DATA PROTECTION NOTICE (WEBSITE, SOLUTION)

We – TheGreenShot – provide you with this Data Protection Notice to inform you, our website visitors and solution users, about how and when we process your personal data. This notice covers the processing of your personal data as part of your visit to our website

(https://www.thegreenshot.green/ and https://www.thegreenshot.io/), your registration for and the use of our solution (https://app.thegreenshot.green/ as well as TheGreenShot mobile app), and your communication with us via e-mail, telephone, or social media.


If you want information on how we process personal data via cookies, social plug-ins, pixels and other types of tracking technology, you are kindly referred to our Cookie Notice.


1. IN GENERAL


1.1. Your personal data are processed by TheGreenShot SA, Avenue Albert Lancaster 86, 1180 Uccle, Belgium. You can contact us via e-mail at privacy@thegreenshot.green.


1.2. Where we refer to certain laws or regulations, such reference shall also include any change, replacement or annulment of said laws or regulations, including any related executive decisions.


1.3. We might have to modify, change or amend our Data Protection Notice. We can do this from time to time and at our own discretion. You can always consult the last version of this notice on our website or on our solution.


2. TYPES OF PERSONAL DATA WE PROCESS


2.1. Whenever you use our website or our solution, we collect:


  • Technical information associated with the device you use, such as the device type and model, system language, browser type, geographical location and operating system;


  • Technical identifiers that identify the device you use, such as IP address, IDFA (identifier for advertisers) and other unique identifiers;


  • Information concerning your browsing behaviour and engagement information, such as how long you visit, what links you click on, what pages you visit, how many times you visit a page and how long it takes for you to come back.


2.2. When you contact us via e-mail, telephone, or any other way, we collect the information you provide us with. In most cases this is:


  • Your contact information, such as your name, e-mail address, phone number, and postal address;


  • The content of your communication and the technical details of the communication itself, such as with whom you correspond at our end, and the date and time;


  • Publicly available information about you;


  • Any other personal data you choose to provide to us.


2.3. When you use our solution, we collect:


  • The information we require to allow you access to our solution, namely your e-mail address;


  • The basic identity information we require to build your profile, namely your name, your contact details, such as your e-mail address, and details pertaining to your function;


  • If the timesheet and export features are activated, your additional profile details you provide us with, such as your phone number, birthdate, nationality, language, transaction information, and profile picture;


  • Your activity on our solution, including your time entries, your submitted expenses and your travels;


  • Other personal data you or your project manager provide us with.


3. PURPOSES FOR PROCESSING (this is only for the solution, not for the information Web site).


3.1. We process your personal data in order to provide you the services you and your colleagues request from us. This includes your preferences for tips of the day, the working hours if the timesheets and reporting features are activated, the selection of suppliers, the expenses you submit

and the purchase orders you implement, as well as your preferred language.


3.2. We process your personal data to provide you with your activity notifications as well as your own reporting. This means that we will send you relevant communications about your tasks, including tasks that you have done and need further attention, or tasks to be done in relation to your upcoming work. These communications are sent by email, whatsapp, SMS or in-app notifications based on the configuration choices.


3.3. We process your personal data to comply with our legal obligations or to comply with any reasonable request from competent law enforcement agents or representatives, judicial authorities, governmental agencies or bodies, including competent data protection authorities. In the same way, we may transfer your personal data upon our own initiative to the police or the judicial authorities as evidence or if there are justified suspicions of an unlawful act or crime committed by you through your registration with or use of our website, our solution or other interaction with us.


3.4. We might be required to collect and transfer your personal data to our financial institution or payment service provider to allow your financial institution and the payment service provider to comply with their legal obligations, such as obligations under applicable anti-money laundering and counter-terrorism financing legislation.


3.5. We process your personal data and anonymize it to perform statistical analyses so that we may improve our website, our products and services.


3.6. We may process your personal data for the preservation of our legitimate interests or the legitimate interests of our partners or of a third party if and when your registration with or use of our website or solution can be considered (a) a violation of any applicable terms of use or intellectual property rights or any other right of a third party, (b) a threat to the security or integrity of our website or solution, (c) a danger to our website or solution or any of our, or our subcontractors’ underlying systems due to viruses, Trojan horses, spyware, malware or any other form of malicious code, or (d) in any way hateful, obscene, discriminating, racist, slanderous, spiteful, hurtful or in some

other way inappropriate or illegal.


4. LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA


4.1. We process your personal data to provide you the service you and / or your colleagues requested as set out in clause 3.1, as far as this is necessary for performing the agreement between you and TheGreenShot. This includes your personal profile, including information you share through your choice of suppliers, expenses, purchase orders, hours, travels, accommodations, energy use,

photographs, your email, your mobile phone number.


4.2. When you first use our mobile application, we ask you for consent for processing your data under the conditions outlined in clause 3.1. You can change your preference in the settings on your mobile device.


4.4. The processing of your personal data for the purposes outlined in clauses 3.4 and 3.6 is necessary to allow us to comply with our legal obligations.


4.5. The processing of your personal data for the purposes outlined in clause 3 is necessary for the purpose of the legitimate interests of TheGreenShot, which are:


  • Continuous improvements of our website, products and services to ensure that you have the best experience possible;


  • Keeping our website and solutions safe from misuse and illegal activity;


5. RECIPIENTS


5.1. You understand that if you use our website or solution, your personal data is also processed by third parties that process your data on our behalf in order to provide you our tools and services and to improve them. For example, we rely on third parties for keeping you informed about your project. We also use a third party to safely store your personal data within the European Union, as well as process your subscription payments. Moreover, we rely on third parties to follow certain of your actions on our website and solutions in order to better understand how TheGreenShot is used.


5.2. Our third-party processors are only allowed to process your personal data on behalf of TheGreenShot upon our written instruction. We warrant that all of our third-party processors are selected with due care and are contractually obliged to observe the safety and integrity of your

personal data.


6. LOCATION AND TRANSFER


6.1. TheGreenShot processes your personal data first and foremost within the European Economic Area (“EEA”). However, in order to process your personal data for the purposes outlined in clause 3 above, we may also transfer your personal data to a third country outside the EEA. We will only transfer your personal data to third parties which are bound to observe appropriate safeguards with regards to the processing of your personal data. Such safeguards will be the consequence of:



  • A contractual agreement being in place between TheGreenShot and the third party such as an agreement based on the European Commission’s standard contractual clauses for the transfer of personal data to third countries (Commission Implementing Decision (EU) 2021/914 of 4 June 2021).


  • The request of the customer to transfer solution hosting and / or data outside of the EEA due to the customer’s location outside of the EEA.


6.2. Recipients of your personal data outside the EEA include the recipients described in clause 5. The transfer is limited to the purposes set out in clause 3.


7. QUALITY ASSURANCES


7.1. TheGreenShot does its utmost to process only those personal data which are necessary to achieve the purposes listed under clause 3.


7.2. Your personal data are only processed for as long as needed to achieve the purposes listed under clause 3 of this Data Protection Notice or up until such time where you withdraw your consent for processing them. Note that withdrawal of consent may imply that you can no longer use the whole or part of the website or solution. TheGreenShot will de-identify your personal data when they are no longer necessary for the purposes outlined in clause 3, unless there is:


  • An overriding interest of TheGreenShot or any other third party in keeping your personaldata identifiable;


  • A legal or regulatory obligation or a judicial or administrative order that prevents TheGreenShot from de-identifying them.


7.3. We make our best effort to ensure that any personal data we collect is safely kept. TheGreenShot will take the appropriate technical and organisational measures to keep your personal data safe from unauthorised access or theft as well as accidental loss, tampering or destruction. Access by personnel of TheGreenShot or our third-party processors will only be on a need-to-know basis and subject to strict confidentiality obligations. You understand, however, that safety and security are best efforts obligations only which can never be guaranteed.


7.4. If you are registered to receive communications, offerings and other advertisements via e-mail or other person-to-person electronic communications channels, you can change your preferences for receiving such communications by clicking the ‘unsubscribe’ link in our communication, or by sending us your request by e-mail to unsubscribe@thegreenshot.green.


7.5. If you do not receive push notifications from us in the TheGreenShot mobile application, you can turn these on in your device settings. The other way around, if you receive push notifications and you want to turn them off, this can also be done in your device settings.


8. YOUR RIGHTS


8.1. You have the right to request access to all personal data processed by us pertaining to you. We reserve the right to charge an administrative fee for multiple subsequent requests for access that are clearly submitted for causing nuisance or harm to us.


8.2. You have the right to ask that any personal data pertaining to you that are inaccurate, are corrected free of charge. Your request for correction must be accompanied with proof of the flawed nature of the data for which you ask the correction.


8.3. You have the right to withdraw your earlier given consent for processing your personal data, in which case clause 8.4 will apply.


8.4. You have the right to request that your personal data pertaining will be deleted if they are no longer required in light of the purposes outlined in clause 3 or if you withdraw your consent. This request will be evaluated by TheGreenShot against:


  • Overriding interests of the TheGreenShot or any other third party;


  • Legal or regulatory obligations or administrative or judicial orders which may contradict such deletion.


Instead of deletion you can also ask that TheGreenShot limits the processing of your personal data if and when (a) you contest the accuracy of that data, (b) the processing is illegitimate or (c) the data are no longer needed for the purposes listed under clause 3 but you need them to defend yourself in judicial proceedings.


8.5. You have the right to object to the processing on grounds relating to your particular situation. However, you can always object to processing for direct marketing purposes free of charge and without justification.


8.6. When we process your personal data based on your consent or in order to perform a contract, you have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format and you have the right to transmit those data to another controller.


8.7. You have the right not to be subject to a decision solely based on automated processing, which produces legal effects concerning you or when this decision similarly significantly affects you, unless these decisions are made as a consequence of our agreement in order to provide you with the services requested by you or when we asked your explicit consent for this.


8.8. If you wish to submit a request to exercise one or more of the rights listed above, you can send an e-mail to privacy@thegreenshot.green. This e-mail in which you request to exercise a data subject right shall not be construed as consent with the processing of your personal data beyond what is required for handling your request. Such request should clearly state which right you wish to exercise and, if required, the reasons or proof for it. It should also be dated and accompanied by any evidence adequately proving your identity.


We will promptly inform you of having received this request. If the request proves valid, we will honour it as soon as reasonably possible and at the latest one month after we received your request.


If you are unhappy with any aspect of our handling of your personal data you, you may always contact us at privacy@thegreenshot.green. If you remain unsatisfied with our response, you are free to file a complaint with the competent supervisory authority: the Belgian “Autorité de la protection des données – Gegevensbeschermingsautoriteit”.


Last update – 20/01/2023




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