About our services and this Privacy Policy

Single.Earth is committed to protecting the privacy and confidentiality of our users, and being transparent about how we process personal information. This Privacy Policy (“Policy”) will inform you as to how we look after your personal information when you visit our website or use our services and describes how we process your personal information and how you can exercise your privacy rights. It meets the requirements of General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the "GDPR").

References in this Privacy Policy to "Single.Earth", "we", "our" or "us", are to Single.Earth OÜ and references to “user”, “you” or “your” are to the person who signs up to use the Single.Earth services, creates the Single.Earth account or browses our website.

The website www.single.earth and its subdomains are operated by Single.Earth OÜ, a company established and existing under the laws of the Republic of Estonia with the registry code 14873080 and registered address at Telliskivi 60/2, Tallinn 10412, Estonia. Single.Earth operates under the virtual asset service provider license issued by the Estonian Financial Intelligence Unit (license no. FVT000524).

Our overall goal is to build a system of technical, scientific and financial means which would facilitate conservation of the natural environment to maintain and improve the provision of ecosystem services (namely carbon sequestration in biomass) and ecosystem integrity (function, structure and composition of ecosystems, i.e., biodiversity) globally. 

More information about our (future) services and how you can use them can be found on our website at  www.single.earth. Please take the time to also read through our Website Terms of Use when using our website. If you have any questions about this Policy, please submit your request to support@single.earth.

PLEASE TAKE A MOMENT TO READ THIS PRIVACY POLICY CAREFULLY. BY ACCESSING OUR WEBSITE AND USING OUR SERVICES, YOU ACCEPT THE TERMS OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH ANY ASPECT OF THIS PRIVACY POLICY, YOU SHOULD IMMEDIATELY DISCONTINUE ACCESS OR USE OF OUR WEBSITE AND SERVICES.

We may modify this Privacy Policy from time to time which will be indicated by changing the date at the top of this page. If we make any material changes, we will notify you by email (sent to the email address specified in your account), by means of a notice on our services prior to the change becoming effective, or as otherwise required by law.

1. How we collect personal information


1.1 Personal information is typically data that identifies an individual or relates to an identifiable individual. This includes information you provide to us, information which is collected about you automatically, and information we obtain from third parties. 

1.2 To establish an account and access our services, we'll ask you to provide us with some important information about yourself. We may also ask you to upload some files containing the information about your lands, which may include personal data about you or other persons. You confirm that your disclosure of any personal data relating to individuals other than yourself was or will be made in accordance with all applicable data protection laws and you have the consent or legal grounds to do so.

1.3 If you choose not to share certain information with us, we may not be able to serve you as effectively or offer you our services. Any information you provide to us that is not required is voluntary.

1.4 As we add new features and services, you may be asked to provide additional information.

1.5 The personal information we process depends on the context of your interactions with Single.Earth, however, the personal information we collect broadly falls into the following categories:

1.5.1. general personal information: first name, last name, country of residency;

1.5.2. identification data: date and place of birth, address, tax residency, citizenship; ID document and data included in the ID document (also photo taken by device’s camera);

1.5.3. contact data: mailing address, phone number, email address;

1.5.4. information about persons related to a legal entity: first and last name(s), date of birth, address of the board member(s) and ultimate beneficial owner(s), ownership structure document;

1.5.5. account related details: login details; password;

1.5.6. video recording: video recording by using device’s camera during the verification process;

1.5.7. financial information: bank account information, source of funds, source of wealth; 

1.5.8. transaction data and nature of using the service: transaction sums, counter-parties;

1.5.9. other data used for performing customer due diligence measures, assessing trustworthiness and to prevent fraud: media coverage, occupation and connection to other persons, whether you are a politically exposed person or have (had) contacts with politically exposed persons;

1.5.10. information about the politically exposed person: your link to the politically exposed person, first and last name, date of birth, country of residency;

1.5.11. usage information: information on how our services and platform are used, including feedback provided;

1.5.12. technical information: technical information collected during use of the services (please also see our Cookie Policy for further information about the use of cookies);

1.5.13. correspondence between you and us

2.What is the purpose and legal basis for processing your personal data


2.1. We process your personal data based on the applicable legal requirements, based on our legitimate interests or your consent. Our primary purpose in collecting personal information is to provide you with a secure, smooth and efficient experience in using our services. In some cases, mainly but not limited to anti money laundering laws and regulations and for the purposes of fighting fraud, we may be required by law to collect certain types of personal data about you. We generally use personal information to create, develop, operate, deliver, and improve our services, content and anti-fraud purposes.

2.2 We may use your personal information which we collect for the purposes and on the legal bases identified below:

Purpose Legal basis
To maintain legal and regulatory compliance and to detect and prevent fraud:
most of our services are subject to laws and regulations requiring us to collect, use, and store your personal information in certain ways in order to comply with anti-money laundering laws (e.g identification and ID document information, video recording of the verification). We also process your personal information in order to help detect, prevent, and mitigate fraud and abuse of our services.
For compliance with a legal obligation [GDPR Article 6-1(c)]
We may rely on legal obligation as a legal basis when transferring your personal data to third parties. For example to verify your identity by comparing the personal information you provide against third-party databases and public records and/or to fraud prevention services.
To enable you access to our platform and provide you our services: such as carrying out your transactions on the platform, evaluating your land etc. For the performance of a contract with you or to take steps at your request prior to entering into a contract [GDPR Article 6-1(b)]
To communicate with you regarding our service: for example, we may inform you about temporary or permanent changes to our service, such as planned outages, security or compliance notifications, information about new features, version updates, releases, abuse warnings, and changes to this Privacy Policy. For the performance of a contract with you or to take steps at your request prior to entering into a contract under [GDPR Article 6-1(b)]
To support and improve our services: to improve and further develop our services so that we can provide a better user experience -, including data analytics. For the performance of a contract with you [GDPR Article 6-1b] or based on our legitimate interests [GDPR Article 6-1(f)]
When we process your personal data for our legitimate interests we always ensure that we consider and balance any potential impact on you and your rights under data protection laws.
To retain accounting related information:
to help us comply with legal and accounting requirements
For compliance with a legal obligation [GDPR Article 6-1(c)]
To facilitate corporate acquisitions, mergers, demergers: as is necessary in the context of corporate acquisitions, mergers, demergers, or other corporate transactions. Based on our legitimate interests [GDPR Article 6-1(f)]
To engage in direct marketing and sales related activities: based on your communication preferences, we may send you marketing communications (e.g. emails or mobile notifications) to inform you about our events or our partner events; to deliver targeted marketing; and to provide you with promotional offers. Based on our legitimate interests [GDPR Article 6-1(f)]
For any purpose that you provide your consent:we will not use your personal information for purposes other than those purposes we have disclosed to you, without your permission. For instance we may request your permission to allow us to share your personal information with third parties or to engage in third party marketing activities. Your consent [GDPR Article 6-1-(a)]In those situations, we process personal data on the terms as provided in the consent that has been granted to us by you.
Automatically collected technical data We use cookies on our website


2.3. Your personal information may be used to combine and anonymize data about you and your use of the service in order to create aggregate, anonymized statistics which we may use to provide certain features within the service and for promoting and improving the service in reliance on our legitimate interests. In cases where the customer and/or statistical data is anonymized we make sure that no personal data is included (which means that no person can be identifiable) and therefore personal data processing regulation and the GDPR shall not apply to such processing.

2.4. To the extent required by applicable data protection regulation, you have the right to object to the processing of your personal data which is based on legitimate interest. See also the section “your data protection rights” below. 

3.Who has access to your personal data


3.1. We only share your personal data when we have a valid reason for it and we take care to allow your personal information to be accessed only by those who require access to perform their tasks and duties, and to share only with third parties who have a legitimate purpose for accessing it. 

3.2. We only use service providers (data processors) that provide sufficient guarantees to implement appropriate technical and organizational security measures to protect your personal data. We have concluded appropriate data processing agreements with the service providers and shall remain responsible for their actions in respect of the processing of your personal data. Should you require more detailed information as regards the data processors we use (e.g., their names and location) please contact us via the contact details below.

3.3. We may transfer your personal data to third countries, i.e. countries outside the EU/EEA area, for the purposes explained in this Privacy Policy. When transferring personal data to third countries, we will ensure that the transfer is subject to appropriate safeguards under the GDPR and that your rights are protected, such as the Commission’s model contracts for the transfer of personal data to third countries (i.e., the standard contractual clauses). You may request a copy of the safeguards we have put in place with respect to the transfer of personal data by contacting us via contact details below.

3.4. We will never sell or rent your personal information to third parties without your explicit consent. We will only share your information in the following circumstances:

3.4.1. Identity and data verification service providers  in order to prevent fraud and other types of crime, and to comply with applicable laws and regulations. In doing so we are able to confirm your identity and data by comparing the information you provide us, or we collect, to public records and other third party databases. 

3.4.2. Financial institutions and payment service providers with which we partner to process payments you have authorized.

3.4.3. IT service providers and servers providing IT-solutions and other related services necessary for our daily business function.

3.4.4. Service providers under contract who help with parts of our business operations for example, but not limited to, data analytics, customer support, transaction monitoring, marketing, cloud storage. 

3.4.5. Advertising partners. We may cooperate with third party advertising platforms and social media channels to promote our services, both on our websites and third-party websites. To this effect, we may share limited personal information to achieve this purpose.  For example, we and our third-party advertising partners may use cookies, pixels and web beacons and similar technologies to gather information about your activities on the website and other websites to provide you with advertising based on your browser activities and interests. For further information, please see our Cookie Policy.

3.4.6. Professional advisors who provide banking, legal, compliance, insurance, accounting, or other consulting services in order to provide us advice or complete third party financial, technical, compliance and legal audits of our operations or otherwise comply with our legal obligations.

3.4.7. With companies or other entities that we plan to demerge or merge with or be acquired by. You will receive prior notice of any change in applicable policies.

3.4.8. Public institution(s). Any competent law enforcement body, regulatory body, government agency, court or other third party where we believe disclosure is necessary (a) as a matter of applicable law or regulation, (b) to exercise, establish, or defend our legal rights, or (c) to protect your vital interests or those of any other person.

4.How we protect and store your personal data


4.1. We take appropriate and reasonable technical and organizational measures designed to protect personal information from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the personal information. These measures include but are not limited to the implementation of appropriate computer security systems and safeguards such as firewalls and data encryption, enforcement of physical access controls to our buildings and files, and authorising access to personal information only for those employees who require it to fulfill their job responsibilities. If you have any questions about the security of your personal information, you may contact us at the contact details below.

4.2. However, we cannot guarantee that loss, misuse, unauthorized acquisition, or alteration of your data will not occur. Please recognize that you play a vital role in protecting your own personal information. When registering with our services, it is important to choose a password of sufficient length and complexity, to not reveal this password to any third-parties, and to immediately notify us if you become aware of any unauthorized access to or use of your account.

4.3. Furthermore, we cannot ensure or warrant the security or confidentiality of information you transmit to us or receive from us by Internet or wireless connection, including email, phone, or SMS, since we have no way of protecting that information once it leaves and until it reaches us. If you have reason to believe that your data is no longer secure, please contact us.

5. Your data protection rights


5.1. To the extent required by applicable data protection regulations, you have all the rights of a data subject as regards your personal data. Such rights include the following:

5.1.1. Access. You have the right to know which of your personal information we process.

5.1.2. Rectification. You may ask us to (and you are also obliged to) rectify any error in your personal data.

5.1.3. Erasure (the right to be forgotten). You may ask us to erase your personal information, which we will respect and comply with.

5.1.4. Restriction. You may ask us to restrict the processing of your personal information.

5.1.5. Object. You may object to the processing of your personal information.

5.1.6. Data portability. You may ask us to provide you or others with your personal information in a structured, commonly used and machine-readable format.

5.1.7. Lodge a complaint  to the data protection authority. You may lodge a complaint with your applicable data protection authority regarding our collection and use of your personal information. Contact details for data protection authorities within the EU and EEA are available here.

5.1.8. Right to withdraw your consent. If personal information is collected or processed on the basis of consent, or if you have, for example, consented to receiving marketing emails from Single.Earth, you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

5.2 Please note that the above rights may be subject to exceptions and limitations. We cannot, for example, provide personal data if it would violate our duty of confidentiality or if we have a legal obligation to retain such data. Also, certain information is necessary for us for providing the services to you and if we cannot use your information we may not be able to continue providing our services.

5.3 How to exercise your rights. You may correct and/or delete personal data linked to your account yourself, in the user settings on your account page. If you wish to exercise any of the other privacy rights that applies to you, you can do this by reaching out to us on support@single.earth. 

5.4 If we receive an email from you, we may ask you to verify your identity to comply with applicable law, and in order to help us respond efficiently to your request.

6.How long is your data stored

6.1 We store your personal information securely throughout the life of your account. We will only retain your personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting obligations or to resolve disputes.

6.2 Personal data obtained for the purposes of the fulfilment of obligations related to anti-money laundering and terrorist financing prevention, or data necessary for accounting purposes, shall be retained as required under applicable legislation and industry standards. Generally, respectively at least for 5 or 7 years since the date of the end of our business relationship, but not longer than 10 years.

6.3 Contact information such as your email address and telephone number for marketing purposes is retained on an ongoing basis until you unsubscribe. Thereafter we will add your details to our suppression list to ensure we do not inadvertently market to you.

6.4 Information collected via technical means such as cookies, webpage counters and other analytics tools is kept for a period of up to two years from expiry of the cookie.

7. Applying to open work position


7.1. In case you find an open position in Single.Earth on our website, you can apply to it directly. We use Teamtailor service for handling recruitments and simplifying the hiring process. More detailed overview of how we handle personal information of job applicants can be found by visiting our careers page at https://careers.single.earth/data-privacy

7.2 In order to apply for an open position we may ask the following information:

7.2.1. full name;

7.2.2. e-mail address;

7.2.3. phone number;

7.2.4. uploaded CV; 

7.2.5. cover letter;

7.2.6. uploaded additional files if you voluntary share with us.

7.3 We use this information to register your application, to consider your suitability for this position and to contact you for further information. This data is stored for 1 year period. In some cases we might need to store your data longer in order to consider you for future open positions, in that case we will store it for 2 years with your consent.

7.4 If you have any further questions about how we process job applicants information or would like to exercise any of your rights as a data subject, please contact us on our contact details below.


8.Questions and concerns


If you have any questions or comments, or if you have a concern about the way in which we have handled any privacy matter, you may contact us on support@single.earth, or by postal mail to: 

Single.Earth OÜ
Telliskivi 60/2 
Tallinn 10412 
Estonia