Privacy Policy
Effective date: 04/01/2020 Version 2, May 4, 2020
1. Introduction
Welcome to Regen Network Development, Inc.
Regen Network Development, Inc. (“RND”, “us”, “we”, or “our”) operates https://www.regen.network (hereinafter referred to as Service). At RND, we are committed to protecting the privacy and security of your personal information. This Privacy Policy describes the types of personal information we may collect, how we may use this information and when (under certain circumstances) we may disclose this information. This Privacy Policy also details the steps we have taken to secure your personal information. By visiting our Site, you accept the practices described in this Privacy Policy. We are not responsible for the content on, or privacy practices of, any non-RND web site to which this Site links or that links to this Site.
Our Privacy Policy governs your visit to https://www.regen.network, and explains how we collect, protect and disclose information that results from your use of our Service.
We use your data to provide and improve Service. By using Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.
Our Terms and Conditions (“Terms”) govern all use of our Service and together with the Privacy Policy constitutes your agreement with us (“agreement”).
2. Definitions
SERVICE means the website https://www.regen.network operated by Regen Network Development, Inc.
USER DATA means data about a living individual or organization who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
USAGE DATA is data collected automatically either generated by the use of Service or from Service infrastructure itself (for example, the duration of a page visit).
COOKIES are small files stored on your device (computer or mobile device).
DATA CONTROLLER means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any User Data are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your data.
DATA PROCESSORS (OR SERVICE PROVIDERS) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.
DATA SUBJECT is any living individual who is the subject of User Data.
THE USER is the individual using our Service. The User corresponds to the Data Subject, who is the subject of User Data.
REGEN LEDGER is a decentralized data persistence layer that RND leverages to track the issuance, transfer and sale of ecosystem service credits.
REGEN REGISTRY is an ecosystem service credit marketplace operated by RND.
3. Information Collection and Use
We collect several different types of information for various purposes to provide and improve our Service to you.
4. Types of Data Collected and the Right to Be Forgotten
User Profile Data
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (User Profile Data). Personally identifiable information may include, but is not limited to:
- Email address
- First name, last name, entity/company name
- Phone number
- Address, State, Province, ZIP/Postal code, City, Country
- Farm data to enable the creation of ecosystem service credits, which could include, but is not limited to GIS data, land management history (including photos), soil samples, lab results etc.
- Financial information (bank account or credit card) to distribute proceeds from purchase or sale of ecosystem services
We may use your User Profile Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link.
Project Data
While using our Service, we may ask you to provide us with certain information that can be used in the development of ecosystem service credits (Project Data). Information may include, but is not limited to:
- Farm data to enable the creation of ecosystem service credits, which could include, but is not limited to GIS data, land management history (including photos), soil samples, lab results etc.
- Land tenure
Usage Data
We may also collect information that your browser sends whenever you visit our Service or when you access Service by or through a mobile device (Usage Data).
This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When you access Service with a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.
Location Data
We may use and store information about your location if you give us permission to do so (Location Data). We use this data to provide features of our Service, to improve and customize our Service.
You can enable or disable location services when you use our Service at any time by way of your device settings.
The Right to Be Forgotten
Users shall have the right to the erasure of personal data without undue delay and RND shall have the obligation to erase personal data without undue delay. In the case where information can be stripped of identifiers, RND retains the rights to the use of this data. Inquiries can be sent by email to office@regen.network.
Tracking Cookies Data
RND may use any number of tools to collect information about you, your computer access points, and the web browser that you use to connect to our Site, including cookie, web beacon, pixel tag and clear gif technology. We use cookies and web beacons to identify your device, provide website user authentication, conduct fraud prevention and management services, distinguish you from other visitors, record your IP address and understand your use of our application, and identify the name of the website from which you linked to RND. This information is used for fulfilling contracts with our business partners, and to help us serve you better by improving our Site design, as well as our products, services, and promotions. We do not otherwise track any information about your use of other web sites. Information obtained through cookies and web beacons may be shared with or obtained by service providers on our behalf.
A cookie is a small data file that is placed on the hard drive of your computer when you visit a web site. A session cookie expires immediately when you end your session (i.e., close your browser). A persistent cookie stores information on the hard drive so when you end your session and return to the same web site at a later date, the cookie information is still available. A web beacon is a small string of code that represents a clear graphic image and is used in conjunction with a cookie.
When you visit our Site, we may use both a session and a persistent cookie. This RND-placed cookie may contain information (such as a unique user ID) that is used to track your usage of our Site and in some cases, your email address. Your email address is only saved in this RND-placed cookie if you register with us. A web beacon allows us to capture certain additional types of information about a visitor’s actions on a web site, such as a visitor’s cookie number, the time, date, duration and number of page views, a description of the page where the web beacon is placed, and details about any items that were purchased.
If you register with us, this RND-placed cookie allows us to recognize you when you return to our Site, and provides you with access to your account information. If you save your information with or order from us, we may also use cookies to monitor and maintain information about your use of our Site. If you have not saved your information with or ordered from us, we may monitor and maintain information about your use of our Site in a manner that does not identify you. You can disable cookies at any time by using your browser options; however, if you turn off cookies, we will not be able to track your order or enable you to make a purchase from our Site. In addition, we will not be able to recognize you as a registered user to allow you access to your account information.
We may use Flash Cookies (also known as Local Stored Objects) or other similar technologies. A Flash cookie is a small data file placed on a computer using Adobe Flash technology that may be built into your computer or downloaded by you to your computer. We use these technologies to personalize and enhance your online experience, facilitate processes, personalize and store your settings. Flash cookies may help our Site visitors to, for example, set volume preferences associated with a video experience, play games and perform surveys. They help us improve our web sites by measuring which areas are of greatest interest to customers. We do not use Flash cookies for marketing or behavioral targeting purposes. Flash cookies are different from browser cookies and the cookie management tools provided by your browser will not remove Flash cookies. If you disable Flash cookies or other similar technologies, please be aware that you may not have access to certain features and services that make your online experience more efficient and enjoyable.
Before using the Site, you are advised to check your current browser settings to ensure that the settings reflect your consent for RND to place cookies on your devices.
Device Identifiers
When you use a mobile device like a tablet or phone to access our Site, we may access, collect, monitor, store on your device, and/or remotely store one or more device identifiers. Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to the device by RND.
A device identifier may deliver information to us or to a third-party partner about how you browse and use the Site and may help us or others provide reports or personalized content and ads. Some features of the Site may not function properly if use or availability of device identifiers is impaired or disabled.
Other Data
While using our Service, we may also collect the following information: sex, age, date of birth, place of birth, passport details, citizenship, registration at place of residence and actual address, telephone number (work, mobile), details of documents on education, qualification, professional training, employment agreements, non-disclosure agreements, information on bonuses and compensation, information on marital status, family members, social security (or other taxpayer identification) number, office location and other data.
5. Use of Data
We do not sell or rent information about our users and all information provided to CONSENT remains absolutely confidential, except that we may use information that we receive to:
- Help you efficiently access your information after you sign in;
- Remember information so you will not have to re-enter it during your visit or the next time you visit the Site;
- Provide personalized content and information to you and others, which could include online ads or other forms of marketing;
- Provide, improve, test and monitor the effectiveness of our Site;
- Develop and test new products and features;
- Monitor metrics such as total number of visitors, traffic and demographic patterns; and diagnose or fix technology problems.
Regen Network Development, Inc. uses the collected data for various purposes:
- to develop methodologies and serve in the generation of ecosystem service credits
- to create project pages including farm data and available ecosystem service credits
- to provide and maintain our Service;
- to notify you about changes to our Service;
- to allow you to participate in interactive features of our Service when you choose to do so;
- to provide customer support;
- to gather analysis or valuable information so that we can improve our Service;
- to monitor the usage of our Service;
- to detect, prevent and address technical issues;
- to fulfill any other purpose for which you provide it;
- to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
- to provide you with notices about your account and/or subscription, including expiration and renewal notices, email-instructions, etc.;
- to provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information;
- in any other way we may describe when you provide the information;
- for any other purpose with your consent.
6. Retention of Data
We will retain your User Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your User Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
Project Data will be retained indefinitely, as it backs ecosystem service credits, which are durable assets that are required to meet compliance standards.
We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
STORAGE OF YOUR INFORMATION
Your information collected through the Site may be stored and processed in the United States or any other country in which RND, its Affiliates or Service Providers maintain facilities.
RND, its Affiliates, or Service Providers may transfer information that we collect about you, including personal information across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction.
By using the Site, you consent to the transfer of information to the U.S. or to any other country in which RND, its Affiliates or Service Providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.
We use commercially reasonable safeguards to help keep the information collected through the App secure and take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. However, RND cannot ensure the security of any information you transmit to RND or guarantee that information on the Site may not be accessed, disclosed, altered, or destroyed.
Please do your part to help us. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to emails between you and RND, at all times. Your privacy settings may also be affected by changes to the social media services you connect to RND make to their services. We are not responsible for the functionality, privacy, or security measures of any other organization.
OFFLINE COLLECTION, USE; DISCLOSURE OF INFORMATION
We will not rent or sell your information to third parties outside RND without your consent, except as noted in this Policy.
Parties with whom we may share your information: We may share information (including but not limited to, information from cookies, log files, device identifiers, location data, and usage data) with businesses that are legally part of the same group of companies that RND is part of, or that become part of that group (Affiliates). Affiliates may use this information to help provide, understand, and improve the service we provide (including by providing analytics) and Affiliates own services (including by providing you with better and more relevant experiences).
We also may share your information as well as information from tools like cookies, log files, and device identifiers and location data, with third-party organizations that help us provide services to you (Service Providers). Our Service Providers will be given access to your information as is reasonably necessary to provide the Service under reasonable confidentiality terms.
We may also share certain information such as cookie data with third-party advertising partners. This information would allow third-party ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you.
We may remove parts of data that can identify you and share anonymized data with other parties. We may also combine your information with other information in a way that it is no longer associated with you and share that aggregated information.
Parties with whom you may choose to share your information: Any information or content that you voluntarily disclose, such as comments, becomes available to the public. Once you have shared content or made it public, that content may be re-shared by others.
If you remove information that you posted to the Site, copies may remain viewable in cached and archived pages, or if other users or third parties using the Site have copied or saved that information.
7. Transfer of Data
Your information, including User Data, may be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including User Data, to the United States and process it there.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
Regen Network Development, Inc. will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your User Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.
8. Disclosure of Data
We may disclose personal information that we collect, or you provide:
- Disclosure for Ecosystem Service Credit Registry listings. In order to list your project on the Regen Registry, we may need to disclose various aspects of farm data through our Registry marketplace.
- Disclose for the Creation of Ecosystem Service Credits on Regen Ledger. We will disclose a subset of Project Data for the creation of credits on Regen Ledger
- Disclosure for Law Enforcement. Under certain circumstances, we may be required to disclose your User Data or Project Data if required to do so by law or in response to valid requests by public authorities.
- Business Transaction. If we or our subsidiaries are involved in a merger, acquisition or asset sale, your User Data and Project Data may be transferred.
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Other cases. We may disclose your information:
- To our subsidiaries and affiliates;
- To fulfill the purpose for which you provide it;
- For the purpose of including your company’s logo on our website;
- For any other purpose disclosed by us when you provide the information;
9. Security of Data
The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your User Data, we cannot guarantee its absolute security.
PROTECTING YOUR INFORMATION
Your personal information including your name and address is encrypted so that it cannot be read as it is transmitted over the Internet. Regardless of these efforts, no data transmission over the Internet can be guaranteed to be 100% secure. Therefore, any information you transmit to us is sent at your own risk.
10. Your Data Protection Rights Under General Data Protection Regulation (GDPR)
If you are a resident of the European Union (EU) and European Economic Area (EEA), you have certain data protection rights, covered by GDPR. See more at
https://eur-lex.europa.eu/eli/reg/2016/679/oj
We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your User Data. If you wish to be informed what User Data we hold about you and if you want it to be removed from our systems, please email us at office@regen.network.
In certain circumstances, you have the following data protection rights:
- the right to access, update or to delete the information we have on you;
- the right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete;
- the right to object. You have the right to object to our processing of your User Data;
- the right of restriction. You have the right to request that we restrict the processing of your personal information;
- the right to data portability. You have the right to be provided with a copy of your User Data in a structured, machine-readable and commonly used format;
- the right to withdraw consent. You also have the right to withdraw your consent at any time where we rely on your consent to process your personal information;
Please note that we may ask you to verify your identity before responding to such requests. Please note, we may not be able to provide Service without some necessary data.
You have the right to complain to a Data Protection Authority about our collection and use of your User Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
11. Your Data Protection Rights under the California Privacy Protection Act (CalOPPA)
CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law's reach stretches well beyond California to require a person or company in the United States (and conceivable the world) that operates websites collecting personally identifiable information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy. See more at
https://consumercal.org/about-cfc/cfc-education-foundation/california-online-privacy-protection-act-caloppa-3/
According to CalOPPA we agree to the following:
- users can visit our site anonymously;
- our Privacy Policy link includes the word Privacy, and can easily be found on the page specified above on the home page of our website;
- users will be notified of any privacy policy changes on our Privacy Policy Page;
- users are able to change their personal information by emailing us at office@regen.network.
Our Policy on Do Not Track Signals:
We honor Do Not Track signals and do not track or plant cookies when a Do Not Track browser mechanism is in place. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
12. Service Providers
We may employ third party companies and individuals to facilitate our Service (Service Providers), provide Service on our behalf, perform Service-related services or assist us in analysing how our Service is used.
These third parties have access to your User Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Amazon Web Services
Amazon Web Services (AWS) is a hosting service. Read more about their legal policies here:
https://aws.amazon.com/legal/?nc1=f_cc
Auth0
Auth0 is an authentication service. Read more about their Privacy Policy here:
https://auth0.com/privacy/
Airtable
Airtable is a survey management tool. Read more about their Privacy Policy here:
https://airtable.com/privacy
13. Analytics
We may use third-party Service Providers to monitor and analyze the use of our Service.
Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page:
https://policies.google.com/privacy?hl=en
We also encourage you to review Google's policy for safeguarding your data:
https://support.google.com/analytics/answer/6004245.
Mixpanel
Mixpanel is a web analytics service. Read more about their privacy policy here:
https://mixpanel.com/legal/privacy-policy/
14. Code Repositories
We may use third-party Service Providers to automate the development process of our Service.
GitHub
GitHub is provided by GitHub, Inc. GitHub is a development platform to host and review code, manage projects, and build software. For more information on what data GitHub collects for what purpose and how the protection of the data is ensured, please visit GitHub Privacy Policy page:
https://help.github.com/en/articles/github-privacy-statement.
Netlify CMS
Netlify CMS is an open-source content management system for Git workflow. Read their Code of Conduct here:
https://github.com/netlify/netlify-cms/blob/master/CODE_OF_CONDUCT.md
Heroku
Hekoku is a Platform-as-a-Service for running applications in the cloud. Read more about their Privacy Policy here:
https://www.salesforce.com/company/privacy/
15. Payments
We may provide paid products and/or services within Service. In that case, we use third-party services for payment processing (e.g. payment processors).
We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
The payment processors we work with are:
Stripe
Their Privacy Policy can be viewed at:
https://stripe.com/us/privacy
16. Links to Other Sites
Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
17. Children's Privacy
Our Services are not intended for use by children under the age of 18 (Child or Children).
We do not knowingly collect personally identifiable information from Children under 18. If you become aware that a Child has provided us with User Data, please contact us. If we become aware that we have collected User Data from Children without verification of parental consent, we take steps to remove that information from our servers.
18. Changes to This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update effective date at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
ENFORCEMENT
RND uses a self-assessment approach to assure compliance with this privacy policy and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible. We encourage interested persons to raise any concerns using the contact information provided and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Information in accordance with the principles.
19. Contact Us
If you have any questions about this Privacy Policy, please contact us: By email: office@regen.network.