We welcome you to Clean Something For Nothing (“CSFN”), our website at www.cleansomethingfornothing.com and/or our iOS and Android Mobile application (collectively our “Platform”). In the below Privacy Policy, we inform you about the scope of the processing of your Personal Data. CSFN proceeds with all data processing procedures (e.g., collection, processing, and transmission) in accordance with the EU`s General Data Protection Regulation (“GDPR”).

Responsible for data processing

Responsible for data processing in accordance with the provisions of the GDPR is:

Clean Something For Nothing

Luxembourg

Web: www.cleansomethingfornothing.com

E-Mail: info@cleansomethingfornothing.com

 

General information on data processing

In the course of our platform operations, we process data. All Personal Data that we obtain from you via the platform will only be processed for the purposes described in more detail below. This is done only if:

  1. you have given your consent,
  2. the data is necessary for the fulfillment of a contract / pre-contractual measures,
  3. the data is necessary for the fulfillment of a legal obligation or
  4. the data is necessary to protect the legitimate interests of our company, provided that your interests are not overridden.

CSFN processes and stores your Personal Data only for the period of time required to achieve the respective processing purpose or for as long as a legal retention period exists. Once the purpose has been achieved or the retention period has expired, the corresponding data is routinely deleted.

 

Processing of Automatically Collected Data

  1. a) Hosting

To provide our Platform, we use a web hosting service, who process the data mentioned below and all other data that is processed in connection with the operation of our Platform on our behalf. Our Platform is hosted using the services of Heroku a Salesforce Inc. Company. The legal basis for the data processing is our legitimate interest in providing our platform and services.

 

  1. b) Collection of access data and log files

We also collect data on every access to our website. The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.

Log file information is stored for security reasons (e.g., for the clarification of abuse or fraud) for a maximum of 7 days and then deleted. Data whose further storage is necessary for evidentiary purposes is exempt from deletion until the respective incident is finally clarified. The legal basis for the data processing is our legitimate interest in providing an appealing website.

 

  1. c) Use of cookies

We use so-called cookies on our website. Cookies are small files that are stored by most Internet browsers to obtain information about visitors so that we can make the web experience more appealing to you. During your visit to our website, we use four types of cookies.

i) How do we use them?

We use cookies to:

  • obtain information about your browser settings, domain name, Internet service provider, operating system, date and time of access, location and type of device you use to access our website and to perform system administration.
  • obtain information about other websites you have visited or the types of searches you have performed in order to improve your experience.
  • prevent fraudulent activity and improve security.
  • identify and analyze your browsing preferences and the products you are interested in.
  • associate your past website behavior after you have registered with your information on our website for business and technical purposes.

Some of the cookies used on our websites are set by us, others are set by third parties on our behalf.

 

  1. ii) What types of cookies do we use?
  • Essential cookies: these cookies are necessary for us to provide you with the basic functionality of our website and cannot be turned off in our systems.
  • Performance and analytics cookies: these cookies allow us to track visits and traffic sources to measure and improve the performance of our website. 
  • Functional cookies: these cookies are used to provide enhanced functionality and personalization during your visit. 
  • Targeting or advertising cookies: these cookies may be set through our website by our advertising partners to profile your interests and suggest relevant advertising to you. 

 

iii) The Cookies we use

According to the Privacy and Electronic Communications Directive (“PECD”) and the GDPR, the use of functional, analysis and performance or advertising cookies require your consent and thus the legal basis for the use of personal data in relation to cookies, the use of cookies would then be your consent as well as our legitimate interest.

Below you can find the cookies we use listed in accordance with their Name, Description, Lifespan, and Type. Please keep in mind that this list may be updated from time to time.

  • _ga
    • The _ga cookie, installed by Google Analytics, calculates visitor, session and campaign data and also keeps track of site usage for the site’s analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognize unique visitors.
    • 2 years
    • Analytics
  • _gid
    • Installed by Google Analytics, _gid cookie stores information on how visitors use a website, while also creating an analytics report of the website’s performance. Some of the data that are collected include the number of visitors, their source, and the pages they visit anonymously.
    • 1 day
    • Analytics
  • _gat_gtag_UA_189731508_1
    • Set by Google to distinguish users.
    • 1 minute
    • Analytics

 

  1. iv) Google Analytics

We use Google Analytics, a web analytics service provided by Google LLC of 1600 Amphitheatre Pkwy, Mountain View, CA 94043, USA and Google Ireland Ltd of Gordon House, Barrow Street, Dublin 4, Ireland, on our website.

Google Analytics also uses cookies to enable our website to analyze how users use our website across multiple devices. The information generated by the cookies about your use of our website is transmitted to and stored by Google, including transmission to the United States. The following data is processed through the use of Google Analytics:

  • 3 bytes of the IP address of the called system of the website visitor (anonymized IP address),
  • the website called up,
  • the website from which the user reached the accessed page of my website (referrer),
  • the subpages accessed from the website,
  • the time spent on the website
  • the frequency with which the website is accessed.

 

Google states that it will not associate your IP address with any other data held by Google.

You can disable tracking by Google Analytics with future effect by downloading and installing the Google Analytics Opt-out Browser Add-on for your current web browser following this link http://tools.google.com/dlpage/gaoptout?hl=en.

 

  1. v) How can I manage cookies?

Each type of cookie serves a specific purpose; when you first visit our website you will be asked about the use of cookies, and you can easily agree or decline. Accepting all cookies allows you to fully personalize your web experience. You can choose which types of cookies to accept or block, but this may affect your experience with our website and the services we offer. Nevertheless, you will be able to use the Service even if you refuse to consent to some cookies, except for those that are strictly necessary.

If you are not interested in the benefits that our cookies offer, you can find instructions on how to refuse cookies and delete existing cookies through the “Help” function of your browser. Google Chrome, Mozilla Firefox, Flash cookies, Microsoft Internet Explorer/ Edge, Opera, Safari. You will also learn how to block all new cookies in your browser and what configuration steps are required to receive notification of new cookies.

Very helpful information about cookies in general can be found on these websites: www.allaboutcookies.org or www.cookiepedia.co.uk.

 

Data processing when you submit it to our website and when you use our services

 

  1. a) Downloading the APP

The APP can be downloaded from the “Google Playstore” a service offered by Google Inc, 1600 Amphitheatre Parkway Mountain View, CA 94043, US, if you are resident outside the EU and Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland if you are a resident within the EU, or the Apple App service “App Store” a service of Apple Inc., 1 Infinite Loop, Cupertino, CA 95014, US, if you are resident outside the EU and Apple Distribution International Ltd, Hollyhill Industrial Estate, Hollyhill Ln, Knocknaheeney, Cork, Ireland, if you are a resident within the EU, to install our APP. Downloading it may require prior registration with the respective App store and/or installation of the respective App store software.

 

  1. b) Installing the APP

As far as we are aware, Google collects and processes the following data: License check, network access, network connection, WLAN connections, and location information. However, it cannot be ruled out that Google also transmits the information to a server in a third country. We cannot influence which Personal Data Google processes with your registration and the provision of downloads in the respective App store and App store software. The responsible party in this respect is solely Google as the operator of the Google Play Store.

As far as we are aware, Apple collects and processes the following data: device identifiers, IP addresses, location information, it cannot be excluded that Apple also transmits the information to a server in a third country. This could in particular be Apple Inc. One Apple Park Way, Cupertino, California, USA, 95014. We cannot influence which Personal Data Apple processes with your registration and the provision of downloads in the respective app store and app store software. The responsible party in this respect is solely Apple as the operator of the Apple App Store.

 

  1. c) Device information

Google and Apple may collect information from and about the device(s) you use to access the APP, including hardware and software information such as IP address, device ID and type, device-specific and APP settings and properties, APP crashes, advertising IDs (AAID), information about your wireless and mobile network connection such as your service provider and signal strength; information about device sensors such as accelerometer, gyroscope, and compass.

 

  1. d) Firebase

We use the Google Firebase developer platform and related features and services provided by Google LLC and Google Ireland Limited for push notifications only. Google Firebase is a platform for developers of apps for mobile devices. The Google Firebase developer platform offers a variety of features. A list of these features can be found at: https://firebase.google.com/terms/. Firebase’s key security and privacy information can be found here: https://firebase.google.com/support/privacy

 

Data processing when you use our services

  1. a) Contacting us

If you contact us, we process the following data from you for the purpose of processing and handling your request: first name, last name, e-mail address, and, if applicable, other information if you have provided it, and your message. The legal basis for the data processing is our obligation to fulfill the contract and/or to fulfill our pre-contractual obligations (Art. 6 para. 1 lit. b GDPR) and/or our overriding legitimate interest in processing your request (Art. 6 para. 1 lit. f GDPR).

 

  1. b) Profile and account

If you create a user account, you will receive a unique ID from us and you are only required to provide a username. This allows us to identify you as a user and gives you the opportunity to manage your account, use our services and manage your purchases. Within your profile you are able to delete your account at any time. Your data will be processed on the basis of your consent (Art. 6 para. 1 lit. a GDPR).

 

  1. c) When using our services

We process the data of our registered users in order to be able to provide our services including user groups as well as to ensure the security of our services and to be able to develop it further. The required information is identified as such in the context of the information required for the provision of services.

Of course, in the course of operating the Services, we also process your chats with other users and the content you transmit.

Some of the Personal Data you provide may be considered “special” or “sensitive”. This includes Personal Data concerning for example your health, racial or ethnic origins, sexual orientation, and religious beliefs. By choosing to provide this data, you consent to our processing of that data.

You have choices about the Personal Data you upload and share. You don’t have to provide Personal Data; however, Personal Data helps you to get more from our Services. It’s your choice whether to include special category data and to make that special category data public. Please do not upload or add data that you would not want to be available.

The legal basis for the processing of your personal and special category data is the establishment and implementation of the user contract for the use of the service as well as your consent. We store the data until you delete your user account. Insofar as legal retention periods are to be observed, storage also takes place beyond the time of deletion of a user account.

You may withdraw your consent and request us to stop using and/or disclosing your personal and special category data by submitting your request to us in writing to info@cleansomethingfornothing.com.

The legal basis for the data processing is the fulfillment of our contractual obligations (Art. 6 para. 1 lit. b GDPR) and, in individual cases, the fulfillment of our legal obligations (Art. 6 para. 1 lit. c GDPR) as well as your Consent (Art. 6 para. 1 lit. a GDPR).

 

  1. d) Donations

We store and process information that you give us as part of a donation primarily for the purpose of carrying out the collection of donations that you have instructed us to do. Your donation will be processed through the payment service providers PayPal as described below and the payment data will not be passed on to any other third parties. The data collected is required for carrying out the donation. The user’s e-mail address is required to confirm receipt of the donation. The data will not be used for any other purpose.

 

If you make a donation your payment will be processed via the payment service provider PayPal and your Personal Data will be processed through the payment system of PayPal. As such PayPal transmits the following Personal Data to PayPal S.á.r.l. & Cie, S.C.A. in order to process your donation: Total amount of the donation, Reference on the PayPal account, your e-mail address of the PayPal account, Encrypted PayPal account number. The legal basis for the processing of your Personal Data is contract (Art. 6 para. 1 lit. b. GDPR).

 

  1. e) Newsletter

If you have consented to receive our newsletter, we will use your e-mail address and, if applicable, your name to send you information about products, promotions, competitions, and news. You can revoke your consent to receive the newsletter at any time with effect for the future by contacting us at info@cleansomethingfornothing.com. You will also find the unsubscribe link at the end of each newsletter. The revocation leads to the deletion of the collected user data. The legal basis for the processing of your Personal Data is contract (Art. 6 para. 1 lit. b. GDPR).

 

Duration of data storage

We only store Personal Data for as long as it is necessary for the purposes for which it is processed or for as long as any consent you have given us has been revoked by you. Insofar as statutory retention obligations must be observed, the storage period for certain data may be up to 10 years, irrespective of the processing purposes.

 

Obligation to provide Personal Data

You are not obliged to provide us with Personal Data. However, depending on the individual case as described above, the provision of certain Personal Data may be necessary for the provision of the services. If you do not provide us with this Personal Data, we may not be able to provide the requested service.

Do Not Sell

We do not sell data to third parties.

 

Authorizations and Access

We may request permission to store your APP data including your Internet Connection and Network access, Location, Camera, Photos and Gallery of your device. The legal basis for data processing is our legitimate interest and the provision of contractual or pre-contractual measures. You can deny access on your device via the Settings/Notifications/ options of your device; however, this means that our APP may not function as intended.

 

Push messages

When you use the app, you will receive so-called push messages from us, even if you are not currently using the App. These are messages that we send you as part of the performance of the contract. You can adjust or stop receiving push messages at any time via the device settings of your device.

 

Transfer of Personal Data

We will not disclose or otherwise distribute your Personal Data to third parties unless this:

  • is necessary for the performance of our services,
  • you have consented to the disclosure,
  • or the disclosure of data is permitted by relevant legal provisions.

 

However, we are entitled to outsource the processing of your Personal Data in whole or in part to external service providers acting as processors within the framework of the GDPR. External service providers support us, for example, in the technical operation and support of the platform, data management, the provision and performance of services, marketing, as well as the implementation and fulfillment of reporting obligations.

The service providers commissioned by us however will process your data exclusively in accordance with our instructions and we remain in accordance with the GDPR responsible for the protection of your data. Doing so we always make sure that service providers commissioned by us are carefully selected, follow strict contractual regulations, technical and organizational measures, and additional controls by us.

We may also disclose Personal Data to third parties if we are legally obliged to do so e.g., by court order or if this is necessary to support criminal or legal investigations or other legal investigations or proceedings at home or abroad or to fulfill our legitimate interests.

 

Sharing and Disclosure of cleanup posts

We may share in an effort to get our objective across a broader audience, some general information with the Earth Day Network. This information is very specific, does not include Personal Data and usually consists of the GPS location of the cleanup post, the quantity of trash collected in volume and weight and the date of the clean-up. An example of this might be “A cleanup was made in this location [GPS coordinates] resulting in 20 liters and 2 kg of trash collected on [Date] at Clean Something For Nothing”. In the very unlikely event that we may need to share Personal Data related to cleanup post, we will always make sure that the relevant data subjects are properly informed and that the necessary consents are obtained.

 

Automated decision-making

Automated decision-making including profiling pursuant to Art. 22 (1) and (4) GDPR does not take place at CSFN.

 

Your data subject rights

Every data subject has:

  • the right to information according to Art. 15 GDPR,
  • the right to rectification according to Art. 16 GDPR,
  • the right to deletion according to Art. 17 GDPR,
  • the right to restriction of processing pursuant to Art. 18 GDPR, and
  • the right to data portability under Art. 20 GDPR.

 

Further, you can revoke consent, in principle with effect for the future.

Furthermore, you have the right to lodge a complaint with a data protection supervisory authority (Art. 77 GDPR). We would, however, appreciate the chance to deal with your concerns before you approach a data protection supervisory authority.

Finally, you also have a right to object according to Art. 21 GDPR. This applies, on grounds relating to data processing on the basis of my legitimate interest and also to profiling.

If you object, we will no longer process your Personal Data unless we can demonstrate compelling legitimate reasons for the processing which override your interests, rights and freedoms, or the processing serves to assert, exercise, or defend legal claims.

Please contact us at any time with questions and suggestions regarding data protection and to enforce your rights as a data subject.

 

Security

State-of-the-art internet technologies are used to ensure the security of your data. During the online enquiry process, your details are secured with encryption. For secure storage of your data, the systems are protected by firewalls that prevent unauthorized access from outside. In addition, technical and organizational security measures are used to protect the Personal Data you have provided against accidental or intentional manipulation, loss, destruction, or access by unauthorized persons.

 

Updating your information

If you believe that the information, we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us using info@cleansomethingfornothing.com.

 

Access Request

In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same using info@cleansomethingfornothing.com.

 

We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the respective legal regulations mentioned above).

 

Withdraw your consent

You may withdraw your consent and request us to stop using and/or disclosing your Personal Data for any or all purposes by submitting your request to us using info@cleansomethingfornothing.com. Please note that your withdrawal of consent will not prevent us from exercising our legal rights (including any remedies) or undertaking any steps as we may be entitled to at law.

 

Changes and updates

We kindly ask you to regularly inform yourself about the content of our Privacy Policy. We will amend our Privacy Policy as soon as changes to the information processing activities we carry out make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g., consent) or other individual notification. This Privacy Policy was last updated on Saturday, 21 January 2023.

 

Concerns and Contact

If you have any concerns about a possible compromise of your privacy or misuse of your personal information on our part, or any other questions or comments, you can contact us using info@cleansomethingfornothing.com.