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Privacy Policy

 

CUSP Green Solutions Limited (“CUSP“, “we“, “our“, or “us“) is committed to protecting and respecting your privacy.

 

  1. OUR APPROACH TO PRIVACY

This privacy policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you (“personal information“) when you use our website at [Link] (the “Website“), or otherwise interact with us.

 

  1. ABOUT US

CUSP Green Solutions Limited (company no. 13579526) is the data controller of the personal information we hold about you.

Our registered and postal address is C/O Bcs Windsor House, Station Court, Station Road, Great Shelford, Cambridge, England, CB22 5NE.

 

PERSONAL INFORMATION WE COLLECT ABOUT YOU AND HOW WE USE IT

The table at Annex 1 sets out the categories of personal information we collect about you and how we use that information. The table also lists the legal basis which we rely on to process the personal information.

More generally, we:

 

  • collect personal information that you voluntarily submit to us, such as your name and contact details, when you register with us, use our Website and our services, or otherwise interact with us in the course of our business activities;

 

  • collect personal information that you are required to provide us as part of our client onboarding procedures, such as your passport number, driving licence number, vehicle registration number, vehicle make and model, cryptocurrency wallet address;

 

  • collect personal information about you from third parties, such as dealers and/or sellers of your existing electric vehicle, dealers and sellers of electric vehicles and other products and/or services that may be advertised as being available for off-site purchase on our Website, vehicle licencing agencies, background checking service providers, social networks, public databases (where permitted by law), our advertising partners and our other partners where we carry out joint business activities; and

 

  • may also collect certain personal information automatically, including in relation to how you access and use the Website, technical information regarding the device you use to access the Website and the way in which you interact with our newsletters (such as whether you open these). We also automatically record telephone calls when you contact our customer services team by phone.

 

We use the information we collect about you to correspond with you, perform our agreements with you, comply with our regulatory responsibilities (such as Know Your Client and anti-money laundering requirements), carry out marketing activities and our day-to-day business activities and operations.

We may link or combine the personal information we collect about you and the information we collect automatically. This allows us to provide you with a personalised experience regardless of how you interact with us.

We will indicate to you where the provision of certain personal information is required in order for us to provide you certain services. If you choose not to provide such personal information, we may not be able to provide the services you have requested.

 

  1. ANONYMOUS DATA

We may anonymise and aggregate any of the personal information we collect about you (so that it does not directly identify you). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving our Website and developing new products and features. We may also share such anonymised information with others.

 

  1. DATA RETENTION

We will store the personal information we collect about you for no longer than necessary for the purposes set out in Annex 1 in accordance with our legal obligations and legitimate business interests.

To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, as well as the applicable legal, regulatory, tax, accounting or other requirements.

 

  1. RECIPIENTS OF PERSONAL INFORMATION

We may share your personal information with the following categories of recipients (as required in accordance with the uses set out in Annex 1):

 

  • Service providers: we may share your personal information with third party vendors and other service providers that perform services for us or on our behalf, which may include providing mailing, advertising, fraud prevention, web hosting, payment gateway or analytics services.

 

  • Professional advisors: we may share your personal information with our lawyers, accountants, insurers and other professional advisors to the extent we need to (for example, to defend ourselves against legal claims).

 

  • Business partners: we may share your personal information (such as contact details) with our business partners (including but not limited to dealers and sellers of electric vehicles and other products and/or services that may be advertised as being available for off-site purchase on our Website and certain vehicle licencing agencies), where this is necessary in the normal course of our business.

 

  • Purchasers and third parties in connection with a business transaction: your personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business.

 

  • Law enforcement, regulators and other parties for legal reasons: we may share your personal information with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements; and/or (iii) exercise or protect the rights, property, or personal safety of CUSP, its users or others.

 

  • Other members of the CUSP group: we may share your personal information with our affiliates (for example, where they provide services on our behalf) or where such sharing is otherwise necessary in accordance with the uses set out in Annex 1.

 

  1. MARKETING AND ADVERTISING

From time to time we may contact you with information about our products and services, including sending you marketing messages and asking for your feedback on our products and services.

 

Most marketing messages we send will be by email notifications. For some marketing messages, we may use personal information we collect about you to help us determine the most relevant marketing information to share with you.

 

We will only send you marketing messages if you have given us your consent to do so. You can withdraw your consent or opt out of receiving further communications at a later date by clicking on the unsubscribe link at the bottom of our marketing emails.

 

We undertake marketing activities using personal information we receive about you from dealers and/or sellers of your existing electric vehicle. To do this, we may collect information about you and your existing electric vehicle from such dealers and/or sellers and contact you to inform you about the estimated number of tokens you may be entitled to collect (in accordance with our Website Terms and Conditions) as the current owner of your electric vehicle.

 

We also participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your online browsing history and your interests. To do this, we or our advertising partners may collect information about how you use or connect to the Website, or the types of other websites, social media services, content and ads that you (or others using your device) visit or view or connect to our Website so that we or our advertising partners may play or display ads on the Website, on other websites, apps or services you may use, and on other devices you may use.

 

To learn about interest-based advertising and how you may be able to opt-out of some of this advertising and to limit some third party advertising cookies, you may wish to visit:

 

  • Your Online Choices (http://www.youronlinechoices.com/)
  • Network Advertising Initiative (http://www.networkadvertising.org/)
  • Digital Advertising Alliance (http://www.aboutads.info/consumers)

 

  1. STORING AND TRANSFERRING YOUR PERSONAL INFORMATION

 

Security. We implement appropriate technical and organisational measures, including encryption, to protect your personal information against accidental or unlawful destruction, loss, change or damage. All personal information we collect will be stored on our secure servers. We will never send you unsolicited emails or contact you by phone requesting your account ID, password, bank account details, national identification numbers, wallet private key, wallet recover seed phrase or any other passwords associated with your cryptocurrency wallet.

International Transfers of your Personal Information. The personal information we collect may be transferred to and stored in countries outside of the UK where our third party service providers have operations. These international transfers of your personal information will be made pursuant to appropriate safeguards, such as standard data protection clauses adopted by the UK government. If you wish to enquire further about the safeguards used, please contact us using the details set out at the end of this privacy policy.

 

  1. YOUR RIGHTS IN RESPECT OF YOUR PERSONAL INFORMATION

In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:

  • Right of access. You have the right to obtain access to your personal information.
  • Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.
  • Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.
  • Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.
  • Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.
  • Right to object. You have a right to object to any processing based on our legitimate interests in certain circumstances. You can also object to our direct marketing activities for any reason by clicking the “unsubscribe” link set out in any marketing communication you receive.
  • Right to withdraw consent. If you have provided consent to any processing of your personal information, you have a right to withdraw that consent.

 

Please note that the above rights are not absolute and we may be entitled to refuse requests, wholly or partly, where exceptions under the applicable law apply.

 

If you wish to exercise one of these rights, please contact us using the contact details at the end of this privacy policy. You may also review and edit some of the personal information you have submitted to us by logging into your account on the Website.

 

You also have the right to lodge a complaint to your national data protection authority. If you are in the UK, information on how to contact the Information Commissioner is available at www.ico.org.uk.  

 

  1. AUTOMATED DECISION-MAKING

We sometimes use algorithms to make decisions on our behalf. This is referred to as automated decision-making. We use automated decision-making for the following purposes:

 

  • To assess your application for an account. Our algorithms assess your suitability for an account with us based on [information]. This means that we may automatically decide that you present a fraud or money-laundering risk or pose a risk to us in terms of breaking financial sanctions, in which case we will reject your application for an account.

 

  • To decide whether we need to help you. [If our algorithms detect that you may have become financially vulnerable, we may have a regulatory obligation to help you. Such decisions are based on [information].

 

  • To detect and prevent fraud. [Our algorithms may freeze a transaction or account if we suspect fraud or money-laundering against CUSP or our customers. Such decisions are based on patterns in our data].

 

You can ask for a member of the team to review an automated decision using the contact details set out in section 15 below. If your application for a CUSP account was rejected, you can ask us to check this decision by emailing contact@cusp.earth.

 

  1. COOKIES AND SIMILAR TECHNOLOGIES

Our Website uses cookies and similar technologies to distinguish you from other users of our Website. Please refer to our Cookies Policy [hyperlink] for more information as to the way in which we use cookies on our Website.

 

  1. LINKS TO THIRD PARTY SITES

Our Website may, from time to time, contain links to and from third party websites, including those of our business partners, advertisers, news publications and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.

 

  1. CHANGES TO THIS POLICY

We may update this privacy policy from time to time and so you should review this page periodically. When we change this privacy policy in a material way, we will update the “last modified” date at the end of this privacy policy. Changes to this privacy policy are effective when they are posted on this page.

 

  1. NOTICE TO YOU

If we need to provide you with information about something, whether for legal, marketing or other business related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on our Website. The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this privacy policy.

 

  1. CONTACTING US

If you have any questions, comments and requests regarding this Privacy Policy, you can contact us:

 

By post:

C/O Bcs Windsor House

Station Court

Station Road

Great Shelford

Cambridge

England

CB22 5NE

 

By email:  contact@cusp.earth

This privacy policy was last modified on the 07 March 2022

 

ANNEX 1 – PERSONAL INFORMATION WE COLLECT

 

Category of personal data

Purpose of Processing

 

Lawful basis for processing

Contact details (including name and phone number) and account preferences (including marketing and notification preferences)

To send you marketing and promotional content (if you have opted in to receiving these).

 

Consent.

To send you information regarding changes to our policies, other terms and other administrative information such as reminders, technical notices, updates and security alerts.

It is in our legitimate interests to ensure that any changes to our policies, terms and other such technical updates are communicated to you.

Contact details (including salutation, name, email address, location, phone number), ID information (including residency and date of birth, passport or national ID, Driver’s Licence)

 

To create your account on the Website, to assess your eligibility to register with us based on our internal rules, and where necessary, share this with other financial institutions to comply with relevant laws.

It is in our legitimate interests that we create your account on the Website and assess the suitability of individuals to register with us to ensure that we can make the features of the Website available to such individuals and to protect us against the risk of individuals failing to repay us or our business partners (as relevant).

Contact details (including name, phone number, and email address)

To send your query regarding an electric vehicle or other products or services that may be advertised as being available for off-site purchase on our Website, to the relevant dealer or seller.

It is in our legitimate interests to forward to your queries and provide any information and materials requested in order to generate and develop business.

Contact details (including name, email address and address)

To provide you with information and materials that you request from us.

 

It is in our legitimate interests to respond to your queries and provide any information and materials requested in order to generate and develop business.

Contact details including ID information (including residency and date of birth, passport or national ID, driver’s Licence), vehicle information (including registration number, make & model, engine number 1st registration date, vehicle buyer’s email)

 

Calculate the tokens the owner of an electric vehicle may be entitled to collect (as detailed in our Website Terms and Conditions), and to ensure that the correct individual is entitled to collect such tokens as the owner of such electric vehicle

by matching the information provided with information available from the relevant vehicle licencing agency.

 

Performance of a contract.

 To send the individuals attempting to collect tokens, a one-time password to verify that the correct individual (who is entitled to collect the tokens as detailed in our Website Terms and Conditions) is transferring the tokens into their Cryptocurrency wallet.

Performance of a contract.

 

 

Contact details (including name and post code), Cryptocurrency wallet information (including wallet address)

In order for you to be collect tokens (as detailed in our Website Terms and Conditions).

Performance of a contract.

Technical information (including IP address, browser type, internet service provider, device identifier, your login information, time zone setting, browser plug-in types and versions, preferred language, activities, operating system and platform, and geographical location) and  

usage data (including clickstream to, through and from the Website, pages you viewed and searched for, page response times, length of visits to certain pages, referral source/exit pages, page interaction information (such as scrolling, clicks and mouse-overs), date and time pages are accessed, and website navigation and search terms used)

To administer the Website including resolving technical issues, troubleshooting, data analysis, testing, research, statistical and survey purposes.

Consent (to the extent required under applicable laws).

To improve the Website to ensure that content is presented in the most effective manner for you and your computer, mobile device or other item of hardware through which you access the Website.

 

To help create and maintain a trusted and safe environment on the Website.

 

To ensure that you are provided with marketing and advertising that is in line with your preferences.

Where consent is not required, such processing will be carried out on the basis of our legitimate interests to improve our services, provide a safe and secure environment for our customers, resolve issues for customers and develop and grow our brand.

ID information (including age), lifestyle preferences

To create lookalike audiences on social media platforms to better target our marketing.

It is in our legitimate interests to market our services in a targeted manner.

Contact details (including name and phone number), telephone recordings

To record your calls with our customer services team to comply with applicable laws.

Compliance with a legal obligation.