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1.1 This Privacy Policy, together with the terms and conditions located here set out the basis on which any Personal Information (as defined in paragraph 2.2 below) that we collect from you, or that you provide to us, will be used, stored and processed by us.
1.2 We are the "responsible party" or "controller" for purposes of applicable data protection legislation in respect of all your Personal Information that you submit to us via our websites, mobile applications and any other platforms of ours that you may access (the "Tweak Carbon Platforms") and/or that may be collected by us through any correspondence and/or communication with you or from third parties.
1.3 Any references to "we", "us" or "our" in this Privacy Policy shall be to Tweak Carbon, a division of Next176 Proprietary Limited ("Tweak Carbon"). References to "user", "you" or "your" in this Privacy Policy shall be to any user of the Tweak Carbon Platforms and the Products and Services. Next176 Proprietary Limited is a wholly-owned subsidiary of Old Mutual Limited.
1.4 This Policy does not apply to the practices of third parties (including, without limitation, their websites, platforms and/or applications) which we do not own or control or individuals that we do not manage or employ. These third-party platforms may have their own privacy policies and terms and conditions and we encourage you to read them before using those third-party platforms.
2.1 When you use the Tweak Carbon Platforms and the products and services provided via the Tweak Carbon Platforms (the "Products and Services") we may collect Personal Information that you provide to us. For purposes of this Privacy Policy, "Personal Information" shall mean any information of a personal nature by which a data subject can be identified, such as a data subject's name, postal address, email address, telephone number, home country, postal code, date of birth, gender, age, payment and/or financial details.
2.2 In particular, we may collect and process the following information (which may include Personal Information) about you ―
2.2.1 your answers to the carbon footprint quiz;
2.2.2 your transactional information
2.2.3 information that you provide to us and/or allow the Tweak Carbon Platforms to access, such as your name, contact information, location, and age;
2.2.4 information collected by cookies, and in this regard please also review our Cookie Policy;
2.2.5 details of your visits to the Tweak Carbon Platforms (including, but not limited to, traffic data, location data and other communication data and the resources that you access);
2.2.6 information that we may ask you for if you report a problem with the Tweak Carbon Platforms and/or the Products and Services
2.2.7 information provided by you if you contact us, or if we contact you;
2.2.8 transactional, financial and payment information related to your purchases on the Tweak Carbon Platforms and/or when you make use of our Products and Services;
2.2.9 information about you when you voluntarily register with us to receive news, complete any "contact us" forms, or complete any user surveys or feedback forms; and/or
2.2.10 your name, email address and country of residence if you would like to receive one of our newsletters or marketing materials.
2.2.11 if you have given consent to our third-party API provider 22seven, all your transactional banking data, including transaction history, account balances, and other financial information. See clause 6.
2.3 The supply of your Personal Information is voluntary; however, you acknowledge that we cannot make certain Products and Services available to you and/or provide certain functionalities on the Tweak Carbon Platforms if you do not wish to supply such Personal Information.
2.4 We may also use third-party companies to monitor traffic, which may, in some instances, store your information, including the Personal Information you submit to such third parties.
2.5 Certain categories of Personal Information are recognised as special or sensitive, including information about religious beliefs, philosophical beliefs, political opinions, race and ethnic origin, trade union membership, health information, information about your sex life, biometric information or information about your criminal behaviour. In limited cases, we may collect and process such sensitive or special Personal Information about you. We will only collect and process such sensitive or special Personal Information with your explicit consent, save where we have another lawful basis.
3.1 We collect your Personal Information, so that we can provide our Products and Services to you. We only collect as much data as we need.
3.2 We collect Personal Information in different ways on the Tweak Carbon Platforms, such as when you directly give us your Personal Information. This includes when ―
3.2.1 you visit the Tweak Carbon Platforms;
3.2.2 you make purchases of the Products and Services via the Tweak Carbon Platforms;
3.2.3 you register to receive marketing or correspondence from us;
3.2.4 you provide certain Personal Information (such as your name, address, telephone and e-mail address) by filling in forms or by corresponding with us;
3.2.5 you request information to be sent to you; and/or
3.2.6 you provide feedback to us.
3.3 In limited circumstances, we may collect Personal Information from third parties or from public sources, such as from external services providers contracted by us to maintain certain sections of the Tweak Carbon Platforms. Such third parties may also include our affiliates and subsidiaries, regulatory bodies, other companies providing services to us and information we access where we make use of publicly available sources of information.
3.4 From time to time we may also request your consent to the collection and processing of your Personal Information. We will provide specific notice at the time of collection and obtain your consent.
4.1 We may use your Personal Information for the following purposes ―
4.1.1 to verify and keep a record of your identity;
4.1.2 to provide our Products and Services to you;
4.1.3 to manage our relationship with you;
4.1.4 to improve your user experience on the Tweak Carbon Platforms;
4.1.5 to monitor and analyse your conduct on the Tweak Carbon Platforms to ensure compliance with laws;
4.1.6 to process and facilitate payments you make via the Tweak Carbon Platforms;
4.1.7 for internal business purposes such as generating statistics and developing our strategic and marketing plans and for administrative and legal purposes;
4.1.8 for systems testing and to diagnose technical and service problems, maintenance and development of the Tweak Carbon Platforms;
4.1.9 to ensure that the content on the Tweak Carbon Platforms is presented in the most effective manner for you and for your device;
4.1.10 to market our Products and Services, where you have consented to being contacted for such purposes;
4.1.11 to provide you with information on the Tweak Carbon Platforms that you request from us and/or to contact you about Products and Services that you request from us;
4.1.12 to carry out statistical and marketing research and for forecasting;
4.1.13 to allow you to participate in interactive features of the Tweak Carbon Platforms, when you choose to do so;
4.1.14 for information security, crime prevention and detection and legal purposes;
4.1.15 to carry out and implement any contracts that may form between us; and
4.1.16 to notify you about changes to the Tweak Carbon Platforms and/or the Products and Services.
4.1.17 Leaderboard Display - We process your data to provide the leaderboard feature, which displays user statistics, including your tier status, CO2 footprint, and other relevant information. This enables you to see how you compare to other users within the Tweak Carbon community.
5.1 You may submit and contribute content including attendance data, pictures, messages and comments ("Your Content") to the website.
5.2 Where Your Content contains the Personal Information of third parties, you warrant that you have complied with applicable data privacy laws and that you have duly obtained consent to collect and process such Personal Information from those third party data subjects whose Personal Information form part of Your Content.
5.3 Further, you undertake and warrant that to the extent that Your Content includes data (including Personal Information and special Personal Information) of a minor (being a person under the age of 18 years), that you have obtained the explicit written consent of that minor’s parent or guardian to process and upload such data onto the Tweak Carbon Platforms. Under no circumstances whatsoever will we be liable to any third persons where you fail to obtain such consent and it is your responsibility to do so.
5.4 You agree that where Your Content contains Personal Information of third parties that you collected using the Tweak Carbon Platforms, Tweak Carbon will be acting as an "operator" or "processor" in respect of such Personal Information.
6.1 In order to provide you with a comprehensive view of your CO2e footprint and assist you in managing your carbon footprint more effectively, we offer the option to link your bank accounts to our platform using a third-party API provider, 22seven.
6.2 By consenting to link your bank accounts through 22seven, you authorize us to access, collect, and process your transactional banking data from those linked accounts. This includes transaction history, account balances, and other financial information.
6.3 We want to assure you that we do not store your online banking credentials, such as usernames and passwords. Your login credentials are securely handled by 22seven, and we only receive and process the necessary transactional data for our platform's purposes.
6.4 Please note that our access to your transactional banking data is read-only, and we do not have the ability to initiate any financial transactions on your behalf. Your banking data is used solely for the purpose of providing you with personalized financial insights and recommendations.
6.5 22seven, as our third-party API provider, is subject to its own privacy policy and security practices. We encourage you to review 22seven's privacy policy to understand how they collect, use, and protect your banking data.
6.6 If you choose to unlink your bank account from our platform or withdraw your consent, we will no longer have access to your transactional banking data through 22seven. However, any previously collected data will be retained in accordance with our data retention policy as outlined in this privacy policy.
6.7 Please note that you have the right to withdraw your consent for the collection and processing of your transactional banking data at any time. To do so, you can manage your linked bank accounts settings within your account or contact our support team for assistance.
6.8 We take the security and confidentiality of your transactional banking data seriously. If you have any concerns or questions about how your banking data is handled, please don't hesitate to contact us at nala@tweakcarbon.com with "Transactional Banking Data" in the subject line.
7.1 We may disclose your Personal Information to our affiliates, agents, advisors, employees and/or third-party service providers and suppliers who assist us to interact with you via the Tweak Carbon Platforms or to provide the Products and Services to you, and thus need to know your Personal Information in order to assist us and to communicate with you properly and efficiently. We will ensure that all such employees and/or third-party service providers having access to your Personal Information are bound by appropriate and legally binding confidentiality and non-use obligations in relation to your Personal Information.
7.2 We may also provide information to third party service providers who process data on our behalf to help run some of our internal business operations including email distribution, information technology services and customer services.
7.3 We may be required to disclose your Personal Information due to legal or regulatory requirements. In such instances, we reserve the right to disclose your Personal Information as required in order to comply with our legal obligations, including but not limited to complying with court orders, warrants, subpoenas, service of process requirements or discovery requests.
8.1 We may store your Personal Information using our own secure on-site servers or other internally hosted technology. Your Personal Information may also be stored by third parties, via cloud services or other technology, whom we have contracted with to support our business operations.
8.2 We will not retain your Personal Information longer than the period for which it was originally required, unless we are required by law to do so, or you consent to us retaining such information for a longer period. Where your information is no longer required, we will ensure it is disposed of in a secure manner and, where required by applicable law, we will notify you when such information has been disposed of.
8.3 We will retain the transactional, financial, and payment information collected for as long as necessary to fulfil the purpose for which it was collected and as required by applicable laws and regulations. Once the data is no longer needed, we will securely dispose of it.
9.1 We may, from time to time, transfer, store or host your Personal Information outside of your jurisdiction. Should your Personal Information be transferred outside your jurisdiction, we shall ensure that at least the same level of data protection will be applied in the country where the data is being processed and that we and the recipient at all times act in compliance with applicable privacy laws.
9.2 We will at all times ensure that appropriate security safeguards are in place to secure and protect such Personal Information and take measures to ensure that the Personal Information handled will receive the level of protection as required by all applicable laws.
9.3 An example of where your Personal Information may be transferred to another country is where a service provider whom we rely on hosts your Personal Information in a foreign country.
9.4 If you have provided your transactional data, please note that this data may be transferred outside of your jurisdiction to our secure servers or other technology for processing. Rest assured that we will take appropriate measures to ensure the security and protection of your Personal Information, and we will comply with all applicable privacy laws regarding cross-border data transfers.
10.1 We are committed to protecting your Personal Information in a variety of ways.
10.2 We will ―
10.2.1 take appropriate legal, technical and organisational measures to ensure that your Personal Information is kept secure and is protected against unauthorised or unlawful processing, accidental loss, destruction or damage, alteration, disclosure or access;
10.2.2 treat your Personal Information as strictly confidential;
10.2.3 where legally required, promptly notify you if we become aware of any unauthorised use, disclosure or processing of your Personal Information; and
10.2.4 upon your request, promptly return or destroy any and all of your Personal Information in our possession or control.
10.3 We have put in place procedures to deal with any suspected data security breaches and will notify you and any applicable regulator of a suspected breach or unauthorised disclosure, where we are legally required to do so.
10.4 We will do our best to protect your Personal Information, and we will use technology that will help us to do this, however, the transmission of information via the internet is not completely secure and we cannot guarantee the security of your information transmitted to or via the Tweak Carbon Platforms.
10.5 We take reasonable measures to maintain the accuracy and security of the information displayed on the leaderboard. However, please be aware that we cannot guarantee the absolute security and accuracy of the data presented.
11.1 We acknowledge that we may only use your Personal Information for purposes of direct marketing (such as sending you email marketing and newsletters) where it is permissible to do so in terms of applicable data protection legislation.
11.2 We will ensure that you have a reasonable opportunity to object to the use of your Personal Information for direct marketing purposes when we collect the Personal Information from you and in each instance where we may send you direct marketing communications. This will generally be in the form of an opt-in function and in the form of unsubscribe and opt-out functionalities.
11.3 We will not use your Personal Information to send you direct marketing communications if you have requested not to receive it. If you request that we stop Processing your Personal Information for direct marketing purposes, we shall do so. We encourage you to use the forms and links provided for this purpose in the marketing materials sent to you.
This Privacy Policy does not govern Personal Information provided to, stored on, or used by third-party providers and third-party websites. We recommend that when you enter a third party's website, you review its privacy policy as it relates to how such third parties collect, process, store and protect your Personal Information.
13.1 You have the ability to either accept or decline the use of cookies. You can configure your browser not to accept cookies. However, declining the use of cookies may limit your access to certain features of the Tweak Carbon Platforms.
13.2 Please review our Cookie Policy available at [insert] to understand how we use cookies and how you can manage your preferences in respect of cookies.
14.1 Please be aware that when you engage with green merchants or avail discounts through our platform, you may be directed to third-party platforms to complete transactions or access additional information. Any data you provide or that is collected on third-party platforms is subject to their respective privacy policies and practices.
15.1 Subject to certain exceptions and your jurisdiction, you have rights under applicable data protection law in relation to our use of your Personal Information, including the right to ―
15.1.1 review, or request access or copies of your Personal Information which is within our custody and control together with details about how we use that information. If you think any of the Personal Information that we hold about you is inaccurate, you may also request that we correct or rectify it;
15.1.2 to request that we delete or erase Personal Information in certain circumstances (such as in accordance with local data retention legal obligations);
15.1.3 withdraw any consent to processing that you have given us and prevent further processing if there is no other legitimate ground upon which we can process your Personal Information;
15.1.4 in certain circumstances, to require us to stop processing your Personal Information;
15.1.5 restrict processing: you can require certain Personal Information to be marked as restricted for processing in certain circumstances;
15.1.6 object to automated decision-making, including profiling; and
15.1.7 lodge a complaint with the relevant data protection regulator if you think we are in breach of any applicable data protection legislation.
15.2 In relation to all of these rights, please email us at the email address set out in paragraph 13.4 below. Please note that we may, where permitted under applicable law, charge a small administrative fee and/or request proof of identity.
15.3 In certain circumstances (for example where required or permitted by law), we might not be able to provide you with access to some of your Personal Information, but where appropriate we will notify you of the reasons for this.
15.4 You may request access to the Personal Information that we collect about you by sending an email to us at nala@tweakcarbon.com
16.1 You warrant that all information (including Personal Information) that you provide to us is accurate, truthful and current information.
16.2 You may not impersonate or misrepresent any person or entity or falsely state or otherwise misrepresent your affiliation with anyone or anything. Failure to adhere to this requirement will entitle us to, among other things, terminate your use of the Tweak Carbon Platforms and the Products and Services.
16.3 It is not intended that any provision of this Privacy Policy contravenes any provision of data protection legislation which may apply in your jurisdiction. Therefore, all provisions of this Privacy Policy must be treated as being qualified, to the extent necessary, to ensure that the provisions of data protection legislation are complied with.
16.4 We reserve the right to change this Privacy Policy from time to time, and in our sole discretion. We may send you a notice regarding material changes to this Privacy Policy, but we encourage you to frequently check this Privacy Policy for any changes. Your continued use of the Tweak Carbon Platforms and the Products and Services after any change in this Privacy Policy will constitute your acceptance of such changes.
17.1 At Tweak Carbon, we value your privacy and provide you with options to customise your experience, especially in regards to our leaderboard feature. Below, you'll find information on how to adjust your privacy settings to control the visibility of your data on the leaderboard.
17.1.1 Tweak Carbon introduces a leaderboard feature that displays user statistics, including your tier status, CO2 footprint, your name, your footprint trend, and how you compare to the community. By default, your name is visible to the entire community. However, you have the option to adjust your privacy settings based on your preferences:
17.1.2 To manage these settings, log in to your Tweak Carbon account and navigate to the settings section. You can customise who sees your data on the leaderboard, providing you with control over your privacy.
17.1.3 We respect your privacy choices and want to ensure you have the ability to make informed decisions about how your information is shared. Please note that any information you choose to make public on the leaderboard may be accessible by other users of Tweak Carbon.
You have the right to lodge a complaint in respect of our Processing of your Personal Information. You can contact the office of the regulator in your jurisdiction.
If you have any questions, comments and/or requests about this Privacy Policy, please contact us at nala@tweakcarbon.com with "Privacy Policy" in the subject line.
20.1 Full name: Tweak Carbon, a division of Next176 Proprietary Limited
20.2 Legal status: Private Company
20.3 Registration number: 2010/011767/07
20.4 Physical address: Mutual Park, Jan Smuts Drive, Pinelands, 7405
20.5 Website address: www.tweakcarbon.com
20.6 Email: nala@tweakcarbon.com
Last updated on [11/10/2023].
