Privacy Policy

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Privacy Policy Statement

Genervest do not sell data or have a commercial model that aims to monetise your private and/or personal information. Genervest understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our Genervestors and Genervestees and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law. In simple terms this means we will only use your information to serve you better and look after you.

 

1 Definitions

 

AML:
Means anti-money laundering, refers to the laws, regulations and procedures we follow intended to prevent criminals from using our Platform and disguising illegally obtained funds as legitimate income
Business:
Is any legal entity engaged in a renewable energy, energy efficiency, electric mobility or other energy transition activity.
Data Protection Officer: 
Compliance Manager. Email address: compliance@genervest.org
DD:
Means due diligence, which is the process of carefully checking the credentials and commercial plans of a legal person and entity.
Genervest:
Refers to Genervest BV, Genervest SCE Limited, Stichting Genervest, the Website and the Platform.
Genervestee(s):
Refers to any legal entity or person that wishes to receive funding from Genervestors and support services from Genervest.
Genervestor(s):
Are the people who become members of Genervest SCE and lend money to or invest in Genervestees.
Greenpeace:
Is used generically for the organisation as a whole where one specific office and Greenpeace International are not clearly identified.
KYC:
Means know your customer, which is the process of checking a customer’s details to ensure compliance requirements are met.
Platform:
Platform refers to the Genervest SCE members area of the Website where Genervestees and Genervestors relationships are managed on block-chain.
Project:
Project is used to distinguish between Genervestees and their projects.
Website:
Website refers to the domain https//:www.genervest.org

 

2 Information About Us

Genervest BV is a company registered in the Netherlands under establishment number: 000044493991. Registered address: NDSM-plein 32, 1033WB Amsterdam, Netherlands. RSIN number: 860783935.
Genervest BV is a founding member of Genervest SCE Limited, which is a European Cooperative Society (SCE) regulated under the European Commission Council Regulation No: 1435/2003 Statute for a European Cooperative Society. The cooperative is established in Croatia where financial services are regulated by HANFA, which is the Croatian Agency for Oversight of Financial Services. Genervest SCE does not offer financial services and is not a bank so does not need to be regulated as a financial institution. Genervestors can make loans and investments by becoming members of the Genervest SCE and investing in the Genervestee investments the cooperative has decided to invest in and listed on the Website.



3 What Does This Privacy Policy Cover?

This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

 

4 What Is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 6, below.

 

5 What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
  1. a) The right to be informed about our or collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 12.
  2. b)         The right to access the personal data we hold about you. Part 11 will tell you how to do this.
  3. c)         The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 12 to find out more.
  4. d)         The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 12 to find out more.
  5. e)         The right to restrict (i.e. prevent) the processing of your personal data.
  6. f)           The right to object to us using your personal data for a particular purpose or purposes.
  7. g)         The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
  8. h)         The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
  9. i)           Rights relating to automated decision-making and profiling. Part 7 explains more about how we use your personal data, including automated decision-making and profiling.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 12.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 12.

 

6 What Personal Data Do You Collect and How?

Depending upon your use of our Website, we may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. We do not collect any sensitive personal data or personal data relating to children or data relating to criminal convictions and/or offences.
 
Data collected
How we collect the data
Identity information including: name, title, date of birth, gender;
Direct interactions. You may give us your identity, contact and financial data by filling in forms or by corresponding with us. This includes personal data you provide when you create an account on our website and use our services;
Contact information including address, email address, telephone number;
Direct interactions. You may give us your identity, contact and financial data by filling in forms or by corresponding with us. This includes personal data you provide when you:
create an account on our website;
use our services;
request marketing to be sent to you;
enter a competition, promotion or survey; or give us feedback or contact us;
Business information including business name, job title, profession;
Direct interactions. You may give us your business identity, contact and financial data by filling in forms or by corresponding with us;
Payment information including card details, bank account numbers;
Direct interactions. You may give us your financial data by filling in forms or by corresponding with us. This includes personal data you provide when you create an account on our website and use our services;
Profile information including preferences, interests, investment history;
Direct interactions with the Website;
Data from third parties including contact information, profile information.
This includes personal data you provide when you create an account on our Website and use our partner services.

 

7 How Do You Use My Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:
 
What we do
What data we use
Our lawful basis
Administering our business;
Identity information. Contact information including address, email address, telephone number. Data from third parties including contact information, profile information;
Register you as a new customer. Set up your wallet and accounts, complete your contracts. We will need to  fulfil regulatory and legal requirements like Anti-Money-Laundering (AML), Know-Your-Customer (KYC) and Due Diligence (DD).
Supplying our services to you;
Identity information. Contact information including address, email address, telephone number;
Legitimate interests including managing our relationship with you completing contractual and communication requirements. We will need to use your data to complete Website services and protect you and the Website, this will include things like troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data.
Managing payments for our services;
Identity information. Contact information including address, email address, telephone number. Payment information including card details, bank account numbers.
Legitimate interests including receiving investment payments and managing accounts on the blockchain. We will need to process your payments and complete transactions for you.
Personalising and tailoring our services for you;
Identity information. Contact information including address, email address, telephone number. Profile information. including preferences, interests, investment history;
Legitimate interests including providing you with information you have requested, and making sure we don’t email you with information you do not want to receive. This will include making suggestions and recommendations to you about services that may be of interest to you. We will also seek to learn, evaluate and understand how effective this selection service is for you;
Communicating with you;
Identity information. Contact information including address, email address, telephone number;
Legitimate interests including learning, improving, and developing our services to make it serve its purpose more effectively;
Supplying you with information by email that you have opted-in-to (you may opt-out at any time by logging into your account and selecting your preferences.
Identity Information including: name, title, date of birth, gender. Profile information including preferences, interests, investment history.
Legitimate interests including providing you with information you have requested, and making sure we don’t email you with information you do not want to receive. 
 
With your permission and where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email with information, news, and offers on our products or services. You will not be sent any unlawful marketing or spam. 
We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will not share your personal data with any third parties except Greenpeace for marketing purposes and you will be able to opt-out at any time.
We use the following automated systems for carrying out certain kinds of decision-making and profiling. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the Data Protection Legislation gives you the right to do so. Please contact us to find out more using the details in Part 12.
The following automated decision-making methods may be used:
  • KYC, AML and DD to ensure you are who you say you are, and that we can comply with EU and international regulations and our policies.
  • Algorithmic and AI assisted Project, Business, Genervestee and Genervestor approval processes to reduce the transactions costs of Genervest and therefore provide a cost effective solution.
The following automated profiling may take place:
  • According to your data entries we may profile you by location, investment interests, investor type, “Greenpeace Supporter” and other segmentation as is useful from time to time to serve you better with information relevant to you. 
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 11.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights. 

 

8 How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
 
Type of data
How long we keep it
Identity Information including name, title, date of birth, gender;
Until you close your account or request us to delete it;
Contact information including address, email address, telephone number;
Until you close your account or request us to delete it;
Business information including business name, job title, profession;
Until you close your account or request us to delete it;
Payment information including card details, bank account numbers;
As defined by regulations from time to time or until you close your account or request us to delete it, whichever is the earlier;
Profile information including preferences and interests, purchase history.
Until you close your account or request us to delete it.

 

9 How and Where Do You Store or Transfer My Personal Data?

We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:
We use specific contracts with external third parties that are approved by the European Commission for the transfer of personal data to third countries. These contracts require the same levels of personal data protection that would apply under the Data Protection Legislation. More information is available from the European Commission.
AND
Where we transfer your data to a third party based in the US, the data may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar levels of data protection to those in Europe. More information is available from the European Commission.
Please contact us using the details below in Part 12 for further information about the particular data protection mechanisms used by us when transferring your personal data to a third country.
The security of your personal data is essential to us and to protect your data, we take a number of important measures, including the following:
  • Limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
  • Procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so;
  • Not retaining personal data beyond the immediate requirements of the business operations.
 

10 Do You Share My Personal Data?

We will not share any of your personal data with any third parties except Greenpeace for any purposes, subject to the following exceptions.
If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our  obligations, and the third party’s obligations under the law, as described above in Part 9.
If any personal data is transferred outside of the EEA, will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 9.
If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

 

11 How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us  for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 12. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

 

12 How Do I Contact You?

To contact us  about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of the Compliance Manager): Email address: compliance@genervest.org.

13 Changes to this Privacy Notice

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection. Any changes will be made available on the Website and emailed to all account holders that we have contact details for.
 
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