Privacy Policy
Who we are
This privacy policy (“Policy”) describes how Coöperatie Greenhood U.A. (“Company”, “we”, “our”, or “us”) collects, uses, shares, and stores personal information of users of its webPrivacy Policy
This Privacy Policy (the ""Policy"") explains how Cooperative Greenhood U.A. (""Greenhood"", the ""Company"", ""we"", ""us"" or ""our"") collects, uses, and shares data in connection with the Greenhood app, https://greenhood.nl website and all of our other properties, products, and services (the ""Services""). Your use of the Services is subject to this Policy as well as our Terms of Service.
High Level Summary
Greenhood is an incorporated company based in The Netherlands that operate https://greenhood.nl among other products and services. Greenhood complies with Europeanlaws and regulations. Greenhood App is a self hosted wallet that is connected to Ethereum Ecosystem. Users hold their own keys and are not dependent on Greenhood.
Greenhood does not collect and store personal data, such as first name, last name, street address, date of birth, email address, or IP address, in connection with your use of the Services.
Greenhood collects non-identifiable data, such as public on-chain data, and limited off-chain data like device type, browser version, etc. This is to help drive production vision, not track users.
If you specifically sign up to receive emails from us, we will store your email address to allow us to send you those emails. You can unsubscribe at any time. We will not attempt to link your email address to your wallet address, IP address, or other personal data.
Greenhood continues to explore methods to further protect consumers' privacy, such as opt-out prompts, migrating to privacy-centric tooling and deploying proxies to anonymize network traffic.
Users are empowered to explore client-side privacy techniques and tools.
Any material changes to privacy will be reflected in an updated privacy policy.
Data We Collect
Privacy is central to everything we do at the Company. And we've enshrined transparency as one of our Company values. Accordingly, we aspire to be transparent about what little data we do collect. We do not maintain user accounts and do not collect and store personal data, such as your name or internet protocol (""IP"") address. When you interact with the Services, we collect only:
Publicly-available blockchain data. When you connect your non-custodial (self hosted)blockchain wallet to the Services, we collect and log your publicly-available blockchain address to learn more about your use of the Services and to screen your wallet for any prior illicit activity. We screen your wallet using intelligence provided by leading blockchain analytics providers. Note that blockchain addresses are publicly-available data that are not created or assigned by us or any central party, and by themselves are not personally identifying.
Information from localStorage and other tracking technologies. We and our third-party services providers may access and collect information from localStorage, mobile deviceID, cookies, web beacons, and other similar technologies to provide and personalize the Services and features of the Services for you across sessions. For example, we may use this information to remember tokens you import, star, or add to your shopping bag. We may also use this information to learn about your preferences, your use of the Services, and our interactions with you. Information we collect from these technologies may include things such as browser type, referring/exit pages, operating system, device or browser language, and other device information. We group and analyze these user journeys collectively, in the aggregate, to improve our product user experience.
Information from other sources. We may receive information about your wallet address or transactions made through the Services from our service providers in order to comply with our legal obligations and prevent the use of our Services in connection with fraudulent or other illicit activities.
Survey or usability information. If you participate in a survey or usability study with us, we will record any biographical information you directly provide to us (for example, your name, email, and job title), the responses you provide to us, and your interactions with the Services.
Correspondence. We will receive any communications and information you provide directly to us via email, customer support, social media, or another support channel (such as Twitter or Discord), or when you participate in any surveys or questionnaires.
Biographical information. If you apply for a job with us, we collect all information provided through our Jobs form, including name, email phone, work and immigration status, and any other resume, cover letter, or free form text you include.
Information you specifically provide us. If you specifically provide us with information (such as your email address), we may use that information for the purposes described when you provide it to us. We will not attempt to link any information you provide to your wallet address, IP address, or other personal data. You do not need to provide us with any personal data to use the Services.
How We Use Data
We use the data we collect in accordance with your instructions, including any applicable terms in our Terms of Service, and as required by law. We may also use data for the following purposes:
Providing the Services. We use the data we collect to provide, maintain, customize and improve our Services and features of our Services.
Customer support. We may use information to provide customer support for and answer inquiries about the Services.
Safety and security. We may use data to protect against, investigate, and stop fraudulent, unauthorized, or illegal activity. We may also use it to address security risks, solve potential security issues such as bugs, enforce our agreements, and protect our users and Company.
Legal compliance. We may use the information we collect as needed or requested by regulators, government entities, and law enforcement to comply with applicable laws and regulations.
Aggregated data. We may use some of the information we collect or access to compile aggregated data that helps us learn more about how users use the Services and where we can improve your experience.
How We Share Data
We may share or disclose the data we collect:
With service providers. We may share your information with our service providers and vendors to assist us in providing, delivering, and improving the Services. For example, we may share your wallet address with service providers like Gnosisscan, Blockscout, Gelato and Quicknodeto provide technical infrastructure services, your wallet address with blockchain analytics providers to detect, prevent, and mitigate financial crime and other illicit or harmful activities, and your activity on our social media pages with our analytics provider to learn more about you interact with us and the Services.
To comply with our legal obligations. We may share your data in the course of litigation, regulatory proceedings, compliance measures, and when compelled by subpoena, court order, or other legal procedure. We may also share data when we believe it is necessary to prevent harm to our users, our Company, or others, and to enforce our agreements and policies, including our Terms of Service.
Safety and Security. We may share data to protect against, investigate, and stop fraudulent, unauthorized, or illegal activity. We may also use it to address security risks, solve potential security issues such as bugs, enforce our agreements, and protect our users, Company, and ecosystem.
Business changes. We may transfer or share data to another entity in the event of a merger, acquisition, bankruptcy, dissolution, reorganization, asset or stock sale, or other business transaction.
With your consent. We may share your information any other time you provide us with your consent to do so.
We do not share your information with any third parties for any marketing purposes whatsoever.
Third Party Cookies
We use services provided by Google and other third parties that use tracking technology such as cookies, deviceID, and localStorage, to collect information about your use of the Services and our interactions with you. You can opt out of having your online activity and device data collected through these third-party services, including by:
Blocking cookies in your browser by following the instructions in your browser settings. For more information about cookies, including how to see the cookies on your device, manage them, and delete them, visit <www.allaboutcookies.org>.
Blocking or limiting the use of your advertising ID on your mobile device through the device settings.
Using privacy plug-ins or browsers. Certain browsers and browser extensions can be configured to block third-party cookies and trackers.
Using the platform opt-out provided by Google at https://adssettings.google.com. You can learn more about how Google uses your information by reviewing Google's privacy policy at https://policies.google.com/privacy.
Using advertising industry opt-out tools on each device or browser where you use the Services, available at http://optout.aboutads.info and http://optout.networkadvertising.org.
Third-Party Links and Sites
We may integrate technologies operated or controlled by other parties into parts of the Services. For example, the Services may include links that hyperlink to websites, platforms, and other services not operated or controlled by us. Please note that when you interact with these other parties, including when you leave the Site, those parties may independently collect information about you and solicit information from you. You can learn more about how those parties collect and use your data by consulting their privacy policies and other terms.
Security
We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect data from loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you. You are responsible for all of your activity on the Services, including the security of your blockchain network addresses, cryptocurrency wallets, and their cryptographic keys.
Age Requirements
Privacy Practices. We do not ""sell"" personal information. Please review the ""Sharing and Disclosure of Information"" section above for further details about the categories of parties with whom we share information.
Privacy Rights. You can request information about how we have collected, used, and shared your personal information. It also gives you the right to request a copy of any information we may maintain about you. You may also ask us to delete any personal information that we may have received about you. We will respond to requests for information, access, and deletion only to the extent we are able to associate, with a reasonable effort, the information we maintain with the identifying details you provide in your request. If we deny the request, we will communicate the decision to you. You are entitled to exercise the rights described above free from discrimination.
Submitting a Request. You can submit a request for information, access, or deletion to privacy@greenhood.nl.
Identity Verification. We collect and verify the identity of any individual submitting a request to access or delete personal information before providing a substantive response.
Disclosures for European Union Data Subjects
We process personal data for the purposes described in the section titled ""How We Use Data"" above. Our bases for processing your data include: (i) you have given consent to the process to us or our service provides for one or more specific purposes; (ii) processing is necessary for the performance of a contract with you; (iii) processing is necessary for compliance with a legal obligation; and/or (iv) processing is necessary for the purposes of the legitimate interested pursued by us or a third party, and your interests and fundamental rights and freedoms do not override those interests.
Your rights under the General Data Protection Regulations (""GDPR"") include the right to (i) request access and obtain a copy of your personal data, (ii) request rectification or erasure of your personal data, (iii) object to or restrict the processing of your personal data; and (iv) request portability of your personal data. Additionally, you may withdraw your consent to our collection at any time. Nevertheless, we cannot edit or delete information that is stored on a particular blockchain. Information such as your transaction data, blockchain wallet address, and assets held by your address that may be related to the data we collect is beyond our control.
To exercise any of your rights under the GDPR, please contact us at privacy@greenhood.nl. We may require additional information from you to process your request. Please note that we may retain information as necessary to fulfill the purpose for which it was collected and may continue to do so even after a data subject request in accordance with our legitimate interests, including to comply with our legal obligations, resolves disputes, prevent fraud, and enforce our agreements.
Changes to this Policy
If we make material changes to this Policy, we will notify you via the Services. Nevertheless, your continued use of the Services reflects your periodic review of this Policy and other Company terms, and indicates your consent to them.
Contact Us
If you have any questions about this Policy or how we collect, use, or share your information, please contact us at privacy@greenhood.nl.
site www.greenhood.nl. This Policy applies to the Sites, applications, products and services (collectively, “Services”) on or in which it is posted, linked, or referenced.
By using the Services, you accept the terms of this Policy and our Terms of Use, and consent to our collection, use, disclosure, and retention of your information as described in this Policy. If you have not done so already, please also review our terms of use. The terms of use contain provisions that limit our liability to you and require you to resolve any dispute with us on an individual basis and not as part of any class or representative action. IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY OR OUR TERMS OF USE, THEN PLEASE DO NOT USE ANY OF THE SERVICES.
Please note that this Policy does not apply to information collected through third-party websites or services that you may access through the Services or that you submit to us through email, text message or other electronic message or offline.
If you are visiting the Sites from the European Union (EU), see our Notice to EU Data Subjects below for our legal bases for processing and transfer of your data.
What we collect
We get information about you in a range of ways.
Information You Give Us. Information we collect from you may include:
- Profile information, such as your username and password, interests, preferences, feedback and survey responses;
- Feedback and correspondence, such as information you provide in your responses to surveys, when you participate in market research activities, report a problem with Service, receive customer support or otherwise correspond with us;
- Usage information, such as information about how you use the Service and interact with us;
- Marketing information, such as your preferences for receiving marketing communications and details about how you engage with them;
- Technical information, such as your Ethereum wallet address, application programming interface (API)-key and network information regarding transactions.
Information Automatically Collected. We may automatically record certain information about how you use our Sites (we refer to this information as “Log Data“). Log Data may include information such as device and browser type, operating system, the pages or features of our Sites to which a user browsed and the time spent on those pages or features, the frequency with which the Sites are used by a user, search terms, the links on our Sites that a user clicked on or used, and other statistics. We use this information to administer the Service and we analyze (and may engage third parties to analyze) this information to improve and enhance the Service by expanding its features and functionality and tailoring it to our users’ needs and preferences.
We may use cookies, local storage or similar technologies to analyze trends, administer the Sites, track users’ movements around the Sites, and to gather demographic information about our user base as a whole. Users can control the use of cookies and local storage at the individual browser level.
Information we will never collect. We will never ask you to share your private keys or wallet seed. Never trust anyone or any site that asks you to enter your private keys or wallet seed.
Use of personal information
To provide our service
We will use your personal information like email address in the following ways:
- To send information, including confirmations, technical notices, updates, security alerts, and support and administrative messages.
To communicate with you
We use your personal information to communicate about promotions, upcoming events, and other news about products and services offered by us and our selected partners.
To optimize our platform
In order to optimize your user experience, we may use your personal information to operate, maintain, and improve our Services. We may also use your information to respond to your comments and questions regarding the Services, and to provide you and other users with general customer service.
With your consent
We may use or share your personal information with your consent, such as when you consent to let us post your testimonials or endorsements on our Sites, you instruct us to take a specific action with respect to your personal information, or you opt into third party marketing communications.
Sharing of personal information
We do not share the personal information that you provide us with other organizations.
How information is secured
We retain information we collect as long as it is necessary and relevant to fulfill the purposes outlined in this privacy policy.
We employ industry standard security measures designed to protect the security of all information submitted through the Services. However, the security of information transmitted through the internet can never be guaranteed. We are not responsible for any interception or interruption of any communications through the internet or for changes to or losses of data. Users of the Services are responsible for maintaining the security of any password, biometrics, user ID or other form of authentication involved in obtaining access to password protected or secure areas of any of our digital services. In order to protect you and your data, we may suspend your use of any of the Services, without notice, pending an investigation, if any breach of security is suspected.
Information choices and changes
Accessing, Updating, Correcting, and Deleting your Information
You may access information that you have voluntarily provided through your account on the Services, and to review, correct, or delete it by sending a request to privacy@greenhood.nl. You can request to change contact choices, opt-out of our sharing with others, and update your personal information and preferences.
Tracking Technologies Generally
Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings.
Contact information
We welcome your comments or questions about this Policy, and you may contact us at: privacy@greenhood.nl.
Greenhood
Saenredamstraat 7e
1072CA Amsterdam
Netherlands
Changes to this privacy policy
We may change this privacy policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make any changes, we will change the Last Updated date above.
Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the changes to the Sites (or as otherwise indicated at the time of posting). In all cases, your continued use of the Sites or Services after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.
Eligibility
If you are under the age of majority in your jurisdiction of residence, you may use the Services only with the consent of or under the supervision of your parent or legal guardian. Consistent with the requirements of the Children’s Online Privacy Protection Act (COPPA), if we learn that we have received any information directly from a child under age 13 without first receiving his or her parent’s verified consent, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use the Sites and subsequently we will delete that information.
Notice to California Residents
Under California Civil Code Section 1789.3, California users are entitled to the following consumer rights notice: California residents may reach the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs by mail at 1625 North Market Blvd., Sacramento, CA 95834, or by telephone at (916) 445-1254 or (800) 952-5210.
This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act or “CCPA.”
For more details about the personal information we collect from you, please see the “What We Collect” section above. We collect this information for the business and commercial purposes described in the “Use of Personal Information” section above. We share this information with the categories of third parties described in the “Sharing of Personal Information” section above. Company does not sell (as such term is defined in the CCPA) the personal information we collect (and will not sell it without providing a right to opt out).
Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.
Notice to EU Data Subjects
Personal Information
With respect to EU data subjects, “personal information,” as used in this Privacy Policy, is equivalent to
“personal data” as defined in the European Union General Data Protection Regulation (GDPR).
Sensitive Data
Some of the information you provide us may constitute sensitive data as defined in the GDPR (also referred to as special categories of personal data), including identification of your race or ethnicity on government-issued identification documents.
Legal Bases for Processing
We only use your personal information as permitted by law. We are required to inform you of the legal bases of our processing of your personal information, which are described in the table below. If you have questions about the legal bases under which we process your personal information, contact us at privacy@greenhood.nl
Use for New Purposes
We may use your personal information for reasons not described in this Privacy Policy, where we are permitted by law to do so and where the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis for that use. If we have relied upon your consent for a particular use of your personal information, we will seek your consent for any unrelated purpose.
Your Rights
Under the GDPR, you have certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:
- Opt-out. Stop sending you direct marketing communications which you have previously consented to receive. We may continue to send you Service-related and other non-marketing communications.
- Access. Provide you with information about our processing of your personal information and give you access to your personal information.
- Correct. Update or correct inaccuracies in your personal information.
- Delete. Delete your personal information.
- Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
- Restrict. Restrict the processing of your personal information.
- Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.
You can submit these requests by email to privacy@greenhood.nl. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us at privacy@greenhood.nl or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.
Cross-Border Data Transfer
Please be aware that your personal data will be transferred to, processed, and stored in the United States. Data protection laws in the U.S. may be different from those in your country of residence. You consent to the transfer of your information, including personal information, to the U.S. as set forth in this Privacy Policy by visiting our Sites or using our service.
Whenever we transfer your personal information out of the EEA to the U.S. or countries not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be based on a data transfer mechanism recognized by the European Commission as providing adequate protection for personal information.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA.