Privacy policy as per D.L. 30 June 2003, n.196 regarding the protection of personal data.

A) INTRODUCTION

1. Treedom S.r.l., registered in Via della Piazzuola 45, Florence, Italy, is a company that promotes agricultural and forestry projects with a social and environmental relevance worldwide.

2. Treedom is the owner of the web platform www.treedom.net, which users (individuals, companies, institutions, etc., v. infra) can ask that one or more trees can be planted in their name in one of the Treedom projects. Users can also gift trees to others, write virtual text messages on the trees, calculate and neutralize their carbon footprint (expressed in CO2), follow their trees through images and info, share their actions on social networks, receive advice on how to offset their impact on the environment.

3. The whole of users is called community. Users are divided into two categories: i) “individual users”, that is people, and ii) “corporate users”, that is legal entities, institutions, etc. Every users has a personal page on the platform with which he can interact with the community, visualize his activity and eventually compete with other community users to become a green user.

B) SOURCE AND TYPE OF COLLECTED DATA

1. Treedom collects and processes the so called “communal” data given by users in the following ways, eventually integrating them with data collected from public inventories, which will also processed in the same way.

2. The data collected and used by Treedom for the reasons stated earlier and further indicated later, are divided between so called data “essential to the subscription” (necessary to subscribe to the community) and “non essential to the subscription” (data which are needed in order to use certain services within the community, but not essential to the subscription itself).

3. The data essential to the subscription are:

i) for the individual user: name, surname, email address, gender, date of birth, city of residence;

ii) for the corporate user: name and/or brand, email address, name and surname of a person in charge and his/her title in the organization.

4. The data mentioned in paragraph 3 are collected in the registration page when filling the form, but they can also be collected without filling the form by choosing the option “register” on the biggest social networks like Facebook, Twitter, Google+. When registering through a social network and logging in from a social network (even in subsequent logins), the person authorizes expressly Treedom to access the data collected in the personal page of said social network. Treedom uses these data to fulfill the profile of every community user and to keep it constantly updated.

5. Data that are not essential to the subscription are:

i) for the individual user: profile image, brand and model of the car, brand and model of the motorbike, daily commute, favorite hangouts, mobility habits, visited places, eating habits, home consumption.

ii) for the corporate user: corporate brand, description of corporate activities, corporate consumption, number of company cars, amount of kilometers traveled, number of employees.

6. Every user of the community can ask Treedom and its associates to plant one or more trees in the name of another person, within the scope of Treedom projects.

7. In these cases the requesting user has to give the email address of the recipient, so that Treedom can send an invitation to accept the tree as a gift. If the recipient is interested in accepting the tree and has not yet subscribed to the community, a link in the email will make it possible for him to access the “register to the community” page, where he can fill in the requested data. If the recipient doesn't subscribe, Treedom will send 3 further emails as reminders, and, in case he/she does not reply, Treedom will finally cancel the email address from its database.

C) PROCEDURES AND PURPOSES OF PROCESSING

1. Treedom S.r.l. collects information manually, that is to say through informatic and telematic and also manually, according to the rules and regulations of d1.lgs.30.6.2003, n.196 and of the EU regulations pertaining to these matters.

2. The collection and usage by Treedom of these data in the ways previously described is intended only for the activation and functioning of the services provided by Treedom, and for the reasons described in the introduction, to create a personal page for each user inside the community, to send to activity notifications to users, for statistical, study and market research purposes, and to comply with the Italian and European rules and regulations.

3. Treedom reserves the possibility to send community users newsletters and informative/promotional emails related to services and initiatives promoted by the company and/or its commercial partners; if the user decide that he/she prefers to not receive communications of such nature by Treedom, he/she can follow the instructions given in the communications themselves to state his/her preference.

4. The personal data provided by each user at the moment of subscription (be it “individual user” or “corporate user”), in addition to the ones provided while using the services offered by Treedom and those collected in the personal pages of the social network (after previous consent), are considered public information (with the exception of the email address provided at the moment of subscription to the community, and/or following the subscription and/or independently from the subscription itself, which Treedom guarantees to not disclose without previous authorization from the user); with this expression we mean the information that are always available publicly, and those information which, even if concealable, the user decides to make public.

5. The act of disclosing these information means that they will be:

visible to everybody and can be associated to each user (name, image, activity within the community, sent messages, trees gifted, current city, etc.) even outside the Treedom community;
can be visible if searched on Treedom or on a public search engine; it is important to keep in mind that if you share information publicly, they can be indexed by a search engine.

6. Information that are always publicly available are:

name;
surname;
user ID;
profile image;
gender;
current city;
number of trees planted and/or gifted;
amount of CO2 emissions calculated;
amount of CO2 emissions neutralized;
amount of CO2 available to be further neutralized;
text messages on the trees.

7. Furthermore, on the Treedom community and on the personal page of each user a so called “stream” will be visualized, which is a dashboard updated in real time with the activity of all users of the community, as, for example: planted and/or gifted trees, messages left on trees, calculation of CO2 emissions and/or neutralizations, level reached in the community (for example, basic planter, golden planter, etc.), badges awarded. The stream messages constitute “information that the user can decide conceal”: they are public by default, but each user of the community can decide to conceal the stream of his/her activity. In order to do so, it will be necessary that the user selects the chosen level of privacy in the settings of his/her profile.

8. The stream of his/her activity by each user inside the community is always visible (and it is not possible to delete it) for a user on his/her personal page.

D) SCOPE OF DATA HANDLING AND SHARING

1. The collected data can be handled, for the purposes stated in policy, only by Treedom and its associates and can only be shared to its departments and/or offices in Italy or abroad, even in countries outside of the EU (as referred to as “Responsible of handling” ex. Art.4, comma 1, lett.g, d.lgs. 196/2003), which cooperate with Treedom to the pursuing and realization of the purposes as previously stated.

2. The information released by the user (which are the “data essential to the subscription” and the “data non essential to the subscription”) can also be shared with:

I) individuals, companies or firms that assist or consult Treedom regarding accounting, administrative, legal, fiscal and financial matters related to the services provided as stated in this policy;

II) entities affiliated and/or assigned by Treedom (and eventually controlled, completely or partially) to perform activities strictly related to the provision of services mentioned previously or with which it is necessary to interact in order to provide these services; entities that provide Treedom with assistance or services needed for the purposes previously indicated, including the entities and the companies that manage and/or participate to the support and/or maintenance of the website www.treedom.net and of the electronic and/or telematic technology used for the shipment/delivery of products;

III) entities, institutions or authorities to which the disclosure of personal information is obligatory because of rules, regulations, EU regulations or demanded by law.

IV) commercial partners, only if the user has accepted to do so, where requested.

3. For these purposes, data can be disclosed to countries in the EU or elsewhere (after verification that the governments of the countries where data ends or transit guarantee an adequate level of protection of people and of their personal data), following the guidelines and regulations as established in d.lgs.196/2003 and by the Italian Data protection Authority and by the European regulations on the matter.

4. Should Treedom be involved in a merger and/or acquisition, it will continue to guarantee the privacy of personal information and will update the users on the transfer of personal information and/or the application of a different privacy policy.

E) ONLINE ADVERTISING

1.Treedom plans to offer space to entities like companies that offer products or services to place so called “personalized advertisement” on the community and to the personal page of users, with purposes such as marketing and/or commercial and/or statistical and/or market research, with the aim of advertising a certain event and/or product and/or service.

2. Treedom shares the information of users with advertisers without allowing them to go back to the single user that disclosed them (except after previous authorization, where it has been requested in specific parts of the website), and only after having expurgated them of personal elements that can identify the user.

3. Treedom uses the information provided by the user at the moment of subscription and following it to match advertisements that could be of interest to the user.

4. It is not possible for users to block advertisements on Treedom, since they help maintain the community of Treedom free and accessible to everybody and also because Treedom pledges to show to the users of the community only the advertisements that can be of interest to them.

5. When an advertiser creates an advertisement he can choose the recipients (anonymous and unidentifiable) based on the information provided by users when they subscribe to Treedom and subsequently gathered from the users' activities, and from the services used by the users within the community.

6. Depending on the kind of advertisement that the advertiser want to publish in the community, Treedom will take care of proposing the advertisement to the users that meet the criteria of the advertiser, without disclosing the identity of the users recipient of the message to anybody.

7. After publishing the advertisement, Treedom provides to advertisers reports on their trend, informing them for example on the number of users that visualized them, always without disclosing the identity of the users that visualized those advertisements.

F) DATA SHARING AND CONSEQUENCES OF REFUSAL

1. As anticipated in lett.B (“Source and type of collected data”), providing the data “essential to the subscription” is always optional, but necessary so that the user can enter the Treedom community. Not providing these information makes it impossible for a user to subscribe to the Treedom community.

2. Regarding the data that are requested to activate specific services offered by Treedom (so called “data non essential to the subscription”), these are also always optional, but not providing them will make it impossible to access those services.

3. It is also optional and not compulsory, where not expressly stated, to agree the collection of personal data and to their eventual disclosure to commercial partners as indicated to in the letter D), comma 2, point IV. If the user decides not to agree to the operations of collection as stated in the aforementioned comma – when expressly stated – such a refusal will not have any consequences for the user regarding registering to the community and benefitting from the services offered by Treedom.

G) ACCESS RIGHTS TO PERSONAL DATA AND OTHER RIGHTS

1. As stated in art.7, d.lgs. 196/2003, the user has the right to know about the existence of his/her personal data, even it not yet registered, and of their disclosure in a clear, intelligible manner.

2. An individual has the right to know:
a) the origin of his/her personal data;
b) the purposes and the procedures of handling;
c) the logic applied to these procedures if handled through a computer;
d) the contact details of the owner, the people in charge and the representative as described in art.5, comma 2, d.lgs. 196/2003;
e) the individuals or entities to which these data can be disclosed and that can access them as representatives of people in charge or associates within national limits.

3.Every individual also has the right to obtain:
a) the update, the rectification, or if there is an interest, the integration of his/her data;
b) the cancellation, destruction, the change into anonymous or the block of data used in ways and purposes in transgression of a law, included those that do not need to be kept for the purposes for which they were collected or processed further;
c) the proof that the procedures described in the letters a) and b) have been made aware, even regarding their content, of the people to which the data have been communicated or disclosed, except in the case in which such fulfillment remains impossible or involves the use of means disproportionate to the right that should be fulfilled.

4. The individual has the right to disagree, fully or partially:
a) for legitimate reasons to the processing of his/her personal data, even if related to the purpose of collection
b) to the processing of his/her personal data with the purpose of advertising or direct sell or for market research or commercial mailing.

5. The fulfillment of the aforementioned rights can be demanded directly or though an individual, entity or association with power of attorney.

6. For questions or queries regarding personal data processing within Treedom and to demand the fulfillment of the rights as stated in d.lgs. 196/2003, the user can contact us at: Treedom S.r.l., via di Mezzo, n.10r, 50121, Florence, or via email at info@treedom.net.

H) CANCELLATION FROM THE COMMUNITY

1. Each user can, at any given moment, ask Treedom to cancel him from the community by sending an email to the email addressinfo@treedom.net.

2. Following the cancellation, all the activities by the user within the community (trees bought and/or gifted, messages sent and/or received, etc.) will not be anymore referable to him inside the community, but will still be visible without reference to the original poster (for instance, the name of the user can be switched to the title “anonymous”).

3.With the cancellation, every relationship between Treedom and the user of the community regarding the use of said community will be ended. Treedom will not be responsible in the case of posts and shared items inside a social network, and results in search engines that can send to a personal profile on www.treedom.net even if the profile has been canceled; the responsibility will lie with the managers of said social networks and search engines.

I) OWNER AND PERSON IN CHARGE OF DATA PROCESSING

1.The owner of processing personal data, according to the law and procedures as stated in art. 28 of d.lgs. 196/2003, is Società Treedom s.r.l., registered in Florence, via di Mezzo, n. 10r.

2.The person in charge of processing the data, according to the law and procedures of art.29, d.lgs. 196/2003, is Mr. Tommaso Speroni.

L)SECURITY

1. Treedom pledges to protect its users and itself from unauthorized access to its information, according to national laws and regulations, to the European laws and regulations; it also guarantees, through adherence to the so called “safety obligations” and security procedures apt to prevent the risks of destruction or loss, even accidental, of said data, of unauthorized access or processing not authorized or not following the purposes of collection.

2. Treedom also pledges to act accordingly to the laws and regulations as stated by law in case of violation of personal data, as stated in art. 32 bis, d.lgs. 196/2003 and by European regulation.

M) APPLICATION

1.Our privacy policy is valid for all services offered by Treedom, included the services offered on other sites (as the advertisement and the advertising banners), but not for the services that contemplate different privacy policies from those present in this policy.

2.Treedom checks regularly its compliance with the present privacy policy and pledges, if it should receive formal written complaints, to contact the people represented, to collaborate with the authority, among which the local authority for the protection of data, to resolve complaints regarding the transfer of personal data that cannot be resolved directly with its users.

N) DURATION OF PROCESS

1. The treatment of the user's personal data for the purposes stated in the present policy will be done within the limits and for the duration necessary for this purpose, following the existing rules and regulations regarding the protection of personal data.

O) CLOSING POINTS

1. The privacy policy of Treedom can occasionally change.

2. Treedom pledges not to cut the basic rights of users as stated in national and European regulation regarding the processing of personal data and recalled in the present privacy policy without their express consent.

3. Treedom will publish the changes to the present privacy policy in this page and if the changes are significant, they will be shown with more remarkable notification (an email notification with the relevant changes to the privacy policy will be sent for changes made to some of the services);

4. Treedom asks to the users of the community and of its own website to use the services offered respecting the purposes described in the present policy, to not publish information and/or texts that are damaging to the reputation and/or name of individuals and/or entities and to uphold a respectful behavior towards other users and towards the managers of these services.

5. Treedom has the right to remove from the community users, texts or images that can be viewed as damaging and/or offensive to other users or other parties.

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