Privacy Policy | Greenphire

Last Updated: February 24, 2025

Greenphire, LLC and its affiliates and subsidiaries (“Greenphire,” “we,” “us,” or “our”) respect your privacy. This Privacy Notice (“Notice”) describes the processing of Personal Information (defined below) that is provided, collected, or disclosed while providing our products or services to you (“Services”) and on the websites, applications, and online platforms that link to this Notice (collectively, “Site”), including when you apply for a job with us. It also describes rights you may have under applicable laws. Please read this Notice carefully to understand our policies and practices regarding your Personal Information and how we will treat it. To access this Notice in an alternative downloadable format, please click here.

Personal Information We Collect

We collect several categories of Personal Information from and about users of our Site and Services. “Personal Information” means information that uniquely identifies, relates to, describes, or is reasonably capable of being associated with or linked to you. The categories of Personal Information we collect may include:

Contact Information – If you submit an inquiry, register for an account, or provide information on or through our Site or Services, we may collect your contact information including your name, mailing address, email address, company name, job title, phone number, and the contents of any messages you send to us.
Commercial Information – If you submit an inquiry, or provide information on our Site, we may collect commercial information including information about Services you have shown interest in.
Usage Information – When you use our Site, we may automatically record information, including your Internet Protocol address (IP Address), geolocation of your device, browser type, referring URLs (g., the website you visited before coming to our Site), domain names associated with your internet service provider, and any other information regarding your interaction with our Site.
Employment Information – If you apply for employment with us, we will collect Personal Information related to your potential employment, including your education and employment history, address and contact information, demographic information, and any other information included in your resume or application.
Communication Information – We may collect Personal Information contained within your communications with us via email, chat functionality, social media, telephone, or otherwise, and in certain cases we may use third-party service providers to do so. Where permitted by applicable law, we may collect and maintain records of calls and chats with our agents, representatives, or employees via message, chat, post, or similar functionality.
Clinical Trial Information – We may collect Personal Information in connection with the administration of trials, including your name, maiden name, email address, address, telephone number, language, social security number, username, password, passport number, photo, and expiration date, sex, residence permit, nationality, and country of issue, date and country of birth, information related to studies (including name and appointment dates and times), participant ID, information related to logistics requests (including service notes and frequent flyer or other rewards numbers), caregiver information, and survey information (including information related to disease history, demographics, genetics, quality of life, and clinical trials).
Financial Information – If you use our Services, we may collect financial information, including via our third-party payment processor, to facilitate payments, such as bank account number, credit card number, type, and expiration date, information related to card balances and pending payments, tax ID, payee ID, social security number, and photos of your receipts for reimbursement.

How We Collect Personal Information

Directly From You – We collect Personal Information that you provide to us directly, for example, if you choose to contact us, request information from us, sign up to receive updates, or otherwise utilize our Site or Services.
From Third Parties – We may collect Personal Information from third parties, including but not limited to business partners, advertising networks, social networks, data analytics providers, mobile device providers, Internet or mobile service providers, recruiters and job application portals, mobile application platform providers, and background check providers.
Through Online Tracking Technologies – We use cookies and similar technologies to collect Personal Information automatically as you navigate our Site. For additional information regarding our use of these technologies, see the Cookies and Tracking Technologies section below.

How We Use Personal Information

To the extent permitted by applicable law, we use Personal Information:

To provide and personalize our Site and Services, such as processing or fulfilling orders and transactions, providing and personalizing our Services, processing payments, providing customer service, maintaining or servicing accounts, providing financing, verifying customer information, creating and maintaining business records, verifying eligibility, and undertaking or providing similar services.
To optimize, improve, and maintain our Services, including understanding how users interact with our Services, gauging user interest in certain Services or Site functionality, and troubleshooting problems.
For internal research and development, such as testing, verifying, and improving the quality of our Services or developing new ones.
For marketing and advertising, including using your information to send you messages, notices, newsletters, surveys, promotions, or event invitations about our own or third parties’ goods and services that may be of interest to you. We also use Personal Information to conduct interest-based advertising as discussed in the Cookies and Other Tracking Technologies section below. You can also unsubscribe from any marketing emails or text messages that we may send you by following the instructions included in the email or text correspondence or emailing us at [email protected].
For communicating with you, such as responding to your questions and comments or notifying you of changes to our Site or Services.
For legal, security, or safety reasons, such as protecting our and our users’ safety, property, or rights; complying with legal requirements; enforcing our terms, conditions, and policies; detecting, preventing, and responding to security incidents; and protecting against malicious, deceptive, fraudulent, or illegal activity.
As part of a corporate transaction, such as in connection with the sale of part or all of our assets or business, the acquisition of part or all of another business or another business’ assets, or another corporate transaction, including bankruptcy.
To fulfill any other purpose for which you provide it, including purposes described when you provide the information or give your consent.

If you are applying for employment with us, we also use Personal Information to process your job application, to verify the information you have provided in your application, conduct interviews, perform background and reference checks, to communicate with you and answer your questions, to confirm your eligibility for employment, and improve our recruiting processes. We may also save your Personal Information for future employment opportunities with us.

How We Disclose Personal Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose your Personal Information with your consent or in the following circumstances:

Employees and Other Personnel – We may share Personal Information with our employees and personnel (such as contractors) who have a need to know the information for our business purposes.
Affiliates and Subsidiaries – We may share Personal Information within our family of companies for their and our business and marketing purposes, including providing you with information about the Services we think may be of interest to you.
Service Providers – We disclose your Personal Information with the service providers that we use to support our business, including but not limited to, travel assistance and logistics partners, rideshare operators, data analytics providers, website hosting providers, and other technology providers. If you are applying for a job with us, this may include service providers such as background check providers, to the extent permitted by applicable law, and human resource providers.
Business Partners – We may disclose Personal Information with trusted business partners. For example, we may disclose your Personal Information with a company whose products or services we think may be of interest to you or who we co-sponsor a promotion or service with.
Clinical Entities– If you are a clinical trial participant, we may share your Personal Information in connection with the administration of trials. If you are a trial participant, we may share your Personal Information with trial sites, site staff members, trial sponsors and those working on the sponsors’ behalf, and contract research organizations.
Financial Institutions- If your use of the Services necessitates payments to you, such as if you are a clinical trial participant, we may share your Personal Information with financial institutions and related parties in order to provide these payments to you, including card processors, card replacement providers, and know your customer verification providers.
Ad Tech Companies and Other Providers – We may share or make available limited Personal Information (such as a mobile device identifiers) with ad tech companies and other online service providers. When we share your Personal Information in this context, we follow applicable legal requirements, which may require that we provide opt-out rights or other individual rights.
Legal Obligation or Safety Reasons – We may disclose Personal Information to a third party when we have a good faith belief that such disclosure of Personal Information is reasonably necessary to (a) satisfy or comply with any requirement of law, regulation, legal process, or enforceable governmental request, (b) enforce or investigate a potential violation of any agreement you have with us, (c) detect, prevent, or otherwise respond to fraud, security or technical concerns, (d) support auditing and compliance functions, or (e) protect the rights, property, or safety of Greenphire, its employees and clients, or the public against harm.
Merger or Change of Control – We may disclose Personal Information to third parties as necessary if we are involved in a merger, acquisition, or any other transaction involving a change of control in our business, including but not limited to, a bankruptcy or similar proceeding. Where legally required, we will give you notice prior to such disclosure.
Other – We may disclose Personal Information to third parties when explicitly requested by or consented to by you, or for the purposes for which you disclosed the Personal Information to us as indicated at the time and point of the disclosure (or as was obvious at the time and point of disclosure).

Cookies and Other Tracking Technologies

We and our service providers may use cookies and similar technologies to collect usage and browser information about how you use our Site. The technologies we use for this automatic data collection may include cookies and web beacons that permit us to verify system and server integrity and generate statistics around the popularity of certain content. We process the information collected through such technologies, which may include or be combined with Personal Information, to help operate certain features of our Site, to enhance your experience through personalization, and to help us better understand the features of our Site that you and other users are most interested in.

Website Delivery and Appearance – We may use third-party providers to enable certain customer interaction opportunities, content delivery (like audio or video), or other service capabilities. Examples include, but are not limited to, the following functionality:

Content Delivery: We partner with service providers to host our Site and deliver specific content in support of our Services. For example, we use Adobe Typekit to serve fonts on our Site, which is governed by Adobe Typekit’s Privacy Policy. We also partner with companies like YouTube to deliver specific content delivery like audio and video. For more information about how YouTube collects and uses your data, visit Google’s Privacy Policy.
Customer Interaction: We enhance our customer interactions by offering features like payment processors to facilitate online payments. Each of these offerings are governed by the terms, conditions, and policies of the underlying service provider.
Chat-based Customer Support: We use a Live Chat feature powered by a third-party (Qualified.com) to enable live customer service and technical support via our Site. When you engage in the live chat enabled by this service provider, we will automatically collect and share certain information (such as personal identifiers, usage information, and message content) with the vendor to provide the customer service and technical support enabled by the live chat tool. For more information on the specific information collected via this tool, and how this information is used and handled by Qualified.com, please see Qualified.com’s privacy policy here.

Website Analytics and Session Replay – We use analytics and session replay services, that use cookies and other technologies that collect your Personal Information, to assist us with analyzing our Site traffic and site usage to optimize, maintain, and secure our Site and inform subsequent business decisions (including, e.g., advertising). These include, but are not limited to, the following third-party services:

Google Analytics: To learn more about how Google uses data, visit Google’s Privacy Policy and Google’s page on “How Google uses data from sites or apps that use our services.” You may download the Google Analytics Opt-out Browser Add-on for each web browser you use, but this does not prevent the use of other analytics tools. To learn more about Google Analytics cookies, visit Google Analytics Cookie Usage on Websites.
Crazy Egg: We use Crazy Egg on the Site to analyze and obtain information about how visitors to our Site interact with the Site. Please note that the Crazy Egg script may store cookies on computers used by visitors to our Site. The cookies may contain a cookie value that allows Crazy Egg to detect if you are a returning visitor or a first-time visitor. Crazy Egg’s use of cookies is further described in its Privacy Policy and Cookie Policy. If you do not wish to be tracked by Crazy Egg, please visit Crazy Egg’s opt-out feature, available at: https://www.crazyegg.com/opt-out. You will be required to comply with those provisions of the Crazy Egg Privacy Policy and Terms of Use regarding Client Site Visitors, Visitor Submitted Content, any disclaimers of liability by Crazy Egg, the limitation of liability set forth in Section 10 (Limitation of Liability) and the terms of Section 15 (Arbitration; Dispute Resolution). Crazy Egg and its affiliates are third-party beneficiaries of such provisions.

Interest-Based Advertising – We may also allow or enable third parties to collect Personal Information to provide their interest-based advertising on behalf of our products and services, or their own. Interest-based advertising occurs when advertisements are shown to you based on information collected from your online interactions over time and across multiple websites, devices, or online services that you visit or use. Some companies may engage in cross-context behavioral advertising to predict your preferences and show you advertisements that are most likely to be of interest or relevant to you. We do not control these third parties’ collection or use of your information for these purposes, or the opt-out options they may individually offer you via their terms, conditions, and privacy policies. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. Examples of the third-party service providers we engage to serve interest-based advertisements include Google Ads (including Google DoubleClick), LinkedIn marketing solutions (including LinkedIn Ads), Demandbase and including Demandbase and LiveRamp, to whom we may disclose data for the purposes of digital targeting- for more information, please visit LiveRamp’s Privacy Policy, available at: https://liveramp.com/privacy/service-privacy-policy/.

Selling or Sharing Personal Information – While we do not sell Personal Information in exchange for monetary consideration, we do share Personal Information for other benefits that could be deemed a “sale” or “sharing” under various data protection laws, because they are sometimes broadly defined to include activities such as the delivery of interest-based advertising on websites or allowing third parties to receive certain information, such as cookies, IP address, and/or browsing behavior. We similarly engage in interest-based advertising when we use data about your activities on our Site to serve you ads on websites owned or controlled by third parties. It is in this context that we have provided advertising networks, data analytics providers, social networks, and video sharing platforms with Personal Information such as your IP address, device information, Internet and other electronic network activity information, and geolocation information in the last twelve months.

Cookie Choices – To manage your preferences with respect to these technologies, you can:

Visit our preferences page, or customize your browser settings to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable certain cookies, please note that some parts of our Site may not function properly. These settings may be lost and require reconfiguration if you delete your cookies.
Block the collection and use of your information by online platforms and ad tech companies for the purpose of serving interest-based advertising by visiting the opt out pages of the self-regulatory programs of which those companies are members: National Advertising Initiative and Digital Advertising Alliance (or the European Interactive Digital Advertising Alliance, if you are located in the European Economic Area). Please note that even if you opt out of interest-based advertising, you may still see “contextual” ads which are based on the context of what you are looking at on the websites and pages you visit.
Review and execute any provider-specific instructions to customize your preferences or opt-out of certain processing, including interest-based advertising, by third-party service providers. For example, to opt-out of this type of advertising by Google, customize your ad preferences, or limit Google’s collection or use of your data, visit Google’s Safety Center and Google’s Ad Settings and follow Google’s personalized ad opt-out instructions.

How Long We Keep Your Personal Information

We retain your information for as long as needed: (i) to conduct business with you; (ii) fulfill the purposes outlined in this policy; and (iii) to comply with our legal obligations, resolve disputes, and enforce any agreements.

Criteria we will use to determine how long to retain your Personal Information include the nature and length of our business relationship with you; our legal rights, obligations, and retention requirements; and if we have an ongoing business purpose for retaining your Personal Information, such as communicating with you about ongoing or prospective Services you requested.

Links to Third-Party Websites

We are not responsible for the practices employed by any websites or services linked to or from our Site, including the information or content contained within them. We encourage you to investigate and ask questions before disclosing Personal Information to third parties, since any Personal Information disclosed will be handled in accordance with the applicable third party’s privacy policy.

In some cases, we offer links to social media platforms (like Facebook, Instagram, LinkedIn, X (formerly known as Twitter), and YouTube) that enable you to easily connect with us or share information on social media. Any content you post via these social media pages is subject to the Terms of Use and Privacy Policies for those platforms.

International Use and Cross-Border Data Transfers

If you are visiting our Site from outside of the United States, please note that our Site is hosted in the United States. Where permitted by applicable law, we may transfer the personal data we collect about you to the United States and other jurisdictions that may not be deemed to provide the same level of data protection as your home country, as necessary for the purposes set out in this Policy.

For individuals in the European Union, European Economic Area, Switzerland, Brazil, and United Kingdom: Greenphire will only transfer Personal Data to third parties located outside of these regions when it has ensured appropriate safeguards for such Personal Information through lawful and approved methods.

Currently, Greenphire complies with the EU-US Data Privacy Framework (“EU-US DPF”), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) as set forth by the U.S. Department of Commerce, with regard to the processing of Personal Data received from the EU, the UK, and Switzerland, respectively and with the Brazilian General Data Protection Law (“LGPD”).

If there is any conflict between the terms in this Notice and the DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (“DPF”) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

Under the DPF program, we commit to subject all Personal Data received from the EU, UK, and Switzerland to the DPF principles, in reliance on the EU-U.S. DPF, its UK extension, and the Swiss-U.S. DPF.

The Federal Trade Commission has jurisdiction over Greenphire, LLC’s compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF.

Your choices and rights under the DPF

If your Personal Data is to be used for a new purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized, or transferred to a non-agent third party, you will be provided, where appropriate, with an opportunity to decline to have your Personal Data so used or transferred. Where the information in question is Sensitive Personal Data, your affirmative express consent will be obtained prior to the intended processing.

Additionally, as detailed in this Notice, you may seek confirmation regarding whether we are processing your Personal Data, request access to it, and ask that we correct, amend or delete that information, where it is inaccurate or has been Processed in violation of the DPF Principles.

for Onward Transfers

When we receive Personal Data under the DPF principle, we remain liable for any subsequent transfer of it to a third party (“Onward Transfer”).

Where the third party is another controller, we commit to notify you beforehand and give you the choices specified in this Notice. Furthermore, we commit to enter into a contract with the third-party controller that provides that such data may only be processed for limited and specified purposes consistent with the choice you expressed and that the recipient will provide the same level of protection as the DPF Principles.

Where the third party is acting as our agent, we commit to only transfer Personal Data where such Agent has given assurances that it provides at least the same level of privacy protection as is required by the DPF Principles and will notify us if it determines it can no longer meet this obligation. Furthermore, should we learn that an agent is failing to meet this obligation, we will take reasonable steps to prevent such processing. Finally, the DPF requires that, to the extent we are responsible for the event, we shall remain liable should our agents process Personal Data in a manner inconsistent with the DPF principles.

How to exercise your rights, ask for more information or lodge a complaint?

Your first step should be to contact us directly. To make a request to exercise your rights, issue a complaint about our handling of your Personal Data, or simply ask for more information, please contact our Data Protection Officer directly at [email protected]

Greenphire, LLC
1018 W 9th Ave #200
King of Prussia, PA 19406

Alternatively, you may also contact our local representative:

In the EU at: [email protected]
In the UK at: [email protected]
In Brazil at: [email protected] (Local DPO: MKR Consultoria LTDA.)

OPTION 1: INDEPENDENT DISPUTE RESOLUTION BODY

Your second step, if you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/submit/ for more information or to file a complaint. The services of JAMS are provided at no cost to you.

OPTION 2: PANEL OF EU DATA PROTECTION AUTHORITIES

Your second step, if you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please contact your local European Data Protection Authority.

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Greenphire commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (“DPAs”), the UK Information Commissioner’s Office (“ICO”) and the Gibraltar Regulatory Authority (“GRA”), and the Swiss Federal Data Protection and Information Commissioner (“FDPIC”) with regard to unresolved complaints concerning our handling of Personal Data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. Your third step, if any request remains unresolved, should be to exercise your right to invoke binding arbitration under the DPF. To learn more about the arbitration mechanism, please visit https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf.

For inquiries related to Human Resources Data

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Greenphire commits to cooperate and comply respectively with the advice of the panel established by the DPAs, the ICO, and the FDPIC with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF in the context of the employment relationship.

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Greenphire commits to refer unresolved complaints concerning our handling of Personal Data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF to JAMS, an alternative dispute resolution provider based in United States, the European Union, the United Kingdom, and/or Switzerland (as applicable). If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/DPF-Dispute-Resolution for more information or to file a complaint. The services of JAMS are provided at no cost to you.

Contact Information. If there are any questions regarding this Notice or how we collect, use, store or handle Personal Data, you may contact us by sending an email to [email protected] or by sending registered mail to:

Greenphire, LLC
1018 West 9th Ave., Suite 200
King of Prussia, PA 19406
USA
Attn: Privacy Department

How We Protect Personal Information

We have implemented commercially reasonable measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, the transmission of information via the internet is not completely secure. Despite these efforts to store Personal Information in a secure environment, we cannot guarantee the security of Personal Information during its transmission or its storage on our systems.

Exercising Your Privacy Rights

Depending on where you live, you may have the following rights with respect to your Personal Information under applicable data protection laws:

Access – The right to request access to and obtain a copy of any Personal Information we may have about you.
Deletion – The right to delete your Personal Information that we have collected or obtained, subject to certain exceptions.
Correction – The right to request that we correct any inaccuracies in your Personal Information, subject to certain exceptions.
Opt Out of Certain Processing – The right to: (a) opt out of the processing of your Personal Information for purposes of targeted advertising, (b) opt out of the sale or sharing of your Personal Information; (c) limit the use of your sensitive Personal Information (if applicable), and (c) opt out of profiling in furtherance of decisions that produce legal or similarly significant effects. We do not collect or process sensitive Personal Information outside of purposes permitted by law (such as section 7027(m) under the California Consumer Privacy Act Regulations), so we do not offer the option to limit its use. We also do not profile you or other individuals in a manner that would result in legal or similarly significant effects, so we do not offer an opt out.
Objection/Restriction of Processing – The right to object or restrict us from processing your Personal Information in certain circumstances.
Withdraw Consent – The right to withdraw your consent where we are relying on your consent to process your Personal Information. You may also have the right to obtain information on the possibility of not providing consent and on the consequences of such denial.
Automated Decision-Making – The right to know when you are subject to automated decision-making, the Personal Information used to render the decision, the principal factors and parameters involved in the decision, and human review or correction of the decision (or its underlying data, where appropriate). You may also have the right to consent or opt out of this automated decision-making, depending on your location.
Lodge a Complaint – The right to lodge a complaint with a supervisory authority or other regulatory agency if you believe we have violated any of the rights afforded to you under applicable data protection laws. We encourage you to first reach out to us so we have an opportunity to address your concerns directly before you do so.

To exercise any of the privacy rights afforded to you under applicable data protection laws, e-mail us at [email protected]. You may also exercise your opt out rights by broadcasting an Opt-Out Preference Signal, such as the Global Privacy Control (GPC). We honor Opt-Out Preference Signals, including GPC. If you choose to use an Opt-Out Preference Signal, you will need to turn it on for each supported browser or browser extension you use.

You will not be discriminated against in any way by virtue of your exercise of the rights listed in this Notice. However, should you withdraw your consent or object to processing of your Personal Information, or if you choose not to provide certain Personal Information, we may be unable to provide some, or all, of our Services to you.

Only you, or an authorized agent that you authorize to act on your behalf, may make a request related to your Personal Information. You may also make a request on behalf of your minor child. We must verify your identity before fulfilling your requests, and if we cannot verify your identity, we may request additional information from you. If you are an authorized agent making a request on behalf of another person, we will also need to verify your identity, which may require proof of your written authorization or evidence of a power of attorney. We endeavor to respond to requests within the time period required by applicable law. If we require more time, we will inform you of the reason and extension period in writing.

We do not charge a fee to process or respond to your requests unless they are excessive or repetitive. If we determine that a request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. We may deny certain requests, or only fulfill some in part, as permitted or required by law. If you are not satisfied with the resolution of your request and you are afforded a right to appeal such decision, you will be notified of our appeal process in our response to your request.

Children’s Privacy

We do not knowingly collect or solicit any Personal Information from children, as defined under applicable law, without verified written parental consent, and we have no actual knowledge of processing such Personal Information of minors under 16 years of age. If we learn that we have collected Personal Information from a child, we will promptly take steps to delete that information. If you believe we might have any information from or about a child, please contact us at [email protected].

Individuals in the European Union, European Economic Area, Switzerland, Brazil, and the United Kingdom

This section provides additional information regarding Greenphire’s processing of personal data of people located in the European Union (EU), European Economic Area (EEA), Switzerland, Brazil, and the United Kingdom (UK) in accordance with the EU Data Protection Regulation, the Brazil General Data Protection Law (“LGPD”), UK Data Protection Regulation, and the Swiss Federal Data Protection Act.

Legal Bases for Processing

Our legal basis for processing Personal Information depends on the Personal Information involved and the context in which we process it. Where Greenphire acts as a controller, we process your Personal Information: with your consent; where necessary to perform a contract; to comply with our legal obligations; and where doing so is in our legitimate interests (including the purposes described in this Notice) and such interests are not outweighed by your rights and freedoms.

Special Category Data

Greenphire only collects Special Category Data where we have a lawful basis for doing so that is permitted under Article 9 of the GDPR, and Article 11 of the LGPD including, where necessary, to provide the Services and within the employment context. In order to provide the Services, we may collect data that reveals your racial or ethnic origin or health. If you apply for a job with us, we may collect data that reveals your racial or ethnic origin, trade union membership, sexual orientation, or health to fulfill our obligations, exercise our rights, and otherwise administer our employment relationship with you (including initial recruitment and hiring, where applicable). For example, we may collect health information to make reasonable disability accommodations; immigration information to verify your right to work in a particular jurisdiction; and data points like your race, ethnicity, and sexual orientation to monitor equal opportunities.

California Residents

This section provides additional information regarding Greenphire’s practices pursuant to the California Consumer Privacy Act of 2018 and its implementing regulations, as amended by the California Privacy Rights Act (“CCPA”), where “Personal Information” has the definition set forth in the CCPA.

Please see the below chart for detailed information about the categories of Personal Information we have collected from California residents during the twelve months preceding the date on which this Notice was last updated and the categories of third parties to whom we sell or share Personal Information. For each category of Personal Information set forth in the chart below, the categories of third parties to whom we disclose it for a business or commercial purpose are set forth in the How We Disclose Personal Information section above.

Personal Information Category set forth in Cal. Civ. Code § 1798.140	Categories of Third Parties to Whom We Sell or Share Personal Information
Personal identifiers, including real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers.	Third-party marketers and other third parties that set cookies and other online tracking technologies on our Site.
California Customer Records Personal Information (Cal. Civ. Code § 1798.80(e)), including name, signature, physical characteristics or description, address, telephone number, education, employment, employment history, etc.	We do not sell or share this category of Personal Information.
Characteristics of protected classifications under California or federal law. This may include age, veteran status, accommodations information, gender identity and expression, sexual orientation, and religion.	We do not sell or share this category of Personal Information.
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Third-party marketers, analytics providers and other third parties that set cookies and other online tracking technologies on our Site.
Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information about individual interactions with an Internet website, application, or advertisement.	Third-party marketers, analytics providers and other third parties that set cookies and other online tracking technologies on our Site
Geolocation data, such as your IP address.	Third-party marketers, analytics providers and other third parties that set cookies and other online tracking technologies on our Site.
Sensory data including audio, electronic, visual, thermal, olfactory, or similar information.	We do not sell or share this category of Personal Information.
Professional or employment-related information.	Third-party marketers, analytics providers and other third parties that set cookies and other online tracking technologies on our Site.
Non-public education information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g; 34 C.F.R. Part 99)	We do not sell or share this category of Personal Information.
Sensitive Personal Information as set forth in Cal. Civ. Code § 1798.140, including social security number, driver’s license number, state identification card, or passport number; citizenship or immigration Information; racial or ethnic origin; account access credentials (like usernames or account numbers combined with password or other security/access code to access an account); precise geolocation; genetic data; personal information collected and analyzed concerning health.	We do not sell or share this category of Personal Information.

California Shine the Light – Under California Civil Code Section 1798.83, individual customers who reside in California and who have an existing business relationship with us may request information about our disclosure of certain categories of Personal Information to third parties for the third parties’ direct marketing purposes, if any. To make such a request, please contact us at [email protected]. Please be aware that not all information sharing is covered by these California privacy rights requirements and only information on covered sharing will be included in our response. This request may be made no more than once per calendar year.

LGPD

For the LGPD purposes, in addition to the privacy rights described above, data subjects may also (i) request confirmation of the data processing; (ii) request the anonymization, blocking or erasure of data considered unnecessary, excessive or non-compliant with data protection regulation; (iii) request the portability of personal data, where applicable; (iv) request the erasure of the personal data processed upon the data subject’s consent, except in cases of legal exceptions; (v) request information about public and private entities with which the controller has shared data; (vi) request information concerning the consequences of denying consent; ; (vii) lodge a complaint with the Brazilian Data Protection Authority (“ANPD”).

All requests to exercise the rights of the data subjects will be analyzed and, if they cannot be met, due justification will be presented.

To exercise rights in Brazil, please contact the Local DPO MKR Consultoria LTDA. [email protected].

Changes to this Notice

Please note that we may modify or update this Notice from time to time, so please review it periodically. If we make material changes to how we treat Personal Information, we will notify you according to applicable law. Unless otherwise indicated, any changes to this Notice will apply immediately upon posting to our Site. You are responsible for periodically visiting our Site and this Notice to check for any changes.

Contact Us

If you have any questions about our practices or this Notice, please contact us at [email protected].

Cookie	Duration	Description
cookielawinfo-checkbox-advertisement	1 year	Set by the GDPR Cookie Consent plugin, this cookie records the user consent for the cookies in the "Advertisement" category.
cookielawinfo-checkbox-analytics	6 months	This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Analytics".
cookielawinfo-checkbox-functional	6 months	The cookie is set by GDPR cookie consent to record the user consent for the cookies in the category "Functional".
cookielawinfo-checkbox-necessary	6 months	This cookie is set by GDPR Cookie Consent plugin. The cookies is used to store the user consent for the cookies in the category "Necessary".
cookielawinfo-checkbox-others	6 months	This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Other.
cookielawinfo-checkbox-performance	6 months	This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Performance".
CookieLawInfoConsent	1 year	CookieYes sets this cookie to record the default button state of the corresponding category and the status of CCPA. It works only in coordination with the primary cookie.
viewed_cookie_policy	6 months	The cookie is set by the GDPR Cookie Consent plugin and is used to store whether or not user has consented to the use of cookies. It does not store any personal data.

Cookie	Duration	Description
__cf_bm	30 minutes	Cloudflare set the cookie to support Cloudflare Bot Management.
li_gc	5 months 27 days	Linkedin set this cookie for storing visitor's consent regarding using cookies for non-essential purposes.
lidc	1 day	LinkedIn sets the lidc cookie to facilitate data center selection.

Cookie	Duration	Description
_ga	1 year 1 month 4 days	Google Analytics sets this cookie to calculate visitor, session and campaign data and track site usage for the site's analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognise unique visitors.
_ga_*	1 year 1 month 4 days	Google Analytics sets this cookie to store and count page views.
_gat_gtag_UA_*	1 minute	Google Analytics sets this cookie to store a unique user ID.
_gcl_au	3 months	Google Tag Manager sets the cookie to experiment advertisement efficiency of websites using their services.
_gd_session	4 hours	This cookie is used for collecting information on users visit to the website. It collects data such as total number of visits, average time spent on the website and the pages loaded.
_gd_visitor	1 year 1 month 4 days	This cookie is used for collecting information on the users visit such as number of visits, average time spent on the website and the pages loaded for displaying targeted ads.
_gid	1 day	Google Analytics sets this cookie to store information on how visitors use a website while also creating an analytics report of the website's performance. Some of the collected data includes the number of visitors, their source, and the pages they visit anonymously.
demdex	5 months 27 days	The demdex cookie, set under the domain demdex.net, is used by Adobe Audience Manager to help identify a unique visitor across domains.
ln_or	1 day	Linkedin sets this cookie to registers statistical data on users' behaviour on the website for internal analytics.
pardot	past	The pardot cookie is set while the visitor is logged in as a Pardot user. The cookie indicates an active session and is not used for tracking.
u	session	This cookie is used by Bombora to collect information that is used either in aggregate form, to help understand how websites are being used or how effective marketing campaigns are, or to help customize the websites for visitors.

Cookie	Duration	Description
ab	1 year	Owned by agkn, this cookie is used for targeting and advertising purposes.
bcookie	1 year	LinkedIn sets this cookie from LinkedIn share buttons and ad tags to recognize browser IDs.
CMID	1 year	Casale Media sets this cookie to collect information on user behaviour for targeted advertising.
CMPRO	3 months	CasaleMedia sets CMPRO cookie for anonymous usage tracking and targeted advertising.
CMPS	3 months	CasaleMedia sets CMPS cookie for anonymous user tracking based on users' website visits to display targeted ads.
dpm	5 months 27 days	The dpm cookie, set under the Demdex domain, assigns a unique ID to each visiting user, hence allowing third-party advertisers to target these users with relevant ads.
IDE	1 year 24 days	Google DoubleClick IDE cookies store information about how the user uses the website to present them with relevant ads according to the user profile.
test_cookie	15 minutes	doubleclick.net sets this cookie to determine if the user's browser supports cookies.
tuuid	1 year 1 month 4 days	The tuuid cookie, set by BidSwitch, stores an unique ID to determine what adverts the users have seen if they have visited any of the advertiser's websites. The information is used to decide when and how often users will see a certain banner.
tuuid_lu	1 year 1 month 4 days	This cookie, set by BidSwitch, stores a unique ID to determine what adverts the users have seen while visiting an advertiser's website. This information is then used to understand when and how often users will see a certain banner.
visitor_id*	1 year 1 month 4 days	Pardot sets this cookie to store a unique user ID.
visitor_id*-hash	1 year 1 month 4 days	Pardot sets this cookie to store a unique user ID.