Global Energy Alliance for People and Planet (GEAPP) LLC in furtherance of the Africa Carbon Markets Initiative project ("ACMI", "we", "us", "our") respects your privacy and is committed to protecting your Personal Data. This Privacy Notice applies to information we need to collect, organise, store, transmit, and otherwise process or use ("Process") about suppliers and prospective suppliers, contacts and all other persons about whom ACMI holds information. This information includes any data that relates to an identified or identifiable person or makes a person identifiable ("Personal Data"), such as names, addresses, electronic device information (e.g. device IDs and IP addresses), activities and other identifiers. This notice will also tell you about your privacy rights and how the law protects you.

This Privacy Notice provides information on how ACMI collects and processes your Personal Data when you visit the ACMI website at https://africacarbonmarkets.org (the "Website"), and/or access or receive ACMI initiatives, communications, and you otherwise engage with us (collectively with the Website, the "Services"). This Privacy Notice should be read in conjunction with the Terms of Service [Insert hyperlink] (the "Terms")

For supplemental information regarding our data collection, use and sharing practices when you interact directly with us, such as through applying for a job, developing and executing a grant proposal or engaging with ACMI on projects, please contact us by emailing us at [insert relevant privacy contact's email address here, i.e. privacy@africacarbonmarkets.org].

The Services are not intended for children and we do not knowingly collect data relating to children.

1. Important information and who we are

The Website is owned and operated by ACMI, and ACMI is responsible for the Personal Data we collect and process. If you have any questions about this Privacy Notice or our data protection practices, including any requests to exercise your legal rights, please contact us using the following details:

CONTACT DETAILS

Email address: [insert relevant privacy  email address here, i.e. privacy@africacarbonmarkets.org]

Postal address: Privacy Office, Global Energy Alliance for People and Planet (GEAPP) LLC, 420 Fifth Avenue, New York, NY 10018, USA,

2. The data we collect about you

We may collect, use, store and transfer different kinds of Personal Data about you including:

• Identity Data, such as first and last name;
• Contact Data, such as email address, telephone numbers and physical address;
• Technical Data, such as your IP address, location data, device data, or a cookie ID;
• Usage Data, including data which tells us how often you access our Services, how long you spend on specific parts of the Website and the activities you undertake when visiting;
• Marketing and Communications Data, including whether you have signed up for our communications or consented to receive other electronic marketing communications, and your preferences regarding the same.
• Account information that you include as part of registration and account creation.
• Other information that you may include as part of any of Your Content (as defined in the Terms).

We may also collect non-Personal Data that does not directly or indirectly reveal your identity or directly relate to an identified individual, such as statistics or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from Personal Data. For example, we may aggregate Personal Data to calculate the percentage of users accessing a specific Website feature.

We use different methods to collect data about you, mainly through our Website, collecting data at events or from our partners, or when you correspond with us, for example, to enquire about our activities.

In limited circumstances we may collect, use or share aggregated data such as statistical or demographic data, or collect special categories of Personal Data about you, including details about your race, ethnicity, or political opinions. We do not collect any Personal Data about criminal convictions and offences via this Website or the Services. Where we process special categories of data, we will process this data under the correct lawful basis and conditions for processing, as required under applicable data protection legislation, and we will only use your Personal Data when the law allows us to. Note that we will not use this type of sensitive personal data (e.g. race, ethnicity, sexual orientation, or political opinions) to select potential candidates for ACMI roles.

3. How we use your Personal Data

We will only use your Personal Data for the purpose for which we collected it, which may include the following:

• As a visitor to the Website or other Services;
• To register you as a new contact;
• Communicate with you, including to respond to your inquiries and fulfil your requests;
• To carry out our obligations and enforce our rights arising from any agreements entered into between you and us;
• To process and deliver any documents and other communications, content or information;
• To manage your relationship with us;
• To administer our Services and conduct internal operations, including for troubleshooting, data analysis, testing, research, statistical, and survey purposes;
• To understand how popular specific content or a particular page on our Website is;
• To improve our Website's functionality, our Services, or our marketing or partner relationships;
• To recommend information or Services which may be of interest to you;
• To notify you about changes to our Services or activities;
• To communicate with you generally, for example, regarding events, or via marketing emails or other communications; and
• To protect our Services, employees, or operations; and
• To comply with legal and regulatory obligations.

We may use non-Personal Data for any business purpose.

4. Legal basis for processing

We process your Personal Data:

• where we need to perform the contract we are about to enter into or have entered into with you or your organisation;
• for the purposes of legitimate interest pursued by us (or those of a third party), and your interests and fundamental rights do not override those interests; or
• in order to comply with a legal and regulatory obligation to which we are subject;
• where processing is necessary to protect the vital interests of the data subject or another natural person;
• for the establishment, exercise or defence of legal claims.

Generally, we do not rely on consent as a legal basis for processing your Personal Data although we will get your consent in certain specific instances.

You have the right to withdraw consent to marketing at any time by contacting us.

Legitimate interests

Where our processing is based on the legitimate interest grounds described above, those legitimate interests include:

• collecting Personal Data to provide a smooth and efficient relationship experience;
• to make sure you receive updated information on our business activities;
• to provide the Services you have requested; and
• for our own marketing and research.

5. Opting Out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.

Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of a relevant Service.

6. If You Fail to Provide Personal Data

Where we need to collect Personal Data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel any relevant contract you have with us but we will notify you if this is the case at the time.

7. Change of Purpose

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

8. How we share your Personal Data

Except as expressly set out in this Privacy Notice we will not sell, distribute or lease your Personal Data to third parties unless we have your permission or are required by law to do so.

The Personal Data you provide to us may be shared with third-party companies, agents, contractors, service providers or affiliated companies to provide you with our Services, respond to your inquiries or for any of the purposes described in this Privacy Notice.

We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not permit our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

We may also share your Personal Data with:

• law enforcement agencies, other governmental agencies or third parties if we are required by law to do so; and
• other business entities should we plan to merge with or be acquired by that business entity, or if we undergo a re-organisation with that entity.

9. International Data Transfer

Your Personal Data may be transferred to, stored and processed in various countries – including the U.S., the U.K., Kenya, and members of the EU – which including some that are not regarded as ensuring an adequate level of protection for Personal Data under EU law or by the European Commission. We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that your data is adequately protected. For more information on the appropriate safeguards in place, please contact us at the details below.

10. Your legal rights

You have the following rights under data protection laws in relation to your Personal Data:

• to request access to or a copy of Personal Data which we hold about you;
• to request erasure of your Personal Data if certain conditions apply;
• to rectification of your Personal Data, if the information we are holding is inaccurate or incomplete;
• to withdraw consent to our processing of your Personal Data (to the extent such processing is based on previously obtained consent);
• to ask us to stop or start sending you marketing messages as described below in the marketing section;
• to request the transfer of your Personal Data to you or to a third party;
• to request the restriction of processing of your Personal Data;
• and to object to your Personal Data being processed in certain circumstances.

Any request from you for access to/a copy of your Personal Data must be in writing and we will endeavour to respond within a reasonable period in compliance with data protection legislation. We will comply with our legal obligations as regards your rights as a Data Subject.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee, if and as permitted by applicable law, if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

11. How long we keep Personal Data

We will only keep the information we collect about you for as long as required for the purposes set out above or as required to comply with any legal obligations to which we are subject.

This will involve us periodically reviewing our files to check that information is accurate, up-to-date and still required.

Where we are permitted to send you direct marketing communications we may retain your contact information necessary for this purpose, for as long as you do not unsubscribe from receiving the same from us. If you opt out from marketing, we will retain your information to enable us to respect your wishes to not be contacted for marketing purposes.

12. Cookies

When you interact with the Website, certain information about your use of the Website is automatically collected. This information includes your domain name and host for Internet access; the Internet address of the website from which you came; the date and time of your access; your computer’s IP address and information about its operating system, browser and host; the date and time you access the Website and the pages you visit. Much of this information is collected through cookies, web beacons, and other tracking technologies, as well as through your web browser or device (e.g., IP address, MAC address, browser version, etc.). The tracking technologies employed when you use our Website may be first party or third-party. We use cookies for the following purposes:

• Necessary: These cookies are required for core Website functionality such as security, network management, and accessibility. You may disable these by changing your browser settings to disable cookies, entirely but this may affect how the Website operates.
• Performance/Analytics: We use these cookies to analyse how the Website is accessed, used or is performing. We use this information to maintain, operate and continually improve the Website. We may also obtain information from our e-mail communications, to learn whether you opened or forwarded the communications or clicked on any of the content. This information tells us about our communications’ effectiveness and helps us ensure that we’re delivering information that you find interesting.
• Advertising: Interest-based advertising is the collection of data across different websites and/or difference devices for the purpose of tailoring advertising based on preferences or interests known or inferred from the data collected. We allow third parties, such as Google, Facebook, and Twitter, who assist us in serving advertising regarding the Website when you leave the Website, to collect or receive information from our Website and elsewhere on the internet and use that information to provide measurement services and target ads.

The third-party Website analytics tools that collect automated information about visitor traffic on our Website include Google Analytics. Google Analytics is a web analytics service provided by Google, Inc., on our Website. Google Analytics uses cookies or other tracking technologies to help us analyse how users interact with and use the Website, compile reports on the Website’s activity, and provide other services related to the Website’s activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a return visitor, and any referring website. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. You can learn how Google collects and processes data and how to opt out of tracking of analytics by Google, by clicking here.

You may set your browser to reject cookies. However, if you turn cookies off, you may not have access to some of the Website’s services and features. We also may allow third parties to issue cookies, pixels, web beacons and other tracking technologies on our Website to help us compile aggregated statistics regarding the operations of our Website. You can learn more about ad serving companies and the options available to limit their collection and use of your information by visiting the websites for the Network Advertising Initiative, the Digital Advertising Alliance, Adchoices (for Canada) and the European Interactive Digital Advertising Initiative. Similarly, you can learn about your options to opt-out of mobile app tracking by certain advertising networks through your device settings and by resetting the advertiser ID on your Apple or Android device.

Because an industry-standard Do-Not-Track protocol has not yet been established, our information collection practices on our Website will continue to operate as described in this Privacy Notice regardless of any “Do Not Track” signals that may be sent by certain browsers. However, you may refuse to accept cookies in order to prevent tracking activities.

13. Security

We are committed to trying to ensure that your information is secure. In order to prevent unauthorised access or disclosure, we use reasonable physical, electronic and managerial procedures intended to safeguard and secure the information we collect online.

14. Links to Other Sites

The Services may include links to third-party websites or apps, including social media platforms. Those third-party websites and services are not Services operated or controlled by us. This Privacy Notice does not apply to, and we do not control and are not responsible for, the practices of those third-party websites or services. Hypertext links are provided as a service to users and are not necessarily sponsored by or affiliated with the Services or ACMI. ACMI has not necessarily reviewed the websites hyperlinked to or from the Services and is not responsible for the content of any other website. These links are to be accessed at your own risk. Once you link to another website from our Services you are subject to the terms of that website, including, but not limited to, its internet privacy policy and practices, so we encourage you to read the privacy policy of every website you visit. ACMI makes no representations or warranties about the content, completeness, or accuracy of these links or the websites hyperlinked to or from the Services, nor with respect to the security or privacy practices of those websites or services. Furthermore, ACMI does not endorse, explicitly or implicitly, third-party websites or services hyperlinked to or from the Services.

15. Complaints

Questions, comments and requests regarding this Privacy Notice are welcomed and should be addressed to [please insert correct ACMI privacy email address].

If you have any concerns about our use of your information, you also have the right to make a complaint to the applicable data protection authority. We would, however, appreciate the chance to deal with your concerns before you approach such an authority so please contact us in the first instance.

16. Changes to This Privacy Notice and Your Duty to Inform Us of Changes

ACMI reserves the right to change or modify this Privacy Notice at any time in our sole discretion without further notice. When we make changes to this Privacy Notice, we will post any changes on this page so please check back frequently so you are aware of any changes, as they are binding on you. Changes will be effective immediately upon being posted on this page unless otherwise specified. If we make material changes, if we have your contact information, we will attempt to notify you directly of any changes. Continuing to use the Services after we post changes to this Privacy Notice constitutes your acceptance of those changes.

We aim to ensure that the information we hold about you is accurate at all times. To assist us in ensuring that your information is up to date, do let us know if any of your personal details change at the following email address: [please insert correct ACMI privacy email address].

Last Updated: August 2023