rest (SSL and AES 256);

- Secure servers at Amazon Web Service;

- Our Oxlin bank aggregation provider is ISO-27001 compliant and is a payment institution authorized by the Autorité de Contrôle Prudentiel et de Résolution (ACPR - Banque de France);

- Logical access controls for Offspend personnel (access identifiers and logs);

- Backups and business continuity plan.

6. What are your rights regarding your Personal Data and how can you exercise them?

As a data subject, you have the following rights:

A right to information: this privacy policy is intended to inform you about the processing of your Personal Data by Offspend.

A right of access: the right to know what Personal Data concerning you is processed, for what purposes, for how long, etc. and the right to obtain communication of it in an understandable format (proof of your identity may be requested in case of reasonable doubt).

A right of rectification: the right to correct, as soon as possible, inaccurate Personal Data concerning you (e.g. wrong age or address) or to complete this Personal Data.

A right to limitation: the right to request in certain cases (article 18 of the RGPD) the temporary stop of the processing of your Personal Data by Offspend (e.g. while Offspend processes a request of opposition from you).
A right to object: the right to object to the processing of your Personal Data by Offspend based on legitimate interest (e.g. clicking on the unsubscribe link in our Newsletter that you receive), unless there are compelling legitimate grounds that override your interests (e.g.

A right to erasure ("right to be forgotten"): the right to request Offspend to erase your Personal Data, you can exercise this right by deleting your account directly from the Greenly Services. However, we may need to retain some of the Personal Data to comply with a legal obligation.

A right to portability: the right to receive your Personal Data processed within the Greenly Services, on the legal basis of your consent or contract, in a structured, commonly used and machine-readable format, and to pass it on to another control
A right to withdraw your consent where the processing of your Personal Data is based on your consent.
A right to arrange in advance and during your lifetime the conditions under which your Data will be stored and communicated, after your death.

The right to lodge a complaint with the supervisory authority in your country to challenge our practices in relation to the protection of your Personal Data (in France this is the CNIL).

In order to exercise your rights, please contact us directly: by email :[email protected]by post: Délégué à la Protection des Données, Offspend, 9 rue de Quatrefages, 75005, France.

In order to keep this privacy policy up to date, Offspend may have to modify it. In this case, we will inform you by means of a special notice posted on the Greenly Services and/or the Greenly Site.