Privacy
Privacy Policy
Last Updated: August 20, 2024
Heirloom Carbon Technologies, Inc., a Delaware corporation (collectively with any of our subsidiaries and affiliates, “Heirloom” or “we,”) have created this Privacy Policy (this “Policy”) to help you understand what information we collect, why we collect it, and how you can update, manage, correct, or delete your information.
We reserve the right to change this policy at any given time, of which you will be promptly updated. If you want to make sure that you are up to date with the latest changes, we advise you to frequently visit this page.
1. Scope
This Policy applies to individual customers, individuals associated with corporations, partnerships, and other non-individual customers, in each case whose Personal Information (defined below) we collect (whether through this website, social media, or any offline interaction) and in some cases share.
This Policy is about how we treat Personal Information. “Personal Information” is information which identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual or household. Personal Information does not include aggregated or de-identified information that is maintained in a form that cannot reasonably be used to infer information about, or otherwise be linked to, a particular individual or household. To make this Policy easier to read, our websites, applications, and offerings (such as [Carbon Removal Services]) are collectively called the “Services.”
2. Personal Information We Collect
The categories of Personal Information we collect depend on how you interact with us and the requirements of applicable law.
A. Personal Information provided directly to us. We collect:
- Personal Information that you provide directly to us when you purchase our Carbon Services such as:
- Your payment information, credit card number, billing address, and/or other related information required to complete a purchase; and
- Information about your past purchases.
We use Shopify Inc (“Shopify”) to enable you to purchase our Carbon Services. Shopify has a Privacy Policy for all of its users. For information on what Shopify collects from Users that use the Shopify platform go to the Shopify Consumer Privacy Policy. While, we do not directly collect or store any payment card information entered through your purchases, we may receive other information associated with your purchase (e.g., your billing details).
- Personal Information that you provide directly to us when you sign up to receive email updates, or otherwise communicate with us by email or submission of a web form. This information may include: Records of our correspondence with you; Your email address or phone number, when you request information about Heirloom or our Services, register for a newsletter, contact us with an enquiry, contact our sales team, apply for a job, or otherwise communicate with us.
- Personal Information you voluntarily provide if, after we (or third parties acting on our behalf) contact you to participate in research, surveys or beta testing or to provide reviews and testimonials, you decide to participate.
- Personal Information provided by other sources, including through third party services and organizations, to supplement information provided by you. Personal Information collected from individuals when we attend or host conferences, trade shows, and other events.
- Personal Information from individuals and third parties in connection with assessing and pursue potential business opportunities.
- Personal Information, such as your job application, resume, cover letter, when you respond to one of our job postings.
B. Personal Information Collected Automatically
We may collect Personal Information automatically when you visit our website or purchase our Services.
- Automated Data. We (or our third-party service providers) may collect certain data automatically through your use of this website and/or other methods of technical analysis. This information may include:
- Your location information, made available through your Internet Protocol (IP) address (including approximate location derived from IP address) or from geolocation information provided from your device or browser (with your permission through your device or browser); Technical information about your device such as IP address, user settings, unique identifiers, MAC Address, cookie identifiers, mobile carrier, and other unique device identifiers; Internet service provider, device type; domain, browser type, version, and language; operating system and system settings; general location information and time zone; and other device identifiers that are automatically assigned to your computer or device when you access the Internet; and
- Your online activity and browsing information, which we identify through the use of cookies, log files, pixel tags, and other tracking technologies, such as links clicked, page views, pages that you visit before and after visiting our website, the date and time of your visit, the amount of time you spend on each page, purchases, searches, features used, items viewed, time spent within our website, information uploaded, items you add to your cart and other actions taken through use of the website (such as preferences).
- Cookie Policy (and Other Technologies). We, as well as third parties that provide content or other functionality on our website, may use Cookies, Pixel Tags, and other technologies (“Technologies”) to automatically collect information through your use of our website.
C. Personal Information collected from social media
We collect some Personal Information directly from you through your interactions with us on social media pages. You permitted this Personal Information to be made available via your privacy setting on the social media site.
3. Why We Use Your Personal Information
We collect your Personal Information to:
- to improve our Services;
- to facilitate the purchase of our Carbon Services;
- enhance our ability to provide you with information about our Carbon Services;
- to communicate with you in relation to your use of the Services via different channels (e.g., by phone, e-mail, chat); and
- to provide functionality, analyze performance, fix errors, and improve the usability and effectiveness of our website;
- to understand how our website and sales platform are used and to continually improve and personal our website;
- to comply with laws; and
- for marketing analytics.
4. How We Use Your Personal Information
Personal Information may be processed by us through our website, mobile applications, and other online or offline offerings that post a link to this Policy.
A. Purchase and Sale
In connection with any purchase of our Carbon Services, we use your Personal Information:
- to facilitate your purchase; and
- to communicate with you in relation to your purchase about policy changes, if applicable.
B. Administrative Purposes
We use your Personal Information to perform administrative tasks such as:
- maintaining functionality, analyzing performance, fixing errors, and improving the usability and effectiveness of our website;
- resisting and protecting against malicious, deceptive, fraudulent or illegal activity, such as cyber-attack, and prosecuting those responsible for such activity;
- authenticating and verifying individual identities, including requests to exercise your rights under this Policy;
- processing applications if you apply for a job with us;
- developing new products and services;
- auditing relating to interactions, transactions, and other compliance activities; and
- allowing you to register for events.
C. Community
We may also collect and preserve Personal Information if we believe it would be necessary to:
- comply with the law or with legal process;
- enforcing our agreements and policies;
- protect and defend our rights and property;
- protect against misuse or unauthorized use of our Services or Shopify’s services;
- protect the safety or property of our users or the general public (e.g., if you provide false information or attempt to pose as someone else, we could share your information to help investigations into your actions); and
- cooperate with government authorities.
D. Marketing and Advertising
We may use your Personal Information to tailor the content we provide to you.
We do not use your Personal Information to display interest-based ads for features, products, and services on our website. We do not use your Personal Information for direct marketing.
We do not sell your Personal Information.
E. Other Purposes
We may use your Personal Information, in particular as collected by Technologies, to:
- Perform Analytics. We may use Technologies and other third-party tools to process analytics information on our website. We use Google Analytics to perform analytics. For more information about how Google uses your Personal Information (including for its own purposes, e.g., for profiling or linking it to other data), please visit Google Analytics’ Privacy Notice.
- De-identified and Aggregated Information. We may use Personal Information to create de-identified and/or aggregated information, such as location, information about the device from when you use our Services, or other analyses we create. De-identified and/or aggregated information is not Personal Information, and we may use and disclose such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.
5. How We Share Your Personal Information
We do not sell your Personal Information, but we do disclose your Personal Information to third parties for several business purposes.
A. Disclosures to Provide the Services.
We may share your Personal Information with:
- third-party service providers that help us sell our products and services; such providers assist us with certain tasks such as processing your payments and fulfilling your purchase orders;
- third-party service providers that help us provide the Services, such as IT support, analyses, hosting, and related services;
- business partners, solely to provide you with a product or service you have requested;
- social network providers when we use social network widgets, buttons, or plug-ins on this website;
- certain vendors for the purpose of analytics, research, auditing our users’ interactions with our website, and improvement of our services;
- other vendors for purposes of bug detection and error reporting.
We do not share your Personal Information with third-party advertising partners.
B. Disclosures to Protect Us or Others
We may access, preserve, and disclose any Personal Information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to:
- comply with law enforcement or national security requests and legal process, such as a court order or subpoena;
- protect your, our, or others’ rights, property, or safety;
- enforce our policies or contracts;
- collect amounts owed to us; or
- assist with an investigation or prosecution of suspected or actual illegal activity.
C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers
In the unlikely event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings), we may need to disclose or provide your information to a third party such as an acquiring entity and its advisers.
6. Your Privacy Choices And Rights
In accordance with applicable law, you may have the right to:
- confirm whether we are processing your Personal Information;
- obtain access to or a copy of your Personal Information;
- receive an electronic copy of Personal Information that you have provided to us, or ask us to send that information to another company;
- request correction of your Personal Information where it is inaccurate or incomplete; and
- request deletion of your Personal Information.
You may elect to exercise any of the foregoing rights at any time. We will not discriminate against you, in terms of price or Services that we offer, if you elect to exercise any of the rights requested above.
To exercise any of the foregoing rights, you may email us at Privacy@heirloomcarbon.com. We will comply with your request as soon as reasonably practicable. Requests to exercise your rights may be granted in whole, in part, or not at all, depending on the scope and nature of the request and the requirements of the law of the governing jurisdiction.
Additionally, you may further limit sharing information by doing any of the following:
- opt out of sharing certain information by adjusting your browser privacy settings, including disabling your browser’s location tracking and search engine autocomplete features, turning off password autofills, and by regularly deleting your browsing history;
- turn off sharing your precise location through your device settings;
- elect what data Shopify collects through its Privacy Controls Portal;
- modify your privacy settings on all of your social media accounts to limit the information we receive through our interaction with such social media sites;
- opt-out of Google Analytics’ use of your information - to learn more, please click here;
- unsubscribe from any unwanted emails or newsletters you received from us by emailing privacy@heirloomcarbon.com or by using the unsubscribe link contained in each email you receive from us. (Note that you will continue to receive transaction-related emails regarding products or Services you have requested and we may also send you certain non-promotional communications regarding us and our Carbon Services, and you will not be able to opt out of those communications (e.g., communications regarding our Carbon Services or updates to ur this Policy).
- stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits; provided, if you adjust your preferences, our website may not work properly.
Please note:
- cookie-based opt-outs are not effective on mobile applications; and
- you must separately opt out in each browser and on each device.
7. Security Of Your Information
We take steps to ensure that your information is treated securely and in accordance with this Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized access, use, disclosure, or loss of Personal Information.
By using our Services or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services or by sending an email to you.
8. Retention Of Personal Information
We store the Personal Information we collect as described in this Policy for as long as you use our Services, or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
9. Supplemental Notice For California Residents
This Supplemental Notice for California Residents only applies to our processing of Personal Information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). If you are a resident of California, you have certain rights with respect to your Personal Information that we collect and may share. Under California law, the exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g., the prevention or detection of crime) and our interests (e.g., maintaining confidentiality when legally required). This is an outline of those rights under California law.
A. Information we expect to collect in the next 12 months
The CCPA provides California residents with the right to know what categories of Personal Information Heirloom has collected about them, and whether Heirloom disclosed that Personal Information for a business purpose (e.g., to a service provider) in the preceding twelve months.
Before the date of this Policy, we did not collect any information about our users. In the next twelve (12) months after the date of this Policy, we anticipate that we will collect:
- Identifiers: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers – Will be collected – May be shared with: Service Providers, Business Partners, Affiliates
- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)): A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. – Will be collected – May be shared with: Service Providers
- Commercial information: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. – Will be collected – May be shared with: Service Providers, Affiliates
Notice at Collection. The categories of sources from which we collect Personal Information and our business and commercial purposes for using Personal Information are set forth in “Personal Information We Collect” and “How We Use Your Personal Information” above, respectively.
Additionally, you have the right to ask us for (i) confirmation on whether we are processing your Personal Information, and (ii) to provide you with access to the Personal Information about you that we collect. Specifically, you may request the specific Personal Information that we collected about you. To do any of the foregoing, e-mail us at privacy@heirloomcarbon.com.
B. “Sales” of Personal Information under the CCPA
For purposes of the CCPA, Heirloom does not “sell” Personal Information, nor do we have actual knowledge of any “sale” of Personal Information of minors under 16 years of age.
C. Your Right to Correct
You have the right to correct your Personal Information.
D. Your Right to Delete under Cal. Civ. Code 1798.105
You have the right to delete your Personal Information.
E. Your Right to Limit under Cal. Civ. Code 1798.121
In certain circumstances, you have the right to limit certain uses and disclosures of your Sensitive Personal information (Cal. Civ. Code 1798.121).
We use the very limited Special Personal Information we collect to perform the Services, including maintaining or servicing accounts, providing customer service, processing, or fulfilling orders and transactions, verifying your information, processing payments (See Cal. Civ. Code 1798.140(e)(5) and 1798.121(a))
To the extent our use of your Sensitive Personal Information is not already limited, you have the right to limit our use of any of such Sensitive Personal Information to only that which is required to perform the Carbon Services our website provides and related services such as website security, debugging, and compliance.
You have the right to obtain a list of what Personal Information we’ve disclosed to third-parties and to whom for direct marketing purposes (Cal. Civ. Code 1798.83). California residents may request and obtain from us a list of what Personal Data (if any) we disclosed to third parties for that third party's direct marketing purposes in the preceding calendar year and the names and addresses of those third parties.
That said, we do not share your Personal Information with third parties for their marketing purposes.
F. Your Right to Opt-Out under Cal. Civ. Code 1798.120.
This right to Opt-Out only applies to:
- the Personal Information of its users that businesses may sell to or share with third-parties - as we do not sell any of your Personal Information, this only applies to the Personal Information we share.
- the Sensitive Personal Information that businesses may collect, sell, or share (unless the business uses such Sensitive Personal Information for a specific purpose outlined in 11 Cal. Code Regs 7027) – any Sensitive Personal Information we collect is solely for facilitating the Carbon Services.
You have the right to opt out of sharing certain Sensitive Personal information (Cal. Civ Code 1798.120). You have the right to opt out of certain data sharing practices with third parties who may use your Personal Data solely for their own purposes.
As we neither sell your Personal Information nor share your Personal Information for purposes of advertising, there is not much to opt out of:
- You are already opted-out of sharing your Personal Information for targeted advertising or direct marketing;
- To opt-out of certain categories of tracking, go to privacy@heirloomcarbon.com
- To unsubscribe from any email marketing, go to privacy@heirloomcarbon.com or use the unsubscribe link contained in each email you receive from us.
Note, we may still use your Sensitive Personal Information for certain purposes such as providing you with Carbon Services that you have purchased.
G. The Rights of Minors under Cal. Civ. Code 1798.120(c)
We do not intentionally collect or share the Personal Information of any individual who is under the age of sixteen (16) and we require any purchaser of our Carbon Services to certify that they are at least eighteen (18) years of age.
If you are a registered user under the age of 18 and a resident of California, you or your legal guardian may request removal of your Personal Information. Please note that making such requests does not ensure complete or comprehensive removal of the content. For example, we may retain the information for our own internal records, and it is also possible that a third party we do not own or control may copy the posting and repost it elsewhere.
H. Non-Discrimination
California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.
I. Making Requests
You may elect to exercise any of the foregoing rights at any time. We will not discriminate against you, in terms of price or Services that we offer, if you elect to exercise any of the rights requested above.
To exercise any of the foregoing rights you may email us at Privacy@heirloomcarbon.com.
Here are some general guidelines:
- Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child, if you believe we have inadvertently collected your child’s Personal information. To designate an authorized agent, please contact us at Privacy@heirloomcarbon.com for additional instructions.
- De-Identified Information. If we create or receive de-identified information, we will not attempt to reidentify such information, except to comply with applicable law.
We will comply with your request as soon as reasonably practicable. Requests to exercise your rights may be granted in whole, in part, or not at all, depending on the scope and nature of the request and the requirements of California and federal law.
To prevent unauthorized access to your Personal Information, we take steps to verify an individual's right to the data - including requiring users to reach out to us directly from a verified email address, pass a challenge response, and/or confirm information associated with the account. If we have a good-faith, reasonable, and documented belief that a request for any of the foregoing is fraudulent, we may deny the request. If we deny the request, we will inform the requestor and the reason why we believe the request is fraudulent.
Following verification of your identity, we will notify you that we have fulfilled your request or, if we are unable to fulfill your request, we will outline the reasons. We will honor any request that we can fulfill for at least twelve (12) months.
If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us at Privacy@heirloomcarbon.com. We will process such requests in accordance with applicable laws.
10. Supplemental Notice For Nevada Residents
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. Please note that we do not currently sell or license your Personal Information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us at Privacy@heirloomcarbon.com.
11. Children’s Information
The Carbon Services are not directed to children under 18 (or other age as required by local law), and we do not knowingly collect Personal Information from children.
If you are a parent or guardian and believe your child has uploaded Personal Information to our Services without your consent, and you wish to review information collected from your child or have that information modified or deleted, you may contact us at Privacy@heirloomcarbon.com. If we become aware that a child has provided us with Personal Information in violation of applicable law, we will delete any Personal Information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account, if applicable.
12. Other Provisions
Third-Party Services. Certain features and functionalities of the Services may link to or allow you to interface, interact, or share information with, access and/or use third-party websites, services, products, and technology (collectively, “Third-Party Services”). Any information disclosed to or otherwise collected by a Third-Party Service may be subject to the Third-Party Service’s privacy policy. We do not provide or control any aspect of the Third-Party Services and are not responsible for any compatibility issues, errors or bugs in the Services or Third-Party Services caused in whole or in part by the Third-Party Services or any update or upgrade thereto. We encourage our users to read the privacy policies of each Third-Party Service with which they interact. We do not endorse, screen or approve, and are not responsible for such Third-Party Services. Providing information to or interacting with Third-Party Services is at your own risk.
Changes to our Privacy Policy. We may revise this Policy from time to time at our sole discretion. If there are any material changes to this Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.