Privacy policy

01What this site collects

When you leave your email address on growgreen.finance, the site stores it together with the number of trees you picked and the squares you marked on the page. The record is held in a database that Matos SRL runs on Railway for Clearworld BV, hosted in the European Union, and it is also added to Brevo, our email platform, which sends you the confirmation and later messages. If you tick the newsletter box, we additionally store the exact sentence you agreed to and the moment you agreed, so we can show what you consented to. When ordering opens, your details are also passed to NinjaPipe, our customer system.

We use this to send you the risk factors, to tell you when ordering opens and to follow up on your reservation. Leaving your email address is not an order and does not create an account. You can unsubscribe with the link in any email, and you can ask us to delete the record at any time using the contact details in this policy.

When you place an order, your order details, including your name and email address, go to Clearworld BV, which sends your purchase documents.

02Cookies, browser storage and ad measurement

To show the site in your language, our own server looks up which country your connection comes from in a local copy of MaxMind's GeoLite2 country list; the address is not sent anywhere and not kept. If you sign up, we keep that country and the language of the page with your signup, and pass both to Brevo so our emails reach you in the right language. When you choose a language, or the first time we pick one for you, we remember it for a year in a cookie called gg_lang. It holds only en, nl or fr and is needed for the site to work as you chose. This product includes GeoLite2 data created by MaxMind, available from https://www.maxmind.com.

On your first visit we ask whether we may measure our ads with Meta's pixel. Until you choose Allow, nothing from Meta loads and no measurement cookies are set. We only store your choice, in a cookie called gg_consent, for six months, so we don't ask again on every page.

If you allow it, the Meta pixel loads and records the pages you view, when you look at or use the calculator or click through to it or to the signup form, when you click our email address, and when you sign up. Our server sends the same events to Meta, so they are counted once. Our server also sets two Meta cookies, _fbp and _fbc (the second only when you arrive from a Meta ad), for up to 90 days. When you sign up, our server sends Meta the signup together with your email address in hashed form, your IP address, your browser type and those cookie values, so Meta can match the signup to the ad you saw. We never send the number of trees you picked or any amount.

With the same consent, Google Analytics loads to count visits and the same steps, so we can see which pages and buttons work. It sets the cookies _ga and _ga_BC6G64HG9W for up to 13 months, uses no advertising features or Google signals, and sends no name or email address. Google Ireland Ltd processes this data for us under its data processing terms; it can involve transfers outside the European Union.

Meta Platforms Ireland Ltd is jointly responsible with Clearworld BV for collecting and sending this data, and processes it under its own privacy policy, which can involve transfers outside the European Union. The legal basis is your consent. You can withdraw it at any time under Cookie settings at the bottom of every page; measurement then stops and the Meta and Google Analytics cookies are removed.

The number of trees you pick is kept in your browser's session storage so the page can remember it while you browse. It stays on your device, is cleared when you close the tab, and is only sent to us if you submit the signup form.

03Your GrowGreen account

Once ordering opens your account holds more than an email address: your owner details, your language, the bank account (IBAN) you give in Settings so a payout can reach you, the balance of received return that Clearworld BV keeps for you, the withdrawals you ask for, your referral code and the friends who used it, your subscription if you have one, and the yearly amount that applies to each group of your trees, with its history.

Clearworld BV is the controller of this data. Matos SRL processes it for Clearworld BV to run your account and to pass your orders, the yearly amount that applies to you and your withdrawal requests to Clearworld BV, which makes the payouts. Your rights below apply to this data.

04Controller: Clearworld BV

Clearworld BV, established at Kortrijksesteenweg 204, 9830 Sint-Martens-Latem, Belgium, is the seller of record and the controller of your personal data, on this site and as its customer. Matos SRL, which runs growgreen.finance for it, is its processor.

05Data collected

• Identification data: name, address, email address, telephone number.
• Financial data: bank account number for payments.
• Technical data: IP address, browser type and other technical data collected automatically when you visit the website.
• Usage data: information about how you use the website.

06Purposes

• Performance of agreements: to deliver products and services to you and process payments.
• Customer service: to help you with questions or complaints.
• Marketing: to inform you about products and services, if you have given consent.
• Legal obligations: to comply with legal obligations.

07Legal basis

• Performance of a contract: processing is necessary to perform an agreement to which you are a party.
• Legal obligation: processing is necessary to comply with a legal obligation.
• Legitimate interest: processing is necessary for the legitimate interests of Clearworld, unless your interests or fundamental rights and freedoms outweigh them.
• Consent: where you have given consent for specific processing.

08Sharing your data

Your personal data is shared with third parties only where necessary to perform an agreement, to comply with a legal obligation, or on the basis of your consent. These third parties may be:

• Service providers, such as hosting and IT providers. For this website those are Railway (hosting and database, European Union), Brevo (email) and, once ordering opens, NinjaPipe (customer system).
• Meta Platforms Ireland Ltd, to measure our ads, and Google Ireland Ltd, for visit statistics (Google Analytics), only if you allow it in the cookie banner.
• Payment services, such as banks and payment providers.
• Public authorities, where legally required.

09Security

Appropriate technical and organisational measures are taken to protect your personal data against loss, theft and unauthorised access.

10Retention

Your personal data is kept no longer than necessary for the purposes for which it was collected, unless a longer retention is legally required.

For the signup on this site specifically: if you never place an order, GrowGreen deletes your signup record, in its own database and in Brevo, at the latest twenty four months after the last time you heard from us or contacted us. Unsubscribing removes you from the mailing immediately. Once you order, Clearworld BV's retention rules apply to your customer record.

11Your rights

• Right of access: to know which of your data is processed.
• Right to rectification: to have incorrect or incomplete data corrected.
• Right to erasure: to have your data deleted, under certain conditions.
• Right to restriction: to restrict the processing of your data, under certain conditions.
• Right to data portability: to receive your data in a structured, commonly used and machine-readable form and to transfer it to another controller.
• Right to object: to object to processing based on legitimate interest.

12Contact

For questions about this policy, or to exercise your rights regarding your customer data: Clearworld BV, Kortrijksesteenweg 204, 9830 Sint-Martens-Latem, Belgium, privacy@clearworld.be.

For the signup record GrowGreen holds on this site, including to unsubscribe or to have it deleted: hello@growgreen.finance.

13Changes to this policy

We reserve the right to change this privacy policy. Changes are published on this website and take effect on publication.