Privacy Policy

1. Who We Are

The operating entity is GreenSweep Pte. Ltd., a private limited company registered in Singapore (UEN 202619802N). All data described in this policy is collected and processed by GreenSweep Pte. Ltd.

A Malta Purpose Foundationis in formation under Chapter 16, Second Schedule to the Civil Code (Cap. 16) of the Laws of Malta and is intended to become the steward of the mission described on /commitment. This policy will be updated with the Foundation’s registration number and registered address once incorporation completes; until then, processing remains with the Pte. Ltd.

Data Protection Officer: Hiram Powers-Heaven — [email protected]

2. Data We Collect

At registration: Email, username, country (optional)

During use: Voting history, engagement metrics, technical data (browser type, anonymised IP after 30 days)

What we don't collect: Payment info, precise location (no GPS, no street-level), browsing history outside GreenSweep, sensitive data

WhatsApp / messaging users: If you register or vote via our WhatsApp channel (powered by ManyChat), we receive and store a one-way hashed identifier derived from your phone number. The raw phone number is never stored in our database.

2.1 Geographic Data Derived from Your IP Address

When you visit GreenSweep, our hosting provider (Vercel) resolves your IP address to an approximate geographic location and passes a country code to our servers in the request headers. We use this country code, and in one narrow case the approximate city/region, for the following purposes:

• Sanctions enforcement. Visitors from comprehensively sanctioned jurisdictions (Cuba, Iran, North Korea, Syria, Russia, Belarus) are refused at the edge with a notice page. Legal basis: legal obligation (OFAC, EU restrictive measures).
• Cookie consent banner. The banner is surfaced only to visitors from jurisdictions that legally require it — the 33 GDPR-equivalent territories and Nigeria. Country resolution determines whether you see the banner. Legal basis: legal obligation (GDPR / NDPR / equivalent).
• Locale defaults. On your first visit, your country is used to seed a default language and content locale, which are written to the gs-locale cookie. You can override this manually at any time via the locale switcher. Legal basis: legitimate interest (UX).
• Homepage personalisation. The hero slot rotation and DACH-evening copy are selected based on your country to show market-relevant content. Legal basis: legitimate interest.
• Per-market feature availability. Some features (such as the optional donation surface) are enabled or disabled by market based on regulatory or product-availability rules. Legal basis: legitimate interest.
• Audience-corridor analytics. Country is recorded as the ip_country property on internal event records and analytics events to measure diaspora-corridor engagement. In jurisdictions where consent is required, these events do not fire until you accept analytics cookies. Legal basis: legitimate interest, consent-gated where applicable.
• Project sorting (city/region). The approximate city/region is used in real time on our servers to sort environmental projects by proximity. This narrower precision is processed ephemerally: it is never written to any database, cookie, log file, or persistent record, and is discarded from server memory when the page finishes rendering. Legal basis: legitimate interest.

What we do not do with your IP address: We do not derive precise (street-level) location, do not combine geo-IP-derived data with your personal identifiers in any stored record without separate consent, do not share city/region with any third party, and do not sell any geographic data. Raw IP is processed for security and rate-limiting under separate technical and organisational controls; that processing is covered by Section 10 (Data Retention).

Right to object. For the legitimate-interest purposes above, you can object at any time under GDPR Article 21. The locale switcher in the page footer overrides geo-IP-derived locale defaults; the cookie consent controls (Section 11) stop analytics emission of ip_country. We have documented our balancing test for these purposes in a Legitimate Interest Assessment, available on request to [email protected].

3. How We Use It

• Enable account login and voting
• Display community leaderboards
• Detect fraud and maintain security
• Improve the platform
• Send service emails (resets, account changes)

4. Advertising Partnerships

We share anonymised, aggregated engagement data with select advertising networks to generate revenue directed to environmental projects. This data: Does not include email/username · Is aggregated across users · Used only for billing verification · Transferred under SCCs.

You can disable this in account settings—you can still vote and use GreenSweep freely.

5. Tier 2 Data Sharing — What Happens When You Opt In

When you toggle "Amplify my impact" in your account settings, you consent to share the following anonymised data fields with our environmental research partners and advertising networks:

• Environmental interest category (e.g. reforestation, ocean cleanup)
• Age range (not date of birth)
• Household size
• Market / country

We never share: your email address, your name, your voting history on specific projects, or any data that could identify you personally.

Purpose: This data helps our partners understand the demographics of environmentally engaged communities. Revenue generated from these partnerships is directed to environmental projects through our 70% allocation commitment. Sharing this data increases your vote weight to 2×, meaning your project preferences carry more influence in funding allocation.

Legal basis: Your explicit, informed consent (GDPR Art. 6(1)(a)). You can withdraw consent at any time in account settings. Withdrawal does not affect the lawfulness of processing before withdrawal.

Recipients: Environmental research partners and advertising networks with whom we have Data Processing Agreements. Data is transferred under Standard Contractual Clauses where recipients are outside the EEA.

6. Optional Visibility & Notification Features (Tier 3 Consent)

We offer six optional features that let you choose how your name, photo, and activity appear to other users. Each is separately toggled, separately consented to, and separately revocable. None is on by default. You can manage all of them at any time in Profile → Privacy & Visibility.

Legal basis for all six: your explicit, freely given consent under GDPR Art. 6(1)(a) and, where applicable, Art. 9(2)(a). Each consent is recorded with the exact text you agreed to and a timestamp (GDPR Art. 7(2) audit log). You can withdraw any consent at any time; withdrawal does not affect the lawfulness of processing before withdrawal (GDPR Art. 7(3)).

7. Legal Basis

We process personal data under the following GDPR Article 6 lawful bases, summarised by the type of processing:

• Your consent (Article 6(1)(a)): registration, voting, optional Tier 2 data sharing, optional Tier 3 visibility features, analytics cookies in regulated jurisdictions.
• Contract (Article 6(1)(b)): operating your account and delivering the platform service.
• Legitimate interest (Article 6(1)(f)): security and fraud prevention; analytics outside regulated markets; geo-IP-derived locale defaults, homepage personalisation, per-market feature availability, audience-corridor analytics, and project sorting (see Section 2.1). Our balancing test for the geo-IP purposes is documented in a Legitimate Interest Assessment, producible on request to [email protected].
• Legal obligation (Article 6(1)(c)): sanctions-jurisdiction edge blocking; surfacing the cookie consent banner where law requires; tax and regulatory reporting.

8. Who We Share With

• Supabase (database, EU)
• Vercel (hosting, GDPR-compliant) — derives approximate country and, in narrow flows, city/region from your IP address as part of standard edge-network routing. Country is exposed to GreenSweep in HTTP headers and used as described in Section 2.1; city/region is processed ephemerally for project sorting and never stored.
• Cloudflare (DNS, WAF, Access SSO, Turnstile)
• Upstash Redis (rate limiting + queues, EU)
• Advertising networks (anonymised data only — see Sections 4 and 5; CPA partners receive country-of-residence at most, never city or postcode)
• Google Analytics 4 (IP anonymised, consent-gated)
• PostHog (product analytics, EU, consent-gated) — receives country-level ip_country as an event property where required for cohort analysis. Never receives raw IP, city, or region.
• ManyChat (WhatsApp channel operator — receives hashed phone identifier only; no raw PII transmitted; DPA in place)
• Resend (transactional email)

All have Data Processing Agreements. No EEA transfers without SCCs.

Full subprocessor list: See our Subprocessors page for the canonical list with data location, categories of data, transfer mechanism, and DPA status per Article 13(1)(e) GDPR. We notify users of material additions or substitutions via that page and via a privacy policy version bump.

Community leaderboard: If you opt in to the referral leaderboard (optional, off by default), your display name (first name and last initial) and referral count are shown publicly on the platform. You can withdraw this consent and remove your entry at any time in account settings.

9. Your Rights

You can: Access, correct, delete, restrict, port, object to, or withdraw consent from your data anytime.

Contact [email protected]. We respond within 30 days.

10. Data Retention

Active accounts: Your data is retained for as long as your account is active, plus 12 months after account deletion to allow for reactivation.

IP addresses: Anonymised after 30 days. A one-way cryptographic hash of your registration IP is retained separately for fraud prevention and regulatory compliance; it cannot be reversed to recover the original IP address.

Anonymised compliance records: When you opt in to data sharing (Section 5), we create a separate, anonymised record of your consent containing only cryptographic hashes (not your actual email or identity). This record is retained for up to three years as required by our commercial partnership agreements and applicable regulatory obligations. It cannot be used to identify you without access to the original data, which is deleted per the standard retention schedule above.

Aggregated data: Anonymised, aggregated analytics data is retained indefinitely and cannot be linked to individual users.

11. Cookies & Analytics

Strictly necessary cookies support authentication, locale detection, performance tier selection, fraud prevention, and basic UI state. These do not require consent under PECR / ePrivacy because they are essential to delivering the service you have requested.

Analytics & product analytics:Visitors from all 33 GDPR-equivalent jurisdictions — the 27 EU member states, the three EEA non-EU states (Iceland, Liechtenstein, Norway), the United Kingdom (UK GDPR + PECR), Switzerland (revFADP), and the UK Crown Dependencies and Gibraltar — see a consent banner on first visit and we do not load Google Analytics 4 or PostHog until you affirmatively accept analytics cookies. Pre-consent visitors in these markets generate zero requests to Google, PostHog, or any third-party analytics endpoint. Visitors from other countries (including Nigeria, per NDPR 2019) also see the banner. In non-consent markets, analytics load by default.

Withdrawing consent: If you have granted analytics consent, you can withdraw it at any time without reloading the page via the Cookie settings link in the page footer. Withdrawing immediately stops all analytics in your current session and clears analytics cookies from your browser. You can also clear the gs-cookie-consent cookie directly via your browser settings.

Each consent decision is recorded server-side with timestamp, locale, the policy version it was granted against (currently 2026-05-02), and the categories you accepted. You can retrieve your full consent history via the data export path described in Section 12 below (GDPR Article 15).

No advertising cookies are set by GreenSweep at any time, with or without consent. The advertising data sharing described in Sections 4 and 5 uses anonymised, aggregated signals; no advertising cookie is ever placed on your device.

12. Security & Your Rights

• TLS 1.3 encryption in transit; AES-256 encryption at rest (database provider default)
• Row-level database security
• Magic link authentication (no stored passwords)
• Regular security audits
• Append-only audit logs

Consent history export (Article 15): Authenticated users can retrieve their full cookie consent history via /api/consent/export. The response includes each decision's timestamp, country, locale, policy version, and categories accepted, enabling you to verify exactly what you consented to and when.

13. Data Protection Complaint

Malta's Information and Data Protection Commissioner (IDPC): idpc.org.mt

14. Children's Privacy

GreenSweep applies additional protections for younger users. The minimum registration age is 13 in most markets and 16 in Germany and Austria, consistent with GDPR Art. 8 and local digital-consent law.

What we do not do:

• We do not knowingly collect personal data from children below the applicable minimum age.
• We do not share data of users under 18 with advertising or Tier 2 research partners.
• We do not target users under 18 with commercial profiling or behavioural advertising.
• We do not display personalised ads to users who have indicated they are under 18.

Age gate: At registration we ask users to confirm they meet the minimum age for their market. We record this confirmation (including timestamp and market at time of confirmation) as part of our accountability records under GDPR Art. 5(2).

If we discover an underage account: We will immediately suspend data sharing for that account, delete any Tier 2 data already collected, and delete the account if the user is below the applicable minimum age. Parents or guardians may contact us at [email protected] to request account review or deletion.

Parental rights:Parents or guardians of users under 18 may request access to, correction of, or deletion of their child's data at any time by contacting our Data Protection Officer at [email protected].

Legal basis:For users aged 13–17 (or 16–17 in Germany, Austria, and Switzerland), we process data under legitimate interest (GDPR Art. 6(1)(f)) limited to providing the core voting and referral service. No consent-dependent processing — including advertising, data licensing, or behavioural profiling — is performed on accounts flagged as belonging to users under 18.

15. Changes

We update this policy periodically. Significant changes are announced via email or platform notice. Continued use means acceptance.